Overview

Assets Under Management: $5.6 billion
Headquarters: PITTSFORD, NY
High-Net-Worth Clients: 363
Average Client Assets: $6.9 million

Frequently Asked Questions

ALESCO ADVISORS, LLC, AN ESL COMPANY charges 0.90% on the first $0 million, 0.60% on the next $2 million, 0.40% on the next $10 million, 0.35% on the next $50 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #339091), ALESCO ADVISORS, LLC, AN ESL COMPANY is subject to fiduciary duty under federal law.

ALESCO ADVISORS, LLC, AN ESL COMPANY is headquartered in PITTSFORD, NY.

ALESCO ADVISORS, LLC, AN ESL COMPANY serves 363 high-net-worth clients according to their SEC filing dated April 20, 2026. View client details ↓

According to their SEC Form ADV, ALESCO ADVISORS, LLC, AN ESL COMPANY offers financial planning, portfolio management for individuals, portfolio management for institutional clients, selection of other advisors, and educational seminars and workshops. View all service details ↓

ALESCO ADVISORS, LLC, AN ESL COMPANY manages $5.6 billion in client assets according to their SEC filing dated April 20, 2026.

According to their SEC Form ADV, ALESCO ADVISORS, LLC, AN ESL COMPANY serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (ALESCO ADVISORS, LLC, AN ESL COMPANY)

MinMaxMarginal Fee Rate
$0 $500,000 0.90%
$500,001 $2,000,000 0.60%
$2,000,001 $10,000,000 0.40%
$10,000,001 $50,000,000 0.35%
$50,000,001 and above 0.30%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million Below minimum client size
$5 million $25,500 0.51%
$10 million $45,500 0.46%
$50 million $185,500 0.37%
$100 million $335,500 0.34%

Clients

Number of High-Net-Worth Clients: 363
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 44.43%
Average Client Assets: $6.9 million
Total Client Accounts: 1,777
Discretionary Accounts: 1,777
Minimum Account Size: $3,000,000
Note on Minimum Client Size: $3,000,000

Regulatory Filings

CRD Number: 339091
Filing ID: 2096544
Last Filing Date: 2026-04-20 14:57:35

Form ADV Documents

Primary Brochure: ALESCO ADVISORS, LLC, AN ESL COMPANY (2026-04-20)

View Document Text
Part 2A of Form ADV: Firm Brochure Cover Page (Item 1) Principal Office: 120 Office Park Way Pittsford, NY 14534 Phone: (585) 586-0970 Toll Free: (800) 277-3440 Email: info@alescoadvisors.com Website: www.alescoadvisors.com Date of Filing: March 30, 2026 This brochure provides information about the qualifications and business practices of Alesco Advisors, LLC, An ESL Company (“Alesco” or the “Firm”). If you have any questions about the contents of this brochure, please contact Benton Kircher at (585) 586-0970. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about Alesco is available on the SEC’s website at www.adviserinfo.sec.gov by searching for CRD number 339091. Part 2A of Form ADV: Firm Brochure Material Changes (Item 2) Material Changes (Item 2) This item describes the material changes since our prior brochure dated November 21, 2025. On November 21, 2025, ESL Newco I, LLC filed its initial Form ADV as a successor by application to Alesco Advisors, LLC (CRD 108590). The SEC approved that initial Form ADV on January 5, 2026, at which time ESL Newco I, LLC succeeded to the predecessor firm’s advisory business. On January 30, 2026, the predecessor firm, Alesco Advisors, LLC, filed Form ADV-W and withdrew its registration. On February 12, 2026, ESL Newco I, LLC changed its legal name to Alesco Advisors, LLC, An ESL Company. Other than these changes, there have been no material changes to our advisory business or this Brochure since November 21, 2025. 2 Part 2A of Form ADV: Firm Brochure Table of Contents Table of Contents Material Changes (Item 2) ............................................................................................................................................ 2 Table of Contents .......................................................................................................................................................... 3 Advisory Business (Item 4) ........................................................................................................................................... 4 Fees and Compensation (Item 5) ................................................................................................................................. 6 Performance Based Fees (Item 6) ............................................................................................................................... 8 Types of Clients (Item 7) .............................................................................................................................................. 9 Methods of Analysis, Investment Strategies and Risk of Loss (Item 8) ................................................................. 10 Disciplinary Information (Item 9) ............................................................................................................................... 11 Other Financial Industry Activities and Affiliations (Item 10) .................................................................................. 12 Code of Ethics (Item 11) ............................................................................................................................................. 13 Brokerage Practices (Item 12) ................................................................................................................................... 14 Review of Accounts (Item 13) .................................................................................................................................... 15 Client Referrals and Other Compensation (Item 14) ................................................................................................ 16 Custody (Item 15) ........................................................................................................................................................ 17 Investment Discretion (Item 16) ................................................................................................................................ 18 Voting Client Securities (Item 17) .............................................................................................................................. 19 Financial Information (Item 18).................................................................................................................................. 20 3 Part 2A of Form ADV: Firm Brochure Advisory Business (Item 4) Advisory Business (Item 4) On November 21, 2025, ESL Newco I, LLC (“Alesco” or the “Firm”) filed its initial Form ADV as a successor by application to Alesco Advisors, LLC (CRD 108590). The SEC approved that initial Form ADV on January 5, 2026, at which time ESL Newco I, LLC succeeded to the predecessor firm’s advisory business. On January 30, 2026, the predecessor firm, Alesco Advisors, LLC, filed Form ADV-W and withdrew its registration. On February 12, 2026, ESL Newco I, LLC changed its legal name to Alesco Advisors, LLC, An ESL Company. Background and Ownership: Alesco is organized as a limited liability corporation, with its principal office located in Pittsford, New York. Alesco continues the investment advisory business previously operated by Alesco Advisors LLC. Alesco Advisors LLC was founded in 2000 by James G. Gould. See Alesco’s ADV Part 1 for a more in-depth list of control persons and Individuals with a material ownership interest. Who We Serve: Alesco provides investment management services primarily to institutions (such as foundations, endowments, for-profit organizations, retirement plans, trusts, and estates) and high net worth individuals. For individual clients, limited financial, tax, estate, and insurance planning are provided to the extent agreed upon by the individuals and Alesco. These planning services are conducted in conjunction with the client’s other professional advisors. Discretionary Investment Management: Most clients grant Alesco discretionary day-to-day management authority through an investment management agreement and/or an investment policy statement. Prior to managing client assets, the Firm works with each client to establish an asset allocation plan and identify any client-specific restrictions. The Firm also collects relevant financial, tax, and fee information before implementing investment strategies aimed at achieving the client’s financial goals. Non-Discretionary Consulting Services: For select clients, Alesco provides consulting only services, in which it delivers recommendations, without discretionary authority. Examples include, but are not limited to, consolidated reporting, asset allocation analysis, securities analysis, investment manager evaluation, and retirement plan advisory services (including plan design and employee education.) Wrap Fee Programs: Alesco serves as portfolio manager in two wrap fee programs sponsored by LPL Financial Corporation (the “Sponsor”); the Manager Access Select Program, and the Manager Select Program. In these programs clients pay a single wrap fee to the Sponsor that covers investment management, custody, trading and certain administrative services. Alesco receives a portion of this fee for providing discretionary investment management of your account. Please see Fees and Compensation (Item 5) and Brokerage Practices (Item 12). Model Portfolio Program: Alesco participates in the Consulting Solutions Program, a “model portfolio” arrangement sponsored by RBC Wealth Management. We provide RBC with an asset allocation model and update it regularly. RBC has full discretion to accept, reject, or modify our recommendations and applies them to its clients’ accounts. Because RBC retains discretion, these assets are not included in our discretionary assets under management. RBC is responsible for executing trades and providing best execution. Clients pay fees directly to RBC, which then compensates Alesco with a portion of those fees. Financial Planning Services: Alesco offers financial planning services to individuals who may or may not be investment management clients. These services are designed to help clients evaluate their overall financial situation and develop strategies to meet their goals. Depending on the client’s needs, a financial plan may address areas such as cash flow and budgeting, retirement planning, investment allocation, education funding, 4 Part 2A of Form ADV: Firm Brochure Advisory Business (Item 4) insurance needs, and estate considerations. We provide recommendations in writing and may review them with the client to ensure understanding and implementation. For these services, Alesco charges a fixed financial planning fee, which is agreed upon in advance. Regulatory Assets Under Management (RAUM): As of February 28, 2026, Alesco reported approximately $5,611,340,728 in RAUM. In addition to RAUM, Alesco provides consulting services for which it does not exercise trading authority. These services may include investment policy development, security selection advice, investment manager analysis, and consolidated reporting. For these consulting services, Alesco receives a fee. As of February 28, 2025, assets under consulting arrangements totaled approximately $999,592,125. 5 Part 2A of Form ADV: Firm Brochure Fees and Compensation (Item 5) Fees and Compensation (Item 5) In most cases, client advisory fees are based on assets under management (in certain instances, Alesco will negotiate a fixed fee amount with the client, but these instances are generally rare). Alesco’s tiered fee schedule for managed accounts is provided below: 0.90% annually for amounts between $0-$500,000 0.60% annually for amounts between $500,000-$2,000,000 0.40% annually for amounts between $2,000,000-$10,000,000 0.35% annually for amounts between $10,000,000-$50,000,000 .30% annually for amounts above $50,000,000 Generally, fees are billed semi-annually in advance for a six-month period. Should an account terminate, a prorated rebate will be issued to the client for unearned fees. If the client terminates the Investment Management Agreement within the first five days after both parties have signed, he or she may do so without advance notice and any prepaid fees will be returned in their entirety. Although the fee schedule displayed above represents the standard management fees charged by Alesco, fees may be negotiable. This is determined on a case-by-case basis, and any variation from the above fee schedule must be approved by a senior manager at Alesco. Clients may be charged a minimum management fee that could effectively be higher than the fee that would be generated using the above fee schedule. This would generally apply to accounts that are under Alesco’s stated minimum account size. The presence of a minimum fee is fully disclosed to the client prior to signing an investment management agreement with Alesco. As discussed in Item 4, Alesco participates as an investment manager in two wrap programs and one model (overlay) programs. Though a client participating in these programs does not pay Alesco directly, a portion of the fee that they pay to the program sponsor is paid to Alesco in accordance with an agreement that Alesco has with each of the program sponsors. The total wrap fee could be greater than the fee charged directly to clients of Alesco that do not participate in these programs. However, the minimum account size accepted by Alesco is lower for clients in wrap programs. There are additional services provided by the wrap program sponsor that could also increase the overall wrap fee. Alesco does not have any control over the fee charged to the individual wrap program client. Alesco furnishes investment consultative services (for a full description of these services, see paragraph four of Item 4 in this document). Fees for consulting services are negotiated on an individual client basis taking into account the nature and number of services and size of the account. Typically, fees are deducted directly from a client’s account. A client receives a notice of the management fee (usually mailed), which discloses the amount of fees deducted from the account. A client also receives a statement from their independent custodian, which would reveal this amount after it is deducted. As an alternative, the client has the option to be invoiced for management fees, rather than having the fee deducted directly from the account. Brokerage commissions and miscellaneous brokerage fees (such as wiring fees or asset transfer fees) may also be incurred. When Alesco has the authority to select a broker-dealer custodian, minimizing these costs is taken into consideration during the selection process. These fees would be disclosed on a custodian statement and are also available from Alesco upon request. Separately, mutual fund and exchange traded fund expenses would affect the performance of an individual security held in a client’s portfolio. These expenses would be embedded in the unit price of a security and would not be listed on a client’s custodial 6 Part 2A of Form ADV: Firm Brochure Fees and Compensation (Item 5) statement. The expense ratio (the percentage of fees charged annually on an individual security) is available in the fund’s prospectus (also, Alesco can provide this information to the client upon request). Alesco does not recommend the use of “load funds.” Alesco does not accept compensation for the sale of securities or other investment products, including asset- based sales charges or service fees from the sale of mutual funds. Alesco provides financial planning services for individuals who are not currently investment management clients. For these services, Alesco receives a fixed financial planning fee. 7 Part 2A of Form ADV: Firm Brochure Performance Based Fees (Item 6) Performance Based Fees (Item 6) Alesco does not charge performance-based fees. Alesco typically charges an asset-based fee, calculated as a percentage of assets under management. For more information about our fees, please see Fees and Compensation (Item 5) of this brochure. 8 Part 2A of Form ADV: Firm Brochure Types of Clients (Item 7) Types of Clients (Item 7) Alesco has a stated account minimum of $3 million (for the purposes of this minimum, an account may be defined as a “client relationship,” which could consist of multiple accounts). In certain instances, Alesco makes exceptions for smaller relationships that Alesco feels may have the potential to achieve this minimum value. As stated in Item 5, clients participating in a wrap program or a model program have a minimum account size far less than the $3 million minimum. Alesco negotiates this minimum size with the wrap program sponsors. For greater detail on this, see Item 5. For a more complete discussion regarding the different types of clients to whom Alesco generally provides investment advice, see Item 4 in this document. 9 Part 2A of Form ADV: Firm Brochure Methods of Analysis, Investment Strategies and Risk of Loss (Item 8) Methods of Analysis, Investment Strategies and Risk of Loss (Item 8) Alesco invests its clients’ assets in accordance with each client’s needs. Alesco considers the investment time horizon of the client, the client’s ability to assume risk, the client’s need for income, the taxable nature of the client’s assets, and other factors to assist the client in formulating an asset allocation strategy. The implementation of the asset allocation involves buying and selling investment securities. This involves risk of loss that the client should be prepared to bear. The specific selection of investments is based on internal analysis of competing investment products. Alesco utilizes fundamental analysis and asset allocation theories, including quantitative modeling, to formulate investment decisions. Though Alesco may invest in a multitude of securities, index-based and systematic mutual funds and exchange traded funds (ETFs) are the most commonly recommended types of securities for accounts where Alesco serves as the discretionary investment manager. These types of securities seek investment results that correspond generally to the price and yield performance, before fees and expenses of a specific index or market segment. As with any equity and fixed income security, investment return and principal value of an investment will fluctuate so that a client’s shares, when sold or redeemed, may be worth more or less than the original cost. The primary risk associated with portfolios managed by Alesco is market risk. This is the risk that the overall market declines. This includes the equity market, the bond market, and the markets for other asset classes which may be used in a client’s portfolio. A risk specifically associated with index mutual funds and ETFs is tracking error. Tracking error occurs when an index mutual fund or ETF does not match the corresponding index return. This may be the result of the expense ratio charged on the index mutual fund or ETF (see Item 5 for a discussion on fund expense ratios), or numerous other factors. Alesco closely monitors each recommended mutual fund and ETF for tracking error and may choose to replace the security with a similar fund with lower tracking error. Individual ETFs and index funds are unable to significantly outperform the target index. By their very nature, it should not be the goal of the ETF or index fund manager to beat the index, but rather to replicate the index return. Alesco aims to optimize the client portfolio’s overall risk-adjusted return via diversified investment exposure across multiple assets classes. For some clients, depending on individual circumstances, Alesco invests in funds that own private assets. Such investments are also subject to illiquidity risk, where investors’ ability to access their capital when needed may be restricted. Operational risks may be greater for private investments, and they may lack diversification compared to publicly traded investments. Valuing private investments may involve subjective judgments and may not accurately reflect their true market value. Private investments typically offer limited disclosure and transparency compared to publicly traded securities and often charge management fees, performance fees, and other expenses which impact an investor’s return. 10 Part 2A of Form ADV: Firm Brochure Disciplinary Information (Item 9) Disciplinary Information (Item 9) There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or integrity. 11 Part 2A of Form ADV: Firm Brochure Other Financial Industry Activities and Affiliations (Item 10) Other Financial Industry Activities and Affiliations (Item 10) Alesco is not a broker/dealer, banking or thrift institution, accounting firm, law firm or trust company. Financial Industry Affiliates: Alesco, ESL Investment Services, LLC (a FINRA member broker-dealer), and Cooper/Haims Advisors, LLC (a SEC registered investment advisor) are wholly owned by ESL HoldCo, LLC. ESL Holdco, LLC and ESL Trust Services, LLC (a New York limited Trust Company) are wholly owned by ESL Federal Credit Union. 12 Part 2A of Form ADV: Firm Brochure Code of Ethics (Item 11) Code of Ethics (Item 11) Alesco maintains a Code of Ethics, which, among other topics, addresses employee trading activities in their personal accounts. Employees are prohibited from engaging in transactions which may put their interests ahead of client interests. Supervision of transactions is accomplished through required quarterly personal transaction reports and annual securities holdings reports. The Code requires all employees to comply with applicable securities laws, to report violations of the Code or such laws to Alesco’s Chief Compliance Officer, to obtain consent to trade or recommend certain securities (such as certain securities held in client accounts) for their own accounts, and to abstain from trading for their own accounts or recommending any securities placed on Alesco’s Prohibited List (such as securities of issuers where an Alesco employee or client is an insider or has material non-public information about such issuers). Securities also include options on securities. In addition, there are restrictions on the value of gifts that an employee may accept from a client, person, or firm doing business with Alesco. There are also restrictions related to employee negotiation of personal account brokerage fees with brokers doing business with Alesco. An employee may not for his or her own account sell securities to or purchase securities from a client nor may the employee without prior written consent of the Chief Compliance Officer, serve as a director, general partner, or trustee of a public corporation or partnership. Alesco does not recommend securities to clients in which Alesco has a material financial interest. Employees are allowed to purchase securities that are recommended to clients. Although most of Alesco’s recommended securities would be classified as non-reportable (securities, such as open-end mutual funds, that would not need to be reported under SEC rule 204A-1(e)(10)), the Code of Ethics establishes the proper procedures for pre-clearing trades through the firm’s compliance officer and/or portfolio management staff. This pre-clearance requirement would help to ensure that the employee is not front-running a client order in a particular security (which is a risk for any investment firm dealing with reportable securities not excluded from the SEC rule). A complete copy of the Code of Ethics may be obtained free of charge upon request to Alesco. 13 Part 2A of Form ADV: Firm Brochure Brokerage Practices (Item 12) Brokerage Practices (Item 12) Alesco does not obtain any soft dollar benefits from any of its broker-dealer custodians. A “soft dollar” arrangement refers to an established agreement between an investment manager and a broker-dealer that would encourage a manager to place a trade with a particular broker-dealer in exchange for services that are for the benefit of the investment manager’s clients. Although this is a common industry practice, Alesco does not participate in this type of arrangement. Most of the broker-dealer custodians that Alesco recommends to clients provide research materials upon request (or they allow Alesco access to their database of education or research-related materials, often provided to all advisors who do some form of business with the custodian). As stated above, Alesco is under no formal agreement to direct business with these broker-dealer custodians and the availability of such materials has minimal influence on the recommendation Alesco provides to clients regarding custodial selection. For various reasons, clients sometimes direct Alesco to work with a particular broker-dealer of their (the client’s) choosing. In these instances, Alesco’s ability to negotiate commissions may be affected and Alesco may be unable to obtain the best price and execution for the client’s account. This may result in the client paying higher commissions than would be available from other brokers. It may also result in restrictions upon the securities available for purchase or sale for the client’s account, such as (1) the purchase of bonds where the designated broker may have a limited inventory and, therefore, may be unable to offer the desired bonds to the client, or (2) the purchase or sale of certain mutual funds which may not be custodied with all brokers. The inability to purchase or sell such securities may affect the overall portfolio return. Alesco will sometimes aggregate multiple client trades as one order to obtain the same price execution. This typically occurs when the firm makes a firmwide trade. Orders for each security purchase and/or sale are often blocked for accounts by custodian, and a policy establishes the order of placement by each custodian for certain firmwide trades. Alesco generally places trades on an individual client basis. Many of the custodians that are utilized by clients of Alesco provide various support services to Alesco. Some of those services help us manage or administer our clients’ accounts. Several support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The availability to us of the custodians’ products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Several custodians also provide access to resources (such as technology consulting, publications, and access to educational materials or presentations). The wrap program sponsor has retained Alesco through a separate investment advisory contract. Wrap program clients should note that Alesco will execute transactions for their accounts through the wrap sponsor. Execution prices through a wrap sponsor may be less favorable in some respects than Alesco’s clients whose trades are not executed through the wrap sponsor. This is because Alesco may not have the ability to negotiate price or take advantage of combined orders or volume discounts. Wrap program sponsors may limit (or altogether prohibit) Alesco’s ability to purchase certain mutual funds that would typically be held in a standard Alesco-managed account. In these instances, a comparable exchange traded fund is used as an alternative. This could have a small effect on the overall performance of the account when compared with non-wrap program accounts. 14 Part 2A of Form ADV: Firm Brochure Review of Accounts (Item 13) Review of Accounts (Item 13) Reviews range from one to four or more times per year. The frequency of reviews depends in part upon events impacting the client or assets of the client, as well as the schedule of the client. Events that can trigger a review include changes in the conditions of the securities markets, a change in the financial status or goal of the client (including cash inflows or outflows), or a change in the marital or other status of the client (or in that of any related person). Reviews are generally conducted in person (or through the use of video conferencing technology) by one or more representatives of Alesco, such as the President, a Principal, a client advisor, and/or the Chief Investment Officer. Written reviews are typically provided. When the client cannot formally meet with one of the aforementioned Alesco representatives, they may request a written review. In-person reviews for clients of any program discussed in Item 4 (wrap, overlay, and automated investment programs) are not typically conducted unless the client requests a meeting. Upon request, Alesco will make a reasonable effort to schedule a review in-person, by video conference, or by telephone. 15 Part 2A of Form ADV: Firm Brochure Client Referrals and Other Compensation (Item 14) Client Referrals and Other Compensation (Item 14) Alesco does not receive an economic benefit for providing investment advice or other advisory services to its clients from someone who is not a client. Alesco does not currently provide compensation for client referrals to anyone who is not an employee of Alesco. 16 Part 2A of Form ADV: Firm Brochure Custody (Item 15) Custody (Item 15) Alesco can deduct fees from client accounts and therefore, by definition, has custody of client assets. Aside from this, Alesco utilizes the services of several qualified broker-dealer custodians to place trades on client accounts and physically custody client assets. These custodians provide account statements at least quarterly (and, in most cases, statements are issued monthly). Clients should carefully review those statements. Alesco does not formally issue statements, however, clients are encouraged to compare Alesco- prepared performance review material and billing statements with the figures provided by their independent custodian. Alesco has obtained client-provided website credential information (including personal usernames and passwords) for a few clients. This would allow select employees of Alesco to access client accounts at a qualified custodian. Without this information, the firm would otherwise not be able to access these accounts. The websites allow users the ability to transfer assets (Alesco retains credential information for several other clients as well, but Alesco does not have the ability to transfer assets out of the accounts on these sites). An employee of Alesco serves as a trustee on two separate trust account relationships managed by Alesco. For some accounts, clients have provided Alesco the ability to process third-party transfers from their investment account to an outside third-party (such as a bank account or service provider not matching the name on the originating client account). Alesco has strict procedures in place to verify these requests. Alesco has retained an independent accounting firm to perform an annual surprise exam to review custody situations where such an exam is required. 17 Part 2A of Form ADV: Firm Brochure Investment Discretion (Item 16) Investment Discretion (Item 16) Alesco accepts discretionary authority to manage securities accounts on behalf of clients. Alesco accommodates restrictions and limitations clients place on this authority. In instances where Alesco is awarded discretionary authority by the client, an investment management agreement is established between both parties (Alesco and the client) that, among other items, establish a limited power of attorney. Separately, a limited power of attorney is often required by the client’s independent custodian. This requires the client to allow Alesco access to trade the account and perform other basic administrative services. 18 Part 2A of Form ADV: Firm Brochure Voting Client Securities (Item 17) Voting Client Securities (Item 17) Alesco has adopted a policy concerning the voting of proxies on securities held by it for clients (which covers proxies on all securities held by Alesco for clients except those as to which a client has specifically retained voting authority), as well as the resolution of any conflicts between Alesco and such clients concerning voting. This policy will be furnished, upon request, without charge to any client and, otherwise, as required by law. The policy provides, among other things, that any proxies for exchange-traded funds are voted by Alesco since Alesco conducts research on these securities. However, Alesco does not conduct research on individual stocks in clients’ accounts since these are often held at the direction of the client. Thus, in the case of individual stocks, Alesco abstains from voting unless on the face of it, a proposition is so egregious that action is mandated. The policy also requires that any material conflict between Alesco (and any of its personnel) and a client relating to the voting of a proxy be resolved with the client’s consent after disclosure or resolved completely in the client’s favor. For purposes of an ERISA-based retirement plan, Alesco votes proxies for the sole benefit of the plan participants. Records of voting are retained and any client may receive, upon written request and free of a charge, a summary of how Alesco voted any securities held in the client’s account. 19 Part 2A of Form ADV: Firm Brochure Financial Information (Item 18) Financial Information (Item 18) Since Alesco requires a prepayment of more than $1,200 in fees per client, six months or more in advance, a balance sheet from the most recent fiscal year is included with this document. There is no known financial condition that is reasonably likely to impair Alesco’s ability to meet contractual commitments to clients. Alesco has not been the subject of a bankruptcy petition at any time during the past ten years. 20