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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.
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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
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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,
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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