CASTLETON PARTNERS, LLC

Castleton Partners, LLC 71 Moore Road Clermont, NY 12526 212-832-9700 www.castletonpartners.com April 17, 2026 FORM ADV PART 2 BROCHURE This brochure provides information about the qualifications and business practices of Castleton Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 212-832-9700. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Castleton Partners, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Castleton Partners, LLC is 140873. Castleton Partners, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the filing of our last annual updating amendment, dated February 9, 2026, we have the following material changes to report: • • • • Disclosed a description of, and fee schedule for, the "Diversified Portfolio Strategy" as part of our asset management services (see Item 4, Item 5, and Item 8); Disclosed a description of, and fees related to, the "Investment Reporting" offering as part of our portfolio consulting and investment reporting services (see Item 4 and Item 5); Disclosed the potential use of independent third-party investment managers as part of the "Diversified Portfolio Strategy" (see Item 4 and Item 8); Updated Item 10 "Other Financial Industry Activities and Affiliations" to reflect our utilization of a Sub-Adviser; Updated Item 17 to reflect Sub-Adviser's discretionary authority to vote client proxies • 2  Item 3 Table Of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table Of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Item 20 Additional Information Page 1 Page 2 Page 3 Page 4 Page 6 Page 7 Page 8 Page 9 Page 14 Page 14 Page 14 Page 15 Page 16 Page 17 Page 17 Page 18 Page 18 Page 18 Page 18 Page 18 3  Item 4 Advisory Business Description of Services and Fees Castleton Partners, LLC ("Castleton") is registered as an investment adviser with the United States Securities and Exchange Commission and we are based in Clermont, NY. We are organized as a limited liability company under the laws of the State of Delaware and we have been providing investment advisory services since 2005. Reinoso & Company, LLC (which is owned by the Marital Trust Established Under The Edward J Reinoso Living Trust dated 5.27.2020) is our principal owner. We are a fee-only independent investment adviser providing asset management services to high net worth individuals, families, and foundations. The following paragraphs describe the services we offer. Please refer to the description of each advisory service listed below for information on how we tailor our advisory services to your individual needs. For information about the fees associated with each service, please refer to Item 5 "Fees and Compensation". Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, owners, employees, and all individuals providing investment advice on behalf of our firm. Asset Management Services We primarily offer discretionary asset management services to our clients and prospective clients. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for asset management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. Based on the strategy selected, we will develop a written Investment Policy Statement or investor profile with investment guidelines tailored to your specific needs. We will use this information to provide continuous and focused investment advice and/or to make investments on your behalf. Once your portfolio is constructed, we will monitor it on an ongoing basis and rebalance as needed in response to changes in market conditions and your financial circumstances. We require you to grant our firm discretionary authority to manage your account unless you have engaged our firm for non-discretionary services. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the Investment Management Agreement ("IMA") you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the credit quality or interest coupon rates of fixed income securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. As part of our asset management services, we may use an unaffiliated registered investment adviser ("Sub-Adviser") to manage a portion or all of your account assets on a discretionary basis. Please see Item 10 "Other Financial Industry Activities and Affiliations" for additional information. We will regularly monitor the performance of your accounts managed by the Sub-Adviser and may hire and fire any Sub-Adviser with prior notice to you. We may pay a portion of our advisory fee to the Sub-Adviser, however, you will not pay our firm a higher advisory fee as a result of a sub-advisory relationship. Our asset management services are offered by strategy: "Investment Grade Fixed Income Strategy" "Diversified Portfolio Strategy" "Special Strategies" • • • Each strategy is described more fully below in Item 5 "Fees and Compensation" and Item 8 "Methods of Analysis, Investment Strategies and Risk of Loss." 4  Portfolio Consulting and Investment Reporting Services We offer portfolio consulting services to prospective high net worth and institutional clients. If you retain our firm for portfolio consulting services, we will meet with you to review your portfolio of investments and provide you with a summary analysis of your portfolio including but not limited to advice on your exposure to risk, maturity strategy and other relevant subjects. We may also be engaged to provide ongoing reviews of your portfolio. In the event we provide any recommendations to you, it shall be your responsibility to implement any advice we provide. We also offer investment reporting services for investments and/or accounts that are not managed by Castleton or for which Castleton does not provide investment advice ("Unmanaged Assets). Portfolio consulting and investment reporting services clients may also retain us to provide asset management services as described above for a separate fee. Types of Investments We primarily offer advice on, and invest in, a broad range of municipal bonds, corporate debt securities, mutual funds, closed end funds, and exchange-traded funds ("ETFs"). We may also provide advice on, and invest in, preferred equities, taxable securities, commercial paper, agency securities, United States Government securities, options, and third-party investment managers (see "Use of Independent Managers", below). Additionally, we may advise you on other types of investments that we deem appropriate based on your stated goals and objectives. We may also provide advice on other types of investments held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in specific securities or certain types of securities. You must provide these restrictions to our firm in writing. Use of Independent Managers When consistent with your investment objectives, we may recommend that clients who are "accredited investors" as defined under Rule 501 of the Securities Act of 1933 ("Securities Act") or "qualified purchasers" as defined under Section 2(a)(51) of the Investment Company Act of 1940 ("Investment Company Act"), as amended, invest in strategies offered by one or more third-party asset managers ("Independent Manager") through private placement securities, which may include debt, equity, and/or pooled investment vehicles (e.g., hedge funds). The specific terms and conditions under which we engage an Independent Manager are set forth in a separate written agreement between Castleton and the Independent Manager. We and our Sub-Adviser provide services that include the discretionary selection, ongoing monitoring, and review of the Independent Manager and your accounts managed by them. We may hire or terminate any Independent Manager as appropriate. We generally receive an annual advisory fee based on a percentage of the market value of the assets managed by the Independent Manager. You will not pay a higher advisory fee to our firm because of these arrangements. When recommending an Independent Manager for a client, we, together with our Sub-Adviser, review information about the Independent Manager, such as its disclosure Brochure Document and/or material supplied by the Independent Manager or independent third parties, for a description of the Independent Manager's investment strategies, past performance, and risk results, to the extent available. We retain oversight responsibility for all Independent Manager selections made on your behalf. Factors that we consider in recommending an Independent Manager include your stated investment objectives and the manager's management style, performance, reputation, financial 5  strength, reporting, pricing, and research. The management fees charged by the designated Independent Manager, together with the fees charged by the corresponding designated broker- dealer/custodian of your assets, are exclusive of, and in addition to, our investment advisory fee. An Independent Manager may impose more restrictive account requirements and different billing practices than we do. In such instances, we may alter our corresponding account requirements and/or billing practices to accommodate those of the Independent Manager. Assets Under Management As of March 31, 2026, we provide continuous management services for $88,704,844 in client assets on a discretionary basis, and $52,164,358 in client assets on a non-discretionary basis. Item 5 Fees and Compensation Below is information about our advisory fees, fee deduction arrangements, and refund policy according to each service we offer. Refer to the preceding "Advisory Business" section of this Brochure for descriptions of each service. Asset Management Services Our fee for asset management services is based on a percentage of your assets which we manage and is set forth in the fee schedule below. Portfolio Size Annual Fee** Investment Grade Fixed Income Strategy Value of Account Assets Value of Account Assets Value of Account Assets $2,000,000 to $9,999,999 $10,000,000 to $49,999,999 Over $50,000,000 .40% .35% Negotiable Diversified Portfolio Strategy Value of Account Assets Value of Account Assets Value of Account Assets $2,000,000 to $9,999,999 $10,000,000 to $24,999,999 Over $25,000,000 .85% .60% .50% Special Strategies Value of Account Assets All amounts 1.0% ** For the Investment Grade Fixed Income Strategy, we impose a minimum fee of $2,000 per quarter or .40% per annum of the value of assets we manage, whichever is greater. For the Diversified Portfolio Strategy, the minimum fee is the greater of $4,250 per quarter or .85% per annum. Our annual asset management fee is billed and payable quarterly in advance based on the closing value of managed holdings, including cash balances, as of the last day of the previous quarter. Our minimum account size is $2,000,000, however, at our discretion we may accept a lower account size. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for 6  you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. We will send you an invoice for the payment of our advisory fee or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. You may terminate the asset management agreement upon 5 days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Portfolio Consulting and Investment Reporting Services We charge either a negotiable hourly fee or a negotiable flat fee for portfolio consulting services. Fees and fee-paying arrangements will be determined with each client on a case-by-case basis and depend on the scope and complexity of the services provided. You may terminate the portfolio consulting agreement upon 5 days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the amount of work we have performed. We charge .10% per annum for reporting on Unmanaged Assets that are publicly available on a securities exchange or over-the-counter market. However, the fee may be greater for some asset types, due to increased complexity. In such cases, the fee is negotiable. Generally, our fee will not exceed 0.25% of the Unmanaged Assets and is billed quarterly in advance and based on the market value of the Unmanaged Assets as of the last day of the previous quarter. Additionally, we may offset all or a portion of our fees for investment reporting services based upon the amount paid for the asset management services. Additional Fees and Expenses As part of our investment advisory services, we may invest in, or recommend that you invest in, mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through which your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this Brochure. Item 6 Performance-Based Fees and Side-By-Side Management In some cases, in addition to an asset-based fee, we may also charge certain "qualified clients" as that term is defined in applicable securities laws and regulations, who generally are persons who have a net worth greater than $2,200,000 or for whom we manage at least $1,100,000, immediately after 7  entering into an investment advisory agreement, a performance-based fee. Performance-based fees are fees based on a share of realized capital gains or capital appreciation of a client's account. Our performance-based fees may be negotiated with each client on a case-by-case basis. We may manage individual accounts which may be charged higher annual fees (e.g., as in the case of Special Strategies) or performance-based fees while at the same time managing accounts (perhaps with similar or different objectives) that are not charged higher annual fees or performance-based fees ("side-by-side management"). This may create conflicts of interest, which we have identified and described in the following paragraphs. In any event, clients may be able to obtain the same or similar services from other advisers for lower fees. Performance-based fees or higher annual fees (e.g., for Special Strategies) may create an incentive for our firm to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement or higher annual fee. In order to address this potential conflict of interest, a senior officer of our firm reviews accounts to ensure that investments are suitable and that the account is being managed according to the client's investment objectives and risk tolerance. Additionally, performance-based fees are only applicable to eligible separately managed accounts that are established following the execution of an addendum to our Investment Management Agreement. We may receive increased fees on allocations as a result of realized gains in managed accounts. Performance-based fees or higher annual fees may also create an incentive for our firm to overvalue investments which lack a market quotation. To address such conflict, we have adopted policies and procedures that require our firm to "fairly value" any investment that lacks readily ascertainable value. Side-by-side management may also provide an incentive for our firm to favor accounts for which we receive a performance-based fee or higher annual fee. For example, we may have an incentive to allocate limited investment opportunities to clients who are charged performance-based fees over clients who are charged asset-based fees only. We have adopted policies and procedures designed to ensure the fair treatment of all clients, with all investment decisions made in your best interests, regardless of fee structure. We retain discretion to allocate trades as we see fit. Item 7 Types of Clients We offer investment advisory services to individuals, trusts, estates, charitable organizations, corporations, and other business entities. In general, we require a minimum of $2,000,000 to open and maintain an advisory account. At our discretion, we may waive this minimum account size. For example, we may waive the minimum if you appear to have significant potential for increasing your assets under our management. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. 8  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Recommendation of Particular Types of Securities Our investment strategies and advice vary depending upon your specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. In implementing our strategies, we may rely on a Sub-adviser, Independent Manager, or analysis and advice from consultants. Investment Grade Fixed Income Strategy The primary investment objective of this strategy is to attain an income-focused rate of return with a prudent level of risk, achievable from a portfolio of publicly traded securities. These securities include, but are not limited to, fixed income securities, exchange traded funds, preferred stock, and mutual funds. On occasion, we may also advise on and invest in taxable securities, commercial paper, agency securities, and U.S. Government Securities. We examine the credit rating of each issue to determine the suitability of the investment for you. Our investment strategy is to purchase fixed income securities for the long term, generally greater than one year. We generally limit our selection of bonds to high credit quality. The primary risk associated with this investment analysis is that we rely, in part, on the accuracy of third-party rating services when purchasing investments for you. Although we utilize well known rating companies such as Moody's, Standard & Poor's, and Kroll, it is possible that information provided may not be accurate. Diversified Portfolio Strategy This strategy aims to provide you with an optimal asset allocation. Under our oversight, our Sub- Adviser places focus on diversification and tax- and cost-efficiency, allocating across mutual funds, ETFs, individual securities, options, third-party asset managers, and other investments. Implementation of this strategy begins with selection of an appropriate benchmark, consisting primarily of widely recognized market indexes, based on your agreed-upon goals and level of risk. Your benchmark is updated as needed, typically due to a material change inyour risk profile or as a result of a predetermined asset allocation strategy that gradually shifts your portfolio's allocation over time. Core asset allocation is based on the expected performance of each asset class during various macroeconomic scenarios. Forward-looking scenario analysis is used to evaluate portfolio risk and optimize allocations, following examination of the fundamental links between asset classes. Asset allocation and rebalancing do not guarantee investment success. All investment strategies have the potential for profit or loss. Changes in investment strategies, contributions or withdrawals, and economic conditions, may materially alter the performance of your portfolio. Past performance is no assurance of future success. There are no assurances that a portfolio will match or outperform any particular benchmark. Special Strategies From time-to-time we may analyze, recommend and invest in situations with higher risk, and the potential for corresponding higher returns, including but not limited to investment in high yield securities and distressed issues and issues of distressed issuers. The underlying principles guiding 9  Special Strategies portfolio decisions are to capitalize on opportunities in the corporate and tax-exempt bond markets. The opportunities seek to include potential capital gains, as well as income. The risks of any particular Special Strategy may not be suitable for all clients. See "Risk of Loss" below. Within these Special Strategies, it is expected that the majority of bonds will be purchased at discounts to par value. Some bonds may include bond insurance. This investment style may have a higher turnover rate than other strategies, as it is a very actively managed portfolio. Bonds are bought when we feel the price justifies the risk and sold either to take a profit or cut losses where we deem necessary. Use of Margin Castleton does not explicitly use leverage (margin) as part of any investment strategy, however a Sub- Adviser, Independent Manager, or some fund products that we may recommend to you may utilize margin. When purchasing securities on margin, money is borrowed to purchase a security, in which case the security serves as collateral on the loan. In a margin account, a minimum balance must be maintained before the broker will force the borrower to deposit more funds or sell stock to pay down the margin loan (known as a margin call). If, for any reason, a borrower is unable to meet a margin call, the borrower's brokerage firm has the right to sell securities without consulting the borrower. In a margin account, a borrower could potentially lose more money than the borrower has invested. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. This risk includes the risk of illiquidity and the risk that you could lose part or all of your investment. There is no guarantee that any strategy will perform as expected. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. General Investment Risk. You should be aware that you may lose all or part of your investment. We believe that the risk to each client's portfolio is moderated through careful selection of investments. However, we make no guarantee or representation that your investments will be successful. Concentration of Holdings. Except as set forth in non-discretionary accounts, there are no restrictions on the amount of a portfolio that may be invested in a particular security, geographic region, industry or sector. Thus, at any given time, it is possible that your investments may be concentrated in a particular geographic region, industry or sector, or a limited number or type of securities. This limited diversity could expose your portfolio to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those investments. Value Investing Risk. To the extent a Special Strategy pursues a value-oriented investment approach by attempting to identify credits that are undervalued, such an investing style may perform better or worse than equity and bond portfolios that have a broader investment style. A value investment is typically identified when 1) It may be significantly cheap with respect to long-term historical valuation; 2) It may be cheap relative to future prospects; and 3) It may offer a prospective return that, to compensate for potential risks, exceeds returns available in the broader market. A value investment may decrease in price or may not increase in price as anticipated if it continues to be undervalued by the market or if the factors believed to cause the security's price to increase do not occur. 10  Illiquid Investments. To the extent that a Special Strategy invests in securities that are subject to legal or other restrictions on transfer or for which no liquid market exists, it may be subject to specific risks associated with such securities. The market prices, if any, for such securities tend to be volatile and you may not be able to sell them when you desire to do so or to realize what you perceive to be a fair value in the event of a sale. The sale of illiquid securities often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of securities eligible for trading on national securities exchanges or in the over-the-counter markets. Investment positions in illiquid securities could prevent you from liquidating unfavorable positions promptly and subject your portfolio to substantial losses. Investments in Distressed Securities. To the extent that your portfolio is invested in securities and private claims and obligations of domestic and foreign entities which are experiencing significant financial or business difficulties, such as loans, loan participations, claims held by trade or other creditors, non-performing and sub-performing mortgage loans, partnership interests and similar financial instruments, most of which are not publicly traded, it may be subject to a substantial degree of risk. A portfolio may lose a substantial portion or all of its investment in a troubled loan or equity interest or may be required to accept cash or securities with a value less than its share of the investment. Among the risks inherent in investments in troubled entities is the fact that it frequently may be difficult to obtain information as to the true condition of such entities. Market Disruption and Geopolitical Risk. A portfolio is subject to the risk that geopolitical events will disrupt securities markets and adversely affect global economies and markets. War, terrorism, pandemics, and related geopolitical events have led, and in the future may lead, to increased short- term market volatility and may have adverse long-term effects on U.S. and world economies and markets generally. Likewise, systemic market dislocations of the kind surrounding the insolvency of Lehman Brothers in 2008 may be highly disruptive to economies and markets. Those events as well as other changes in U.S. and foreign economic and political conditions also could adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment, and other factors affecting the value of a portfolio's investments. At such times, a portfolio's exposure to the risks described in this Item will likely increase. Market disruptions can prevent us from implementing a given strategy for a period of time and achieving an investment objective. Cyber Risk. Investment advisers, including Castleton, must rely in part on digital and network technologies ("cyber networks") to maintain substantial computerized data about activities for client accounts and otherwise conduct their businesses. Such cyber networks might in some circumstances be subject to a variety of possible cybersecurity incidents or similar events that could potentially result in the inadvertent disclosure of confidential computerized data or client data to unintended parties, or the intentional misappropriation or destruction of data by malicious hackers seeking to compromise sensitive information, corrupt data, or cause operational disruption. Cyber-attacks might potentially be carried out by persons using techniques that could range from efforts to electronically circumvent network security or overwhelm websites to intelligence gathering and social engineering functions aimed at obtaining information necessary to gain access. Castleton maintains policies and procedures on information technology security. It has certain technical and physical safeguards intended to protect the confidentiality of its internal data and takes other reasonable precautions to limit the potential for cybersecurity incidents and to protect data from inadvertent disclosure or wrongful misappropriation or destruction. Nevertheless, despite reasonable precautions, the risk remains that cybersecurity incidents could potentially occur, and such incidents, in some circumstances, might result in unauthorized access to sensitive information about Castleton or its clients or their investors and/or cause damage to client accounts or Castleton's activities for clients or their investors. Castleton will 11  seek to promptly notify affected clients and investors of any known cybersecurity incident that may pose a substantial risk of exposing confidential personal data about such clients or investors to unintended parties. Use of Independent Managers. We may recommend the use of one or more independent investment managers for certain clients. In these cases, we will continue to perform ongoing due diligence of such managers, but such recommendations rely, to a great extent, on the Independent Manager's ability to successfully implement their investment strategy. In addition, Castleton and our Sub-Adviser cannot supervise the Independent Manager on a day-to-day basis other than as previously described in Item 4, above. Additionally, in the management of certain accounts, we may also consider investment recommendations/signals from one or more Investment Manager. Fixed Income Securities. Fixed income securities, including, without limitation, bonds, notes and debentures issued by corporations, debt securities issued or guaranteed by a government or one of its agencies or instrumentalities, and commercial paper, pay fixed, variable or floating rates of interest. To the extent a portfolio is invested in fixed income securities, the value of such securities will change in response to fluctuations in interest rates. In addition, the value of certain fixed-income securities can fluctuate in response to perceptions of credit worthiness, political stability or soundness of economic policies. Fixed income securities are subject to the risk of the issuer's inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). Investments in unrated or lower grade debt securities are subject to greater risk of loss of principal and interest than higher rated debt securities. Special Strategies may invest in debt securities which rank junior to other outstanding securities and obligations of the issuer, all or a significant portion of which may be secured on substantially all of that issuer's assets. Additionally, Special Strategies may invest in debt securities that are not protected by financial covenants or limitations on additional indebtedness. In addition, fixed income securities are subject to interest rate risk. Interest rate risk is the risk that a bond may decrease in value in the event of a rise in interest rates. The longer the term of the bond, the more the bond's value is likely to drop when interest rates rise. Municipal Securities. Municipal bonds, while generally thought of as safe, can have risks associated with them including, but not limited to, the credit worthiness of the governmental entity that issues the bond as well as the stability of the revenue stream that's used to pay the interest on the security. Most municipal securities are rated by rating agencies, which identify the credit risk of the issue. Corporate Bonds. Corporate bonds are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, the maturity of the bond, and whether or not the bond can be "called" prior to maturity. Certificates of Deposit. Certificates of deposit are generally the safest type of investment since they are insured by the federal government up to a certain amount. However, because the returns are generally very low, it's possible for inflation to outpace the return. Likewise, US Government securities are backed by the full faith and credit of the United States government but it's also possible for the rate of inflation to exceed the returns. 12  Preferred Stock Securities. Preferred stock shares are commitments by a company to pay a set amount of interest to shareholders. Preferred shares have some characteristics that make them unique. First, just as with common stock, preferred stockholders are behind bond holders in line for a company's assets if it runs into a financial problem. If a company fails, money is repaid to bondholders first. The preferred stockholders are merely shareholders; no debt is owed to them. This adds default risk to preferred stock and, just as with dividends paid on common stock, a company may decide it no longer wants to pay the preferred dividend. Additionally, unlike with equity shareholders, who may benefit from the potential growth in the value of a company, but just like with those holding conventional bonds, preferred shareholders' investment return is a function of the fixed-dividend yield. The difference is that all conventional bonds have a fixed maturity date, while preferred stocks, as equity instruments, may not. Even those preferred stocks with call dates will not necessarily be called. A characteristic of callable preferred stocks is that almost all callable preferred stocks are callable at par, which means there is extremely limited upside potential if the security is purchased at par, and virtually none if the call date is near. Preferred stock pays dividends at the discretion of the company, but only after common equity dividends have been suspended. In times of financial distress, preferred dividends could be deferred. Preferred stocks can have call features, and therefore be related to interest rate changes. If the company's credit deteriorates, it will likely not call in the preferred stock, but the price of the preferred will fall due to the deteriorated credit. Ratings changes can also impact the likelihood of the company refinancing the preferred. While longer-term maturities with fixed yields do provide a hedge against deflationary environments, similar to any fixed income instrument with a call feature, the call feature negates the benefits of the longer maturity in a falling rate environment. High Yield Securities. High-yield securities, like most fixed income securities, are generally not exchange-traded and some of these instruments trade in a smaller secondary market, which may affect liquidity. To the extent a portfolio is invested in high yield debt securities, investing in such securities involves risks, which are greater than the risks of investing in higher rated debt securities. These risks include: (1) changes in credit status, including weaker overall credit conditions of issuers and risks of default; (2) sector, market and economic risk; (3) interest rate fluctuations; and (4) greater price variability and credit risks of certain high yield securities such as zero coupon and payment-in- kind securities. While these risks provide the opportunity for maximizing return over time, they may result in greater upward and downward movement of the value of a portfolio. Furthermore, the value of high yield securities may be more susceptible to real or perceived adverse economic, issuer or industry conditions than is the case for higher rated securities. The market values of speculative and unrated debt instruments tend to reflect individual issuer developments to a greater extent than do higher-rated securities. Adverse market, credit or economic conditions could make it difficult at certain times to sell certain high yield securities. Mutual Funds and ETFs. Mutual funds and exchange traded funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short- term money market instruments, other mutual funds, other securities or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. 13  Exchange traded funds differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely, which can dilute other investors' interests. Options. Options are contracts that grant the right, but not the obligation, to buy or sell an underlying asset at a specified price within a certain timeframe. Options transactions involve risks including the risk of total loss of the premium paid, the risk that the price of the underlying security may move unfavorably, and the risk that the option may expire worthless. Writing (selling) options involves potentially unlimited risk of loss. Item 9 Disciplinary Information Neither our firm nor our principal owners have any legal or disciplinary events, material or otherwise. Item 10 Other Financial Industry Activities and Affiliations We have entered into a sub-advisory arrangement with a registered investment adviser to provide asset management services for certain strategies, as described in Item 4 of this Brochure. The Sub- Adviser is an SEC-registered investment adviser. The Sub-Adviser may be affiliated with entities that manage private investment funds. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Client Relations at (212) 832-9700 or info@castletonpartners.com. Personal Trading Practices Our firm or associated person may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. 14  Item 12 Brokerage Practices We execute transactions through the custodian/broker-dealer that you elect to use. In cases where you do not instruct us to use a specific custodian/broker, we recommend the brokerage and custodial services of Fidelity Brokerage Services LLC. Our firm has an arrangement with National Financial Services LLC ("NFS") and Fidelity Brokerage Services LLC ("FBS") (collectively, and together with all affiliates, "Fidelity"), through which Fidelity provides our firm with "institutional platform services." Our firm is independently operated and owned and is not affiliated with Fidelity. The institutional platform services include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services that assist us in managing and administering your accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of advisory fees from your accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Fidelity may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by Fidelity may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; electronic news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Fidelity to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. Fidelity does not make client brokerage commissions generated by client transactions available for our firm's use. The aforementioned research and brokerage services are used by our firm to manage accounts for which our firm has investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to you, we will endeavor at all times to put your interests first. You should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm's choice of Fidelity as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend Fidelity and have determined that the recommendation is in your best interest and satisfies our fiduciary obligations, including our duty to seek the best execution. Fixed income transactions may be executed at a number of different broker-dealers depending on the transaction. We believe that Fidelity and other broker-dealers we use provide quality execution services for you at competitive prices. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Directed Brokerage You may establish custodial accounts at broker-dealers other than Fidelity. In such cases, you should understand that in a directed brokerage relationship where we utilize the custodian/broker-dealer of your choice to execute transactions, you may pay higher transaction costs than those charged by Fidelity. Additionally, we may not be able to aggregate orders for accounts custodied outside Fidelity. 15  Brokerage For Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products are in addition to any benefits or research we pay for with soft dollars, and may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Block Trades and Aggregation of Orders As a general practice, we and our Sub-Adviser execute transactions for each client account independently. However, if we or our Sub-Adviser determine that it is appropriate to purchase or sell the same securities for multiple clients at approximately the same time, we may, but are not obligated to, aggregate or batch such orders. This aggregation is conducted to seek best execution, negotiate favorable commission rates, or equitably allocate differences in prices and transaction costs among clients. When orders are aggregated, transactions will generally be averaged as to price and allocated pro rata to the purchase and sale orders placed for each participating client on any given day. We and/or our Sub-Adviser aggregate client orders in accordance with applicable regulatory rules and guidance, and do not receive any additional compensation or remuneration for the aggregation of client transactions. If a prorated allocation is not appropriate, we or our Sub-Adviser may use an alternative allocation method based on relevant factors, including but not limited to: the size of the accounts, investment objectives, cash availability, investment restrictions, or the need to avoid odd lots or de minimis allocations. We and or Sub-Adviser strive to ensure that all allocations are fair and equitable to clients. In the event that circumstances arise which may constitute a conflict of interest between or among clients with positions in the same securities, such situations will be referred to the Compliance Committee of the Sub-Adviser for resolution. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Item 13 Review of Accounts Asset Management Services J. Michael Reinoso, Chief Executive Officer, will monitor your accounts on an ongoing basis and will conduct account reviews at least quarterly to ensure that the portfolio mix is consistent with your current/stated investment needs and objectives, as described in your investment policy statement. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, 16  • market moving events, • security specific events, and/or, • changes in your risk/return objectives. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Portfolio Consulting and Investment Reporting Services J. Michael Reinoso will review your accounts at the inception of the client relationship. Mr. Reinoso may conduct further ongoing reviews of your account, the frequency of which will be negotiated with each client on a case-by-case basis. We will provide you with an analysis of your portfolio, which may cover such items as credit selection, targeted maturity range and security construct (e.g. coupon, call feature). We may also provide additional reports/analysis for clients who engage us for ongoing consulting and reporting services. The frequency of such reports will be determined on a case-by-case basis. Item 14 Client Referrals and Other Compensation We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. Item 15 Custody We directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent qualified custodian. You will receive account statements from the independent qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact Client Relations at 212-832-9700 or via e- mail at info@castletonpartners.com. Our firm or persons associated with our firm may effect third party wire transfers for client accounts with client written consent per transaction or a client may use a Standing Letter of Authorization. A Standing Letter of Authorization is an authorization provided by a client in which the client grants authority to their advisor permitting the advisor to instruct the client's qualified custodian to transfer assets to a third party designated by the client. The Securities & Exchange Commission ("SEC") believes that entering into a Standing Letter of Authorization ("SLOA") arrangement constitutes custody and the adviser is therefore required to comply with the custody rule. However, the adviser is not subject to an annual surprise audit if the advisor follows and satisfies the SEC's guidance provided in the SEC's no-action letter dated February 21, 2017. Where the Adviser acts pursuant to a SLOA, we believe we are making a good faith effort to comply with the representations noted in the SEC's no-action letter. Additionally, since many of those representations involve the qualified custodian's operations, we will collaborate closely with your custodians to ensure that the representations would be able to be met. 17  Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our Discretionary Investment Management Agreement. By signing our discretionary investment management agreement, you grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that you desire only a certain credit quality or a certain maturity limit. Please refer to the "Advisory Business" section in this Brochure for more information on our discretionary asset management services. Item 17 Voting Client Securities Castleton does not vote proxies on behalf of advisory accounts. However, for accounts managed by our Sub-Adviser on a discretionary basis, the Sub-Adviser may vote proxies on your behalf in accordance with their Proxy Voting Policies and Procedures. The Sub-Adviser utilizes third-party proxy advisory services to assist in the research and voting of client proxies. Votes will be made in what the Sub-Adviser considers to be your best interests. You may request a copy of the Sub-Adviser's proxy voting record and policies by contacting us at (212) 832-9700 or info@castletonpartners.com. Item 18 Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. Item 19 Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any nonpublic personal information about you to any nonaffiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees, who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to 18  ensure our integrity and confidentiality. We will never sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact Client Relations at 212-832-9700 or via e-mail at info@castletonpartners.com if you have any questions regarding this policy. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. For accounts under the custody of Fidelity, if a profit results from the correcting, all monthly net gains (after offsetting any trade error losses) from trade error profits will be donated to charity and you will not keep the profit. 19