DOCK STREET ASSET MANAGEMENT INC

Dock Street Asset Management Inc 2875 South Ocean Blvd., Suite 200-46 Palm Beach, FL 33480 Telephone: 203-532-9470 www.dockstreet.com March 27, 2025 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Dock Street Asset Management Inc. If you have any questions about the contents of this brochure, please contact us at 203-532-9470. 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 Dock Street Asset Management Inc is available on the SEC's website at www.adviserinfo.sec.gov. Dock Street Asset Management Inc 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 Since the filing of our last updating amendment on March 28, 2024, we have made the following material changes to this disclosure brochure: Item 12. Brokerage Practices - We updated this item to clarify that while we receive benefits from our use of Charles Schwab's platform as outlined below, we do not receive soft dollar benefits from Charles Schwab. Research and Soft Dollar Benefits Dock Street does not receive research or other soft dollar benefits as a result of custody arrangements or trading commissions. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian, including access to products and services provided by the custodian. These products and services may include financial publications, 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 the custodian, and are not considered to be paid for with soft dollars. • Item 5 - Fees and Compensation - We have updated our fee schedule for new clients to a flat 0.70% of household assets on an annual basis and removed our tiered fee schedule and quarterly minimum fee. Legacy clients may be on a historical fee schedule. • Item 7 - Types of Clients - We generally require a minimum investment of $10 million to establish a client relationship. This minimum may be satisfied by liquid investable assets or ownership of a private business. We may, at our discretion, waive or reduce this minimum in certain circumstances. 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 Additional Information Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 6 Page 6 Page 10 Page 10 Page 11 Page 11 Page 13 Page 13 Page 14 Page 15 Page 15 Page 15 Page 16 3  Item 4 Advisory Business Description of Services and Fees Dock Street Asset Management Inc. is a registered investment adviser based in Palm Beach, Florida. We are organized as a corporation under the laws of the State of Connecticut. We have been providing investment advisory services since 1989. Daniel A. Ogden is the sole owner. Currently, we offer portfolio management services which are personalized to each individual client. Below we describe our services and fees and how we tailor those services to our client's individual needs. As used in this brochure, the words "we", "our" and "us" refer to Dock Street Asset Management Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and make investments on your behalf. As part of our portfolio management services, we customize an investment portfolio for you according to your investing objectives. Your portfolio will be based on several predefined model portfolios used for all clients. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. We require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us 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 granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Non-discretionary investment advisory service is not offered to new clients. Actions taken, such as which investments to buy or sell, based on our advice through non-discretionary investment advisory services are ultimately decided by the client. Types of Investments We offer advice on equity securities, government, corporate and municipal fixed income securities, mutual funds, exchange traded funds (ETFs) and options. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. 401(k) Rollover and IRA Transfer Recommendations When we provide investment advice to you regarding your retirement plan account (401(k)) or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: 4  • Give Prudent Advice - Meet a professional standard of care when making investment recommendations • Give Loyal Advce - Never put our financial interests ahead of yours when making recommendations • Avoid misleading statements about conflicts of interest, fees, and investments • Follow policies and procedures designed to ensure that we give advice that is in your best interest • Charge no more than is reasonable for our services • Give you basic information about conflicts of interest We benefit financially from the rollover of your assets from an ERISA account to an account that we manage because the assets increase our assets under management and our advisory fees. In contrast, we receive no compensation if assets remain in the current plan or are rolled over to another Company plan in which you may participate. Assets Under Management As of December 31, 2024, we provide continuous management services for $903,078,061 in client assets on a discretionary basis, and $2,720,110 in client assets on a non-discretionary basis. Item 5 Fees and Compensation Our Fees We are a fee-only investment manager. As such, our only income is the fees we charge our clients. Our fee is 0.70% of household assets on an annual basis. One forth of this fee is billed and payable quarterly in advance based on the value of your household assets on the last day of the previous quarter. While we generally adhere to our standard fee schedule, at our discretion, we may offer different fee arrangements based on factors such as the total client relationship, complexity, or other considerations. Legacy clients may be on a historical fee schedule. We will send you a statement of our advisory fee quarterly. We will deduct our fee directly from your account through the qualified custodian holding your funds and securities only when you have given our firm written authorization. The qualified custodian will deliver an account statement to you at least quarterly showing all disbursements from your account including our fee. You should review all statements for accuracy. Either party may terminate the contract upon written notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the contract, 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. We encourage you to reconcile our statements with the statements you receive from the qualified custodian. If you find any inconsistent information between our statements and the statements you receive from the qualified custodian please call us at 203-532-9470. Additional Fees and Expenses As part of our investment advisory services to you we may 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 5  prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You may 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 whom 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 or fees charged by funds. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, custodians and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this brochure. Buying Securities on Margin and Margin Interest We may use margin loans on client accounts. Each client must sign a separate margin agreement before margin is extended to that client account. We do not utilize margin for trading purposes but to manage the cash flow needs of our clients. The use of margin permits us to maintain the securities portfolio while meeting short term cash needs. We charge investment advisory fees on the net value of the account. We do not charge advisory fees on the total value or margined value of the account. We believe that not charging advisory fees on the margined balance of the client account mitigates or removes any conflict of interest regarding the use of margin. The use of margin will also result in interest charges. Daniel Ogden serves as a Managing Member of both Manhattan Atlantic Partners IV, LLC (the General Partner to Manhattan Atlantic Partners IV, L.P.) and Manhattan Atlantic Partners VI, LLC (the General Partner to Manhattan Atlantic Partners VI, L.P.). The fees charged by these private pooled investment vehicles are separate and apart from our advisory fees. Please refer to Item 10 below Other Financial Industry Activities and Affiliations for more detailed information to include conflicts of interest. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance-based fees are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. By not engaging in these practices, we avoid the conflicts of interest inherent in them. Item 7 Types of Clients We offer investment advisory services to individuals (including high net worth individuals), pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other types of business entities. We generally require a minimum investment of $10 million to establish a client relationship. This minimum is waived for owners of private business with revenue of $10 million or more. We may, at our discretion, waive this minimum. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies We use different investment strategies, based upon the needs of the client, including long-term purchases, short-term purchases and option writing. 6  We invest in companies that achieve high profitability on the total investment in the business. These companies must also have the ability to make additional high return investments in sufficient size to produce growth in shareholder value. Companies which produce high returns on invested capital usually display a combination of characteristics in the way they do business through superiority in either management style, corporate culture, cost efficiency, marketing, patent protection, or new product development. Furthermore, high return companies as a rule have low debt, strong balance sheets, and can fund high levels of capital spending and growth without diluting the shareholder's interests. Once Dock Street has identified high return/reasonably valued companies, the selection process continues with a series of other evaluations and judgment factors such as the following: • Relative historical price/earnings ratio to the company itself, its industry and to the market. • The relationship of the historical and projected growth rates to the price/earnings ratio and debt levels of the company. • The level and location of sales and earnings in foreign markets. • A careful review of historical and current pre-tax and after tax profit margins and earnings acceleration or deceleration. • A review of the technical factors which might impact on the price action of the company's stock. We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Fundamental Analysis - involves analyzing individual companies and their industry groups, through a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical Analysis - involves studying past price patterns, trends, and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short- term price fluctuations. 7  Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. Option Writing - a securities transaction that involves selling an option. An option is the right, but not the obligation, to buy or sell a particular security at a specified price before the expiration date of the option. When an investor sells an option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the stock in order to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Our investment strategies and advice may vary depending upon each client's 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. Tax Considerations Our strategies and investments may have unique and significant tax implications. While tax efficiency is a consideration, and general guidelines on taxes are discussed with clients, tax efficiency is not our primary consideration in the management of client assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional prior to and throughout the investing of your assets. Client accounts are defaulted to use a High Cost Lot method for calculating the cost basis of securities. You are responsible for contacting your tax advisor to determine if this accounting method is right for you. If not, please provide written notive to Dock Street and we will update your accounting method witht your custodian. Please note that the costs basis method for a trade cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. 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. Recommendation of Particular Types of Securities As disclosed under the Advisory Business section in this brochure, we recommend many types of securities and we do not necessarily recommend one particular type of security over another. However, we may recommend other types of investments as appropriate for you since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks 8  associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Bonds: Corporate or Government debt securities (or "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; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Money Market Funds: Money market funds are investment securities that seek to maintain a stable value of $1 per share, but this value is not guaranteed. Although losses are rare, they are possible. These funds are not FDIC insured, and their yields fluctuate with market conditions. As a result, your return may vary and could be lower than expected. Over time, money market funds typically earn less than riskier investments like stocks, and inflation may reduce their real value. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") 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. ETFs 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 whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical 9  compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Futures: Futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of his/her contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Options: There are numerous risks associated with transactions in options on securities or securities indexes. A decision as to whether, when and how to use options involves the exercise of skill and judgment, and even a well-conceived transaction may be unsuccessful to some degree because of market behavior or unexpected events. As the writer of covered call options, the client forgoes, during the option's life, the opportunity to profit from increases in the market value of the underlying security or the index above the sum of the option premium received and the exercise price of the call, but has retained the risk of loss, minus the option premium received, should the price of the underlying security decline. In the case of index options, the client incurs basis risk between the performance of the underlying portfolio and the performance of the underlying index. For example, the underlying portfolio may decline in value while the underlying index may increase in value, resulting in a loss on the call option while the underlying portfolio declines as well. Item 9 Disciplinary Information Dock Street Asset Management Inc. has been registered and providing investment advisory services since 1993. Neither our firm nor any of our management nor supervised persons have any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations Arrangements with Affiliated Entities Mr. Ogden serves as a Managing Member of private pooled investment vehicles Manhattan Atlantic Partners IV, LLC (the General Partner to Manhattan Atlantic Partners IV, L.P.) and Manhattan Atlantic Partners VI, LLC (the General Partner to Manhattan Atlantic Partners VI, L.P.) (collectively as the "Fund"). Clients are no longer solicited to invest in the Funds. 10  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics Dock Street has adopted a Code of Ethics to prevent violations of federal securities laws. The Code of Ethics is predicated on the principle that Dock Street and its employees owe a fiduciary duty to its clients. Accordingly, Dock Street expects all employees to act with honesty, integrity and professionalism and to adhere to federal securities laws. Dock Street and its employees are required to adhere to the Code of Ethics. At all times, Dock Street and its employees must (i) place client interests ahead of Dock Street's; (ii) engage in personal investing that is in full compliance with Dock Street's Code of Ethics; and (iii) avoid taking advantage of their position. Clients and prospective clients may request a copy of Dock Street's Code of Ethics by contacting Spencer Ogden, Chief Compliance Officer of Dock Street at 203-532-9470. Participation or Interest in Client Transactions and Personal Trading Practices Our firm or persons associated with our firm 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 firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Please see Other Financial Industry Activities and Affiliations under Item 10 and Custody under Item 15 for more information. Item 12 Brokerage Practices We recommend the brokerage and custodial services of various custodians including Charles Schwab & Co. (whether one or more we use the term "Custodian"). Your assets will be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Our selection of custodian is based on many factors, including the level of services provided, the custodian's financial stability, and the cost of services provided by the custodian to our clients, which includes the yield on cash sweep choices, commissions, custody fees and other fees or expenses. We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider various factors, including: • Capability to buy and sell securities for your account itself or to facilitate such services. • The likelihood that your trades will be executed. • Availability of investment research and tools. • Overall quality of services. • Competitiveness of price. • Reputation, financial strength, and stability. • Existing relationship with our firm and our other clients. Research and Other Soft Dollar Benefits Dock Street does not receive research or other soft dollar benefits as a result of custody arrangements or trading commissions. 11  Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian, including access to products and services provided by the custodian. These products and services may include financial publications, 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 the custodian, and are not considered to be paid for with soft dollars. 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. Directed Brokerage We routinely recommend that you direct our firm to execute transactions through Charles Schwab and Co., Inc. ("Schwab"). As such, we may be unable to achieve the most favorable execution of your transactions and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to direct brokerage. In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from aggregating trades with other client accounts or from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Block Trades We combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, and is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. 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. We do not aggregate trades for non-discretionary accounts. Accordingly, non-discretionary accounts may not be able to buy and sell the same quantities of securities and may pay higher commissions, fees, and/or transaction costs than discretionary accounts. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When we purchase mutual funds for a client, we select the share class that is deemed to be in the client's best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, we 12  will purchase the fund at net asset value. We also review the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. Item 13 Review of Accounts The chief investment officer and other designated employees are the reviewers that provide all accounts with continuous and regular supervisory or management services. The portfolio manager reviews each account's financial performance in detail each month. Reviews include assessments on both an aggregate account and individual security basis. In addition to these regular reviews, the portfolio manager monitors news affecting securities owned by clients on a daily basis, and when necessary, updates assessments for future performance and makes changes in portfolio makeup accordingly. In addition to monthly statements from the broker or custodian, we issue quarterly reports to each client which include information about the current holdings in each account, the realized gains and losses for the period and performance information allowing clients to gauge returns on holdings and asset classes. Clients are urged to compare the account statement provided by the broker- dealer/custodian with those provided by Dock Street. Clients also receive letters from the portfolio manager covering topics from market conditions to the prospects of individual securities. Item 14 Client Referrals and Other Compensation We directly compensate non-employee (outside) consultants, individuals, and/or entities (solicitors) for client referrals. In order to receive a cash referral fee from us, solicitors must comply with the requirements of the jurisdictions in which they operate. If you were referred to us by a solicitor, you should have received a copy of this brochure along with the solicitor's disclosure statement at the time of the referral. If you become a client, the solicitor that referred you to us will receive a percentage of the advisory fee you pay us for a period agreed with the solicitor, or until such time as our agreement with the solicitor expires. You will not pay additional fees because of this referral arrangement. Referral fees paid to a solicitor are contingent upon your entering into an advisory agreement with us. Therefore, a solicitor has a financial incentive to recommend us to you for advisory services. This creates a conflict of interest; however, you are not obligated to retain us for advisory services. Comparable services and/or lower fees may be available through other firms. Solicitors that refer business to more than one investment adviser may have a financial incentive to recommend advisers with more favorable compensation arrangements. We request that our solicitors disclose to you whether multiple referral relationships exist and that comparable services may be available from other advisers for lower fees and/or where the Solicitor's compensation is less favorable. 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. 13  Item 15 Custody Your independent custodian will 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. Your funds and securities will be held with an 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. As discussed, clients generally authorize Dock Street Asset Management to directly deduct advisory fees owed to Dock Street Asset Management from their accounts held by a qualified custodian. Clients should always carefully review all custodian account and capital account statements that they receive for accuracy as well as review any advisor fees that have been deducted to check them for accuracy. For more information about custodians and brokerage practices, see Item 12 - Brokerage Practices. If you have a question regarding your account statement, or if you did not receive a statement from your custodian, please contact us at 203-532-9470. Private Investment Companies Dock Street Asset Management is deemed to have custody of client funds and securities because a related person, Daniel A. Ogden, is a Managing Member of the Manhattan Atlantic Partners IV, LLC and Manhattan Atlantic Partners VI, LLC (Funds). These partnerships are independently audited by an independent CPA auditing firm each year. In his capacity as managing member to the Funds, we will have access to the Fund's funds and securities, and therefore have custody over such funds and securities. We provide each investor in the Fund with audited annual financial statements. If you are a Fund investor and have questions regarding the financial statements or if you did not receive a copy, contact us directly at 203-532-9470. Trustee Relationship Daniel A. Ogden, President of Dock Street Asset Management, serves as trustee to certain accounts for which we provide investment advisory services. Mr. Ogden's capacity as trustee gives him custody over the advisory accounts for which he serves as trustee. These accounts will be held with a bank, broker-dealer, or other independent, qualified custodian. If Mr. Ogden acts as trustee for any of your advisory accounts, you will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. You should carefully review account statements for accuracy. We will also provide statements to you. You should compare our statements with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement or if you did not receive a statement from your custodian, contact us directly at 203-532-9470. Standing Letters of Authorization In certain situations, you may give us written authority to direct your custodian to transfer funds to a third party on your behalf. This is known as a standing letter of authorization, or SLOA. When we have this authority, we are considered to have limited custody of your funds. However, we are not required to undergo an annual surprise audit if specific safeguards are in place. These include your written instructions, confirmation and notices from your custodian, and restrictions on our ability to change transfer details. We meet all required conditions to qualify for this exception. 14  Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement, and the appropriate trading authorization forms. This grants 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 the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the Advisory Business section in this brochure for more information on our discretionary management services. Our non-discretionary investment management service is not offered to new clients. Our advice for non-discretionary investment management services is ultimately decided by the client. Item 17 Voting Client Securities Proxy Voting We will determine how to vote proxies based on our reasonable judgment of the vote most likely to produce favorable financial results for you. Proxy votes generally will be cast in favor of proposals that maintain or strengthen the shared interests of shareholders and management, increase shareholder value, maintain or increase shareholder influence over the issuer's board of directors and management, and maintain or increase the rights of shareholders. However, we will consider both sides of each proxy issue. Unless we receive specific instructions from you, we will not base votes on social considerations. In the event you wish to direct our firm on voting a particular proxy, you should contact us at 203-532- 9470 with your instruction. We invest primarily in publicly traded companies that are not clients of our firm, so direct conflicts of interest in proxy voting (such as voting on matters involving a client issuer) are extremely unlikely to occur. In the rare event that a potential conflict does arise—such as if a senior executive of a portfolio company is also a client—we will take steps to ensure that proxy votes are cast in your best interest. This may include disclosing the conflict, abstaining from the vote, or following an objective third-party recommendation. We keep certain records required by applicable law in connection with our proxy voting activities. You may obtain information on how we voted proxies and/or obtain a full copy of our proxy voting policies and procedures by making a written or oral request to our firm. Item 18 Financial Information Because we do not require or accept fees more than six months in advance, we are not required to provide a balance sheet. We do not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. 15  Item 19 Additional Information Your Privacy We view protecting your private information as a top priority. 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 seek to minimize the information shared in these cases. We do not share your information unless it is required to process a transaction, at your request, or required by law. 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 ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm and annually as a client. Please contact us if you have any questions regarding this policy at 203-532-9470. 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. If a trade error results in a profit, you will keep the profit. Losses from a trade error are handled in one of two ways. Any loss in a client's account of less than $100 is absorbed by Charles Schwab & Co. Any loss great than $100 will be absorbed by Dock Street. In either case, a client is never disadvantaged by a trade error. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 16