Overview
- Headquarters
- Montpelier, VT
- Total Firm Assets
- $2.6 billion
- Average High-Net-Worth Client Portfolio Size
- $2.9 million
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A AND SUPPLEMENTAL 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.00% |
| $500,001 | $1,000,000 | 0.75% |
| $1,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,750 | 0.88% |
| $5 million | $28,750 | 0.58% |
| $10 million | $53,750 | 0.54% |
| $50 million | $253,750 | 0.51% |
| $100 million | $503,750 | 0.50% |
Clients
- High-Net-Worth Share of Firm Assets
- 73.76%
- Number of High-Net-Worth Clients
- 654
- Total Client Accounts
- 3,579
- Discretionary Accounts
- 3,579
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 130209
Primary Brochure: FORM ADV PART 2A AND SUPPLEMENTAL 2B (2026-08-05)
View Document Text
Item 1: Cover Page
Maple Capital Management, Inc.
Form ADV Part 2A
Disclosure Brochure
08/05/2026
Principal Business Office Address:
535 Stone Cutters Way
Montpelier, VT 05602
Main Phone Number: 802-229-2838
Web Site Address:
www.maplecapital.com
This Brochure provides information about the qualifications and business practices of Maple Capital
Management, Inc. (MCM). If you have any questions about the contents of this Brochure, please contact
Thomas W. Rawlings, Chief Compliance Officer by phone at: 802-229-2838 or by email at:
trawlings@maplecapital.com. 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 Maple Capital Management, Inc. is also available on the SEC’s website at
www.advisorinfo.sec.gov.
MCM is registered with the SEC under the Investment Advisers Act of 1940. Being registered with the
SEC or use of the term “registered investment adviser” within this document does not imply a certain
level of skill or training.
MAPLE CAPITAL MANAGEMENT, INC.
Item 2: Material Changes Since Last Filing
On July 28, 2010, the United State Securities and Exchange Commission published “Amendments to
Form ADV” which amends the disclosure document we provide to clients as required by SEC Rules. This
brochure dated August 5, 2026, has been prepared according to the SEC’s requirements and rules.
In the future, this Item will discuss only specific material changes that are made to the Brochure and will
provide clients with a summary of such changes. We will also reference the date of the last annual
update of our brochure.
Since our last filing submitted March 31, 2026, we have not made any material changes to this
document.
In the past, we have offered or delivered information about our qualifications and business practices to
clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a
summary of any material changes to this and subsequent brochures within 120 days of the close of our
business’ fiscal year. We may further provide other ongoing disclosure information about material
changes, as necessary.
We will further provide you with a new brochure as necessary, based on changes or new information, at
any time, without charge.
Our brochure may be requested by contacting Thomas W. Rawlings, Chief Compliance Officer, at 802-
229-2838 or trawlings@maplecapital.com.
Additional information about Maple Capital Management, Inc. is also available via the SEC’s website
www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with
MCM who are registered, or are required to be registered, as investment adviser representatives of MCM.
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Item 3: Table of Contents
Item 1: Cover Page ..................................................................................................................... 1
Item 2: Material Changes Since Last Filing .................................................................................. 2
Item 3: Table of Contents ........................................................................................................... 3
Item 4: Advisory Business ........................................................................................................... 4
Item 5: Fees and Compensation .................................................................................................. 7
Item 6: Performance-Based Fees and Side-By-Side Management .............................................. 10
Item 7: Types of Clients ............................................................................................................ 10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 10
Item 9: Disciplinary Information ................................................................................................ 13
Item 10: Other Financial Industry Activities and Affiliations ....................................................... 13
Item 11: Code of Ethics ............................................................................................................ 13
Item 12: Brokerage Practices ................................................................................................... 14
Item 13: Review of Accounts .................................................................................................... 17
Item 14: Client Referrals and Third-Party Compensation ........................................................... 17
Item 15: Custody ...................................................................................................................... 18
Item 16: Investment Discretion ................................................................................................. 19
Item 17: Voting Client Securities ............................................................................................... 19
Item 18: Financial Information .................................................................................................. 20
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Item 4: Advisory Business
A. Description of Advisory Firm
Maple Capital Management, Inc. (MCM) is a corporation formed on July 1, 2004 in the state of Vermont
that registered as an Investment Adviser Firm with the SEC in 2004. Ramsey A. Luhr, President, is a
managing partner and majority owner of the firm. The firm maintains an employee ownership program
which allows key employees to take an economic position in the company. The firm currently has over
ten participants in this program and expects to add more in the future.
B. Types of Advisory Services
General Description of Primary Advisory Services
MCM provides portfolio management and investment consulting services. Accounts are established with
a qualified custodian by the client, who grants MCM the authority to make trades in each account.
MCM primarily uses individual stocks and bonds when constructing client portfolios. It is our belief that
the use of individual securities gives investors better control over their tax situation, better risk control in
their accounts, and the potential for improved returns. The securities purchased for client accounts are
selected by our research analysts and follow internal company guidelines.
Mutual funds and/or exchange traded funds (ETFs) may generally be used for smaller accounts and for
those sectors of the investment market for which MCM does not have an internal research capacity to
follow. Mutual funds and ETFs are selected after a thorough analysis by the Asset Allocation, and Mutual
Fund Research teams under the supervision of the investment committee.
MCM has the ability to integrate and delegate the investment of client assets to a sub-advisor in lieu of
using mutual funds and/or ETFs for asset class diversification.
Promotion Program
MCM partners with other unaffiliated third-party investment advisers (“promoters”) to provide services
under a promotion arrangement. Clients will enter into an investment advisory agreement with MCM
which allows for information sharing with the unaffiliated third-party investment adviser. The unaffiliated
third-party investment adviser will assist you in the selection of a suitable investment portfolio and asset
allocation strategy that will be used by MCM to properly allocate your assets in the investment portfolio.
MCM will serve as the primary investment manager for your investment portfolios. The unaffiliated third-
party investment adviser, in their role as promoter, will provide initial and ongoing education concerning
the asset allocation strategy selected. The unaffiliated third-party investment adviser is available to
answer questions you may have regarding your account and act as your relationship manager between
you and MCM. The unaffiliated third-party investment adviser will periodically meet with you to discuss
changes in your investment objectives and risk tolerance, and current asset allocations within each
portfolio. Information from these meetings will be shared with MCM to facilitate MCM’s ongoing
management of your accounts. MCM periodically changes the relative allocations among securities in
the portfolios. MCM will take discretionary authority to determine the securities to be purchased and sold
for you. MCM pays a portion of the advisory fee received from the client to the promoter.
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Joint Advisory Program
MCM partners with other unaffiliated third-party investment advisers, pursuant to a separate agreement,
to provide services under a joint advisory structure. Clients will enter into an agreement jointly with MCM
and the unaffiliated third-party investment adviser. The unaffiliated third-party investment adviser will
serve as your primary financial advisor and assist you in the selection of a suitable investment portfolio
and asset allocation strategy that will be used by MCM to properly allocate your assets in the investment
portfolio. MCM will serve primarily as investment manager for your investment portfolios. The
unaffiliated third-party investment adviser will provide initial and ongoing education concerning the asset
allocation strategy selected. The unaffiliated third-party investment adviser is available to answer
questions you may have regarding your account and act as your relationship manager between you and
MCM. The unaffiliated third-party investment adviser will periodically meet with you to discuss changes
in your investment objectives and risk tolerance, and current asset allocations within each portfolio.
Information from these meetings will be shared with MCM to facilitate MCM’s ongoing management of
your accounts. MCM periodically changes the relative allocations among securities in the portfolios.
MCM will take discretionary authority to determine the securities to be purchased and sold for you.
Socially Responsible Investing Limitations
Socially Responsible Investing involves the incorporation of Environmental, Social and Governance
considerations into the investment due diligence process (“ESG”). There are potential limitations
associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have
a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil
drilling, gambling, etc.). The number of these securities may be limited when compared to those that do
not maintain such a mandate. ESG securities could underperform broad market indices. Investors must
accept these limitations, including potential for underperformance. Correspondingly, the number of ESG
mutual funds and exchange traded funds are few when compared to those that do not maintain such a
mandate. As with any type of investment (including any investment and/or investment strategies
recommended and/or undertaken by MCM), there can be no assurance that investment in ESG securities
or funds will be profitable, or prove successful.
Cash Positions
Cash positions (money markets, etc.) are included as part of assets under management for purposes of
calculating MCM’s advisory fee. At any specific point in time, MCM may maintain higher cash balances
based upon perceived or anticipated client needs, market conditions/events (there being no guarantee
that such anticipated market conditions/events will occur). Cash may also build up as a residual to our
investment process if suitable replacement investments cannot be found when securities are sold. This
may result in significant cash balances being held. In addition, while assets are maintained in cash, such
amounts could miss market advances. Depending upon current yields, at any point in time, MCM’s
advisory fee could exceed the interest paid by the client’s money market fund.
Administrative Services Provided by Third Parties
MCM has contracted with several third-party vendors to support various functions related to the
administrative tasks of managing client accounts. Some of the services provided by these vendors
include data reconciliation, performance reporting, voting client proxies, and trading client accounts.
Due to these arrangements, some of these third parties have limited access to client account
information. More information about these arrangements can be found in MCM’s Privacy Notice.
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Class Action Litigation Services
Unless the client directs otherwise in writing, MCM has retained the services of Chicago Clearing
Corporation (referred to as “CCC”) to file all eligible class action lawsuits on behalf of the client. CCC
researches, files, monitors, and expedites the distribution of class action settlements. When a claim is
settled and payments are awarded to MCM clients, it may be necessary to share client information, such
as name and account number, with CCC in connection with this service. In exchange for managing class
action filings, CCC earns a fee based on a flat percentage of all claims it collects on behalf of MCM’s
clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. The
client may opt out the service if they wish to file their own class action lawsuits by contacting MCM’s
Chief Compliance Officer.
ERISA Accounts
MCM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual
retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”).
As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue
Code that include among other things, restrictions concerning certain forms of compensation. To avoid
engaging in prohibited transactions, MCM may only charge fees for investment advice about products for
which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely,
investment advice about products for which our firm and/or our related persons receive commissions or
12b-1 fees, however, only when such fees are used to offset MCM advisory fees.
Portfolio Activity
MCM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its
investment advisory services, MCM will review client portfolios on an ongoing basis to determine if any
changes are necessary based upon various factors, including but not limited to investment performance,
fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and
changes in the client’s investment objectives. Based upon these and other factors, there may be
extended periods of time when MCM determines that changes to a client’s portfolio are neither
necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during
periods of account inactivity.
Client Obligations
In performing its services, MCM shall not be required to verify any information received from the client or
from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is
advised that it remains their responsibility to promptly notify MCM if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing, evaluating, or revising MCM’s
previous recommendations and/or services.
Disclosure Statement
A copy of MCM’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV
and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement.
C. Client-Tailored Advisory Services
MCM gathers key information about its client’s needs and objectives before initiating trades in client
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accounts. When possible, MCM prepares a written investment policy statement (IPS). The IPS reflects
MCM’s understanding of each client’s circumstances and explains the approach MCM will use when
managing client assets.
As part of our services, MCM may provide non-investment financial advice such as estate planning and
tax planning to its clients. Neither MCM, nor any member of its staff, serve as an accountant or attorney
and MCM’s services should not be construed to be the same.
If requested by a client, MCM may recommend other professionals for non-investment financial advice.
MCM does not warrant or otherwise attest to the quality of services provided by these outside
professionals. Clients may engage these service providers at their discretion.
Clients may engage MCM to manage their assets on a non-discretionary or “advisory” basis. Under such
an arrangement, MCM cannot affect any transactions without first obtaining verbal consent from the
client. In the event of market volatility, MCM will be unable to affect any trades/transactions for advisory
clients until they are individually contacted.
D. Wrap Fee Programs
MCM does not participate in any wrap fee programs at this time.
E. Assets Under Management (AUM)
As of December 31, 2025, MCM managed approximately $2,579,565,974 of regulatory assets under
management (RAUM).
As of December 31, 2025, MCM had approximately $2,523,925,503 in assets under advisement (AUA).
Currently, MCM’s assets under advisement include 401k plans, insurance general operating funds and
foundations where MCM serves solely as a consultant and does not have investment discretion or the
ability to execute trades directly in client accounts.
Item 5: Fees and Compensation
A. Fee Schedule for Advisory Services
MCM currently receives all of its revenue from fees paid for portfolio management and portfolio
consulting services. Clients retain MCM to provide ongoing discretionary investment management for
their accounts. MCM may provide non-investment financial advice and financial planning services as
part of this arrangement at no additional fee to clients.
Fee Differential
MCM’s investment advisory fees are negotiable at MCM’s discretion and may be higher or lower than the
fee schedules presented below depending upon objective and subjective factors including but not limited
to:
the amount of assets to be managed;
the scope and complexity of the engagement;
the anticipated number of meetings and servicing needs;
portfolio composition;
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related accounts;
future earning capacity;
anticipated future additional assets;
the professional(s) rendering the service(s);
prior relationships with the MCM and/or its representatives, and
negotiations with the client.
As a result of these factors, similarly situated clients could pay different fees, the services to be provided
by MCM to any particular client could be available from other advisers at lower fees, and certain clients
may have fees different than those specifically set forth below. All clients and prospective clients should
be guided accordingly. MCM’s Chief Compliance Officer, Thomas W. Rawlings, remains available to
address any questions that a client or prospective client may have regarding fee determination.
Clients Working Directly with MCM
MCM’s standard advisory fee schedule for clients who work directly with MCM without the involvement of
a third party investment adviser is as follows:
1.00% of the first $500,000 of assets under management
0.75% of the next $500,000 of assets under management
0.50% of assets under management over $1,000,000
Advisory fees charged for clients working directly with MCM range from 0.23% of assets under
management to as high as 1.25% of assets under management. Fees are negotiable and will vary based
upon a variety of factors as discussed above in the section titled Fee Differential.
Promotion Program
MCM’s advisory fee schedule for clients who engage MCM through a promoter may vary based upon
MCM’s agreement with each promoter. MCM’s standard advisory fee schedule for clients who work with
MCM through the Promotion Program is as follows:
1.50% of the first $1,000,000 of assets under management
1.25% of assets under management over $1,000,000
The advisory fees within the Promotion Program range from 0.40% of assets under management to as
high as 1.75% of assets under management. Fees are negotiable and will vary based upon a variety of
factors as discussed above in the section titled Fee Differential.
Joint Advisory Program
MCM’s advisory fee schedule for clients who engage MCM jointly with a third party investment adviser
will vary based upon MCM’s agreement with each joint adviser. MCM’s standard advisory fee schedule
for clients who work with MCM through the Joint Advisory Program is as follows:
1.70% of the first $1,000,000 of assets under management
1.40% of assets under management over $1,000,000
The advisory fees within the Joint Advisory Program range from 0.
+.80% of assets under management to as high as 1.70% of assets under management. Advisory fees are
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negotiable and will vary based upon a variety of factors as discussed above in the section titled Fee
Differential.
B. Payment of Fees
The specific manner in which fees are charged is established in a client’s Investment Advisory
Agreement (“IAA”) with MCM. Fees for investment advisory services are payable quarterly, in advance of
services being rendered, and are based on the market value of cash and securities in a client’s account
at the end of the previous quarter. The quarterly valuation dates will be the last business day of March,
June, September, and December. Clients may elect to be billed directly or authorize MCM to debit fees
directly from their accounts. Additional management fees may be assessed on a pro-rated basis for
significant capital contributions made during a calendar quarter.
C. Fees Paid in Advance and Termination
A client agreement may be canceled at any time, by either party, according to the client’s IAA. As
disclosed in the IAA, certain fees are paid in advance of services provided. Upon termination of any
account, any prepaid, unearned fees will be refunded. In calculating a client’s reimbursement of fees, we
will pro rate the reimbursement according to the number of days remaining in the billing period.
D. Other Fees and Expenses
MCM is not a qualified custodian for client assets. All accounts must be held at a qualified custodian. As
discussed below, unless the client directs otherwise or an individual client’s circumstances require, MCM
shall generally recommend that Charles Schwab and Co., Inc. (“Schwab”) or Fidelity Investments
(“Fidelity”) serve as the broker-dealer/custodian for client investment management assets. Broker-
dealers such as Schwab and Fidelity charge brokerage commissions and/or transaction fees for effecting
certain securities transactions.
Mutual Funds and Exchange Traded Funds
In addition to MCM’s investment advisory fee, brokerage commissions and/or transaction fees, custody
fees and other charges, clients will also incur, relative to all mutual fund and exchange traded fund
purchases, charges imposed at the fund level (e.g. management fees and other fund expenses). The fees
charged by the applicable broker dealer/custodian, and the charges imposed at the fund level, are in
addition to MCM’s investment advisory fees referenced in this Item 5.
Custodial and Brokerage Fees
In addition to our advisory fees, clients are also responsible for the fees and expenses charged by
custodians and imposed by broker dealers, including, but not limited to, any transaction charges
imposed by a broker dealer with which an independent investment manager effects transaction for the
client's account(s). Please refer to Item 12 - Brokerage Practices in this Form ADV for additional
information.
Tradeaway/Prime Broker Fees
Relative to its discretionary investment management services, when beneficial to the client, individual
fixed income transactions may be effected through broker-dealers other than the account custodian, in
which event, the client generally will incur both the fee (commission, mark-up/mark-down) charged by
the executing broker-dealer and a separate “trade-away” and/or prime broker fee charged by the
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account custodian (Schwab or Fidelity).
E. Outside Compensation for the Sale of Securities to Clients
Neither MCM, nor its representatives accept compensation from the sale of securities or other
investment products.
Item 6: Performance-Based Fees and Side-By-Side Management
Neither MCM nor any supervised person of MCM accepts performance-based fees.
Item 7: Types of Clients
MCM provides portfolio management services and investment consulting services to individuals, families,
trusts, corporate pension and profit-sharing plans, charitable institutions, foundations, endowments,
corporations, and insurance companies.
MCM offers clients equity only accounts, balanced accounts, fixed income only accounts, cash
management accounts, and an account strategy specifically designed for insurance companies.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis and Risk of Loss
MCM creates portfolios for our clients primarily by using individual stocks, bonds, mutual funds and/or
ETFs. The methodology for selecting the actual securities is set out below.
Equities (Stocks)
MCM uses fundamental analysis methods to select securities for client portfolios. Fundamental analysis
is performed using company specific data and other relevant economic or financial data to analyze a
company’s historic results and to make financial forecasts.
MCM’s investment philosophy is based on the premise that a diversified portfolio of high-quality
companies purchased at reasonable valuations will offer compelling returns over a full business cycle.
MCM believes that attractive securities can be identified and further analyzed within a disciplined
investment criteria to identify those companies with the best risk/reward profiles. MCM searches a large
universe of equities for those companies generally exhibiting the characteristics that it believes are
common in superior companies. These characteristics generally include:
High or increasing returns on capital.
Sustainable and defensible competitive positions.
Strong management teams.
Low balance sheet risk.
Strong free cash flow generation capability.
Reasonable valuation and risk-return profiles.
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The potential for sustainable growth through varying economic cycles.
We believe that our fundamental research and valuation discipline can consistently and repeatedly
identify attractive investment opportunities.
Fixed Income (Bonds)
Bonds are used in client accounts to generate income and preserve capital. Fixed income securities are
important tools for controlling risk in a portfolio. We do not believe bonds should be used as a trading
vehicle.
Bond holdings are purchased with multiple maturity dates to diversify interest rate and reinvestment
risks. This “laddered maturity” approach will be adjusted to reflect MCM’s view of market conditions.
This active managing of the “ladder” may lead to shortening or lengthening of the average maturity and
duration of a client bond portfolio.
MCM utilizes a disciplined approach to determine the sectors and maturity selections to be used in
portfolio construction. These factors are based on MCM’s analysis of the yield curve, interest rate
forecasts, and credit and reinvestment risks.
MCM selects potential investments from all sectors of the bond market. Taxable clients will typically
have a higher exposure to tax free municipal bonds although taxable investments may be used for
diversification of risk and to capture higher after-tax or total return potential. Tax-exempt accounts will
typically hold higher yielding taxable bonds.
Mutual Funds
MCM utilizes quantitative and qualitative methods to perform due diligence screening and selection of
open and closed-end mutual funds and exchange trades funds [ETFs]. For actively managed funds, the
goal is to identify managers that manage their products in a consistent manner with how Maple Capital
manages strategies from a stated investment philosophy and process. For passive or index managed
funds, the goal is to provide asset class exposure with a similar return and risk profile to that of a specific
asset class.
Absolute and risk adjusted quantitative data over multiple time periods are analyzed to rank fund
performance. Qualitative due diligence of the firm, investment process, and the investment
professionals are then conducted. Combining the quantitative data and qualitative assessment, MCM
builds a platform of open and closed-end mutual funds and ETFs. Ongoing due diligence is conducted
on a quarterly and annual basis to monitor fund performance and make appropriate changes if
necessary.
Market Risks
Investing in securities involves the risk of loss of principal. Equity and fixed income securities are subject
to broader market conditions as well as company specific risks. MCM does not warrant its ability to avoid
these risks when analyzing investments. Other risk factors include, but are not limited to, geo-political
events, natural disasters, and government policy decisions that are hard to predict or quantify and may
have significant impacts on market valuations and investment returns.
Fundamental Analysis.
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We attempt to measure the intrinsic value of a security by looking at economic and financial factors
(including the overall economy, industry conditions, and the financial condition and management of the
company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or
overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate
market movements. This presents a potential risk, as the price of a security can move up or down along
with the overall market regardless of the economic and financial factors considered in evaluating the
stock.
Qualitative Analysis.
We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and
strength of research and development factors not readily subject to measurement and predict changes
to share price based on that data. A risk of using qualitative analysis is that our subjective judgment may
prove incorrect.
Asset Allocation.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry or market sector. Another risk is that the ratio of securities, industry and/or market sector will
change over time due to stock and market movements and, if not corrected, will no longer be appropriate
for the client's goals.
Mutual Fund and/or ETF Analysis.
We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to
determine if that manager has demonstrated an ability to invest over a period of time and in different
economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to
determine if there is significant overlap in the underlying investments held in another fund(s) in the
client's portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to
follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does
not guarantee future results. A manager who has been successful may not be able to replicate that
success in the future. In addition, as we do not control the underlying investments in a fund or ETF,
managers of different funds held by the client may purchase the same security, increasing the risk to the
client if that security were to fall in value. There is also a risk that a manager may deviate from the stated
investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the
client's portfolio.
Third-Party Money Manager Analysis.
We examine the experience, expertise, investment philosophies, and past performance of independent
third-party investment managers in an attempt to determine if that manager has demonstrated an ability
to invest over a period of time and in different economic conditions. We monitor the manager's
underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk
assessment. Additionally, as part of our due-diligence process, we survey the manager's compliance and
business enterprise risks.
A risk of investing with a third-party manager who has been successful in the past is that he/she may not
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be able to replicate that success in the future. In addition, as we do not control the underlying
investments in a third-party manager's portfolio, there is also a risk that a manager may deviate from the
stated investment mandate or strategy of the portfolio, making it a less suitable investment for our
clients. Moreover, as we do not control the manager's daily business and compliance operations, we may
be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational
deficiencies.
Risks for all forms of analysis.
Our securities analysis methods rely on the assumption that the companies whose securities we
purchase and sell, the rating agencies that review these securities, and other publicly-available sources
of information about these securities, are providing accurate and unbiased data. While we are alert to
indications that data may be incorrect, there is always a risk that our analysis may be compromised by
inaccurate or misleading information.
Item 9: Disciplinary Information
Neither MCM nor the principals and employees of the firm, have been named in any lawsuits or subject
to any disciplinary or enforcement actions.
Item 10: Other Financial Industry Activities and Affiliations
MCM is an independent adviser. Neither MCM nor any of its employees are affiliated with a registered
broker-dealer or other financial firm. MCM does not have outside ownership arrangements, outside
compensation arrangements, and does not receive compensation from third-party fee sharing
arrangements. Neither MCM nor any employee has an application pending to become registered or
otherwise affiliated with a broker-dealer or other financial firm.
Item 11: Code of Ethics
A. Description of Our Code of Ethics
MCM has adopted a Code of Ethics (the Code) pursuant to SEC rule 204A-1 for all supervised persons of
the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code
includes among other things: provisions relating to the confidentiality of client information; a prohibition
on insider trading; restrictions on the acceptance of significant gifts and the reporting of certain gifts and
business entertainment items; and personal securities trading procedures. All supervised persons at
MCM must acknowledge the terms of the Code of Ethics annually, or as amended. MCM’s clients or
prospective clients may request a copy of the firm's Code of Ethics by contacting Thomas W. Rawlings,
Chief Compliance Officer at 802-229-2838 or trawlings@maplecapital.com.
B. Recommendations Involving Material Financial Interests
The Code requires personnel to disclose any and all material financial interests as part of the ongoing
compliance process. Clients will not be invested in securities where a material financial interest exists.
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MAPLE CAPITAL MANAGEMENT, INC.
C. Personal Securities Transactions
The staff of MCM may trade for their own accounts in securities which are recommended to and/or
purchased for MCM’s clients, subject to satisfying the requirements of the MCM compliance policy and
applicable laws. The Code is designed to assure the personal securities transactions of MCM employees
will not create a conflict of interest or otherwise interfere with the portfolio management obligations of
MCM, while still allowing employees to invest for their own accounts.
The Code requires pre-clearance of all covered transactions to prevent employees from trading to the
detriment of client accounts. The exceptions to this rule being open end mutual funds and futures and
options on broad-based market indices. Such transactions by employees are unlikely to have an impact
on market prices and therefore do not require pre-clearance. While the Code permits employees to invest
in the same securities as clients, employee trading is continually monitored by supervisory personnel to
prevent conflicts of interest between MCM and its clients.
MCM has a personal securities transaction policy in place to monitor the personal securities transactions
and holdings of all MCM staff members. This policy requires MCM staff members to report all covered
security transactions on a quarterly basis to the Chief Compliance Officer or his/her designee.
Additionally, MCM staff members report all covered securities holdings to the Chief Compliance Officer
or his/her designee on an annual basis.
D. Trading Securities At/Around the Same Time as Client’s Securities
Employee related accounts (accounts where the employee has a beneficial interest) may trade with client
accounts on an aggregated basis when such a trade is consistent with MCM's obligation of best
execution. In such circumstances, the affiliated and client accounts will share commission costs equally
and receive securities at a total average price. MCM will retain records of the trade order (specifying each
participating account) and its allocation, which will be completed prior to the entry of the aggregated
order. Completed orders will be allocated as specified in the initial trade order. Employee related
accounts will be removed from partially filled orders.
MCM will not affect any principal transactions for client accounts on its own behalf. All transactions in
client accounts will be independently priced and executed through an outside broker/dealer.
Item 12: Brokerage Practices
A. Selection of Custodians and Brokers
Maple Capital Management does not serve as a custodian for client assets. All clients must designate a
custodian prior to MCM assuming management of their assets and this custodian shall be named in the
signed Investment Advisory Agreement. MCM may assist the client in the selection of a custodian in the
event the client does not have a suitable custodial arrangement in place. MCM factors in service quality,
trade execution and quality, and the financial strength of the custodian when making recommendations.
Use of Other Brokers and Best Execution
MCM will seek to use the best execution options available to a specific account when executing a trade
on behalf of that Client. The analysis of best execution levels will include price level, availability of
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MAPLE CAPITAL MANAGEMENT, INC.
securities and other factors beyond commission cost.
Many clients have directed custody arrangements which may allow limited flexibility as to where trades
may be executed. Furthermore, not all available brokers are able to execute trades to settle at a given
custodian.
Directed Brokerage
MCM may direct trades to brokers with higher commission rates if those brokers offer better execution,
or to take advantage of security availability that may not exist with the custodian. Public offerings of
securities, inventory specific trades, and securities with little liquidity are best executed with a firm that
makes a market in such securities.
MCM may also direct trades to brokers with higher commission rates in exchange for valuable research
support that may enhance the investment returns of client accounts. More details on these
arrangements are disclosed below. The custodian may also charge a flat fee (known as a “trade-away
fee” or “ticket charge”) for trades executed by an outside broker. The custodian’s “trade-away fee” is in
addition to any commission or other compensation that may be paid to the outside (executing) broker.
Cross Transactions
In limited circumstances, when determined to be in the best interest of its clients, MCM may engage in a
cross-transaction pursuant to which firm may affect transactions between two of its managed client
accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when MCM believes
that such transactions are beneficial to its clients). This may present a conflict of interest. For all such
transactions, neither MCM nor any affiliate will be acting as a broker. MCM will not receive any
commission or transaction-based compensation, although MCM has an interest in the price at which the
cross trades are conducted since MCM’s asset-based fees will be negatively impacted by lower bond
values. These transactions will be generally affected through Charles Schwab, the account custodian.
The client may revoke MCM’s cross-transaction authority at any time upon written notice to MCM.
Soft Dollar Arrangements
MCM receives investment research from third party brokerage firms in exchange for client securities
transactions. Under these so called “soft dollar” trading arrangements, MCM may execute trades at the
third-party firms and settle the transactions in the client’s account at the custodian. The research
benefits received in exchange for soft dollar trades include:
information and market data not readily available elsewhere,
access to analysts, and
research conferences and non-commission trade benefits.
direct investment research support,
MCM believes the benefits received are not available on a timely or easily accessible basis other than
from the third parties offering the research. Soft dollar trades represent a small percentage of total firm
trades.
MCM may also use soft dollar trades to pay for services, products, publications, or software related to
investment research. MCM believes that the benefits received from soft dollar trades are beneficial to all
clients and are not limited to those clients who may have participated in certain soft dollar allocations.
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MAPLE CAPITAL MANAGEMENT, INC.
Soft dollar trades are allocated randomly, and the costs may not be proportionally allocated to a given
client account relative to that client’s percentage of total firm assets.
MCM reviews the benefits of the research received in exchange for order flow. MCM does not enter into
any soft dollar arrangements which pre-specify a level of trades to be sent to a third-party brokerage firm.
MCM provides a written notice of our “soft dollar” policy to clients once per year.
B. Aggregated Trades (Block Trades)
MCM shall seek to manage potential conflicts of interest and treat all clients fairly when executing and
allocating trades. In those cases where a potential transaction (including but not limited to IPO
allocations) involves more than one client account, MCM will seek to block trades into a single order for
execution.
Block trades will be allocated in the most equitable manner possible. No client account will be
deliberately favored over any other client account and each account that participates in an aggregated
order will participate at the same average price for all transactions in that security on a given business
day. Notwithstanding this rule, orders not included in the block at the time of execution due to client
specific constraints shall not be merged into the block if such aggregation will result in a negative impact
on the clients already in the block order.
The existence of a block order shall not preclude MCM from executing the block in partial trades over an
unlimited period of time.
Advisor shall seek to allocate shares from block trades on a pro-rata basis to the fullest extent possible
using the trade order management system (TOMS). Pro-rata allocations may be unwieldy for certain
partial executions. Trades not allocated on a pro-rata basis will be handled using the random allocation
tool in the TOMS.
Advisor recognizes that computer generated output, either pro-rata or random, is not always in the best
interest of a given client. System allocations may be overridden to avoid punitive trades for client
accounts. Manual adjustments may be made to both pro-rata and random allocations to reflect client
specific circumstances.
IPO Allocation
In the event that an opportunity arises to purchase securities in an initial public offering deemed
attractive by one or more portfolio managers, the following procedures shall apply:
1.
In no case shall any MCM employee participate in an initial equity offering unless all client orders
are first filled, and then only in accordance with the MCM Code of Ethics.
2.
If the investment is suitable for two or more client accounts and there are not sufficient shares
available to satisfy the demand of all potential participants, the available shares will be allocated
on a pro-rata basis through MCM’s TOMS allocation module. If the number of shares received is
too small for an efficient pro-rata allocation, the TOMS will use a random selection basis to
allocate the shares.
Trade Error Policy
If MCM executes a trade on behalf of a client in error, the error shall be corrected as soon as possible
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MAPLE CAPITAL MANAGEMENT, INC.
after it is discovered. Each effected client shall be put in a position as if the error had not occurred. In
the event that the correcting activity results in a financial loss, MCM shall bear the entire amount of such
loss. In the event that the correcting activity results in a financial gain to the client, such gain shall
remain with the client subject to the client’s custodial trade error policy.
Item 13: Review of Accounts
A. Periodic Review of Client Accounts
Client accounts are supervised by a designated Portfolio Manager. Portfolio Managers construct
portfolios with consideration towards asset allocation, diversification, risk, and current income, as
dictated by client directives. Portfolio composition and results may differ depending upon the manager
assigned to the account and the client specific objectives. Client accounts are regularly reviewed by a
Portfolio Manager to ensure that the management of the account is consistent with the client’s objectives
and the MCM investment process.
Portfolio Managers are in regular contact with clients by telephone or in person to review recent or
recommended security selections, to discuss investment strategy and asset allocation, to review
investment objectives, and to respond to questions. Meetings will be held when desired by the client and
when convenient to all parties.
B. Other Account Reviews
MCM reviews specific accounts in response to changes in client circumstances or investment objectives
(such as liquidity needs or risk tolerance), which may in some cases also result in a change to investment
strategy. Clients are responsible for promptly notifying MCM of changes to their circumstances. Clients
are encouraged to review their Investment Policy Statements on a regular basis.
C. Client Reporting
MCM provides clients a quarterly report package which includes an overview of financial market
conditions and portfolio reports which include holdings and transactions information. MCM may
accommodate specific client requests for customized reports that differ from the standard reporting
package.
Item 14: Client Referrals and Third-Party Compensation
A. Economic Benefits Provided by Third Parties
As discussed under Item 12: Brokerage Practices, MCM receives access to a variety of products and
services as a result of MCM maintaining accounts at multiple qualified custodians and trading activities
with various brokers.
B. Promoter Compensation
MCM receives client referrals from third parties (promoters). Many of these third parties are individuals
or entities with whom MCM has executed promotion arrangements. Under these agreements, MCM pays
Form ADV
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MAPLE CAPITAL MANAGEMENT, INC.
a portion of the annual client fee to the promoters in exchange for these promotion services. Clients
must specifically acknowledge in writing the existence of such relationship and the level of fees paid to
the solicitor. Clients referred through promotion arrangements may pay higher advisory fees than non-
solicited clients. Clients are encouraged to review their specific Fees and Conflicts Disclosure Statement
which will contain more information about whether they are subject to any additional fee as a result of the
existence of a promotion arrangement.
Strategic Partnerships
MCM compensates a limited number of third-party firms for non-solicitation marketing activities. MCM
has entered into a Strategic Partner and Marketing Agreement with Equity Services, Inc. (ESI) and a
Marketing Campaign Package Agreement with Cambridge Investment Research, Inc. In exchange for
MCM compensating these firms, MCM is appointed as a Strategic Partner with benefits that include, but
are not limited to, a list of the third-party firm’s investment advisor representatives (IAR’s), access to
periodic sponsored conferences and a listing on the third-party firms’ internal websites.
MCM engages promoters to introduce new prospective clients to MCM consistent with the Investment
Advisers Act of 1940, its corresponding rules, and applicable state regulatory requirements. If the
prospect subsequently engages MCM, the promoter shall generally be compensated by MCM for the
introduction. Because the promoter has an economic incentive to introduce the prospect to MCM, a
conflict of interest is present.
Please Note - Additional Cost
In certain instances (as shall be reflected on the disclosure statement to be provided to the prospect by
the promoter), the client shall pay more for MCM’s services if introduced through a promoter than if the
client was to engage the services of MCM independent of the promoter. MCM shall not receive any
portion of such additional fee. No such introduced client is obligated to engage MCM. The client must be
guided accordingly.
Item 15: Custody
Clients are required to have an unaffiliated custodian hold their assets. MCM shall have the ability to
have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at
least quarterly, with written transaction confirmation notices and regular written summary account
statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts.
MCM may also provide a written periodic report summarizing account activity and performance.
To the extent that the MCM provides clients with periodic account statements or reports, the client is
urged to compare any statement or report provided by MCM with the account statements received from
the account custodian.
The account custodian does not verify the accuracy of MCM’s advisory fee calculation.
MCM provides other services on behalf of its clients that require disclosure at ADV Part 1, Item 9. In
particular, certain clients have signed asset transfer authorizations that permit the qualified custodian to
Form ADV
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MAPLE CAPITAL MANAGEMENT, INC.
rely upon instructions from MCM to transfer client funds to “third parties.” In accordance with the
guidance provided in the SEC Staff’s February 21, 2017 Investment Adviser Association No-Action
Letter, the affected accounts are not subjected to an annual surprise CPA examination.
MCM is deemed to have custody under SEC rules as a principal of the firm serves as a co-trustee for
certain client accounts. Pursuant to these rules, MCM undergoes a surprise custody examination
conducted by an independent auditor.
Item 16: Investment Discretion
MCM usually receives discretionary authority from clients in the IAA at the outset of a relationship.
Clients must also acknowledge this delegation of discretionary authority in writing to the custodian when
opening an MCM managed account at that firm. Discretionary authority may be withdrawn at any time.
Discretionary authority allows MCM to select the identity an amount of securities to be bought or sold in a
client account. In all cases, however, such discretion is to be exercised in a manner consistent with the
stated investment objectives spelled out for the particular client account.
MCM may accept advisory accounts. An advisory relationship requires client approval to execute each
and every trade. MCM will make every effort to treat advisory clients in the same manner as discretionary
accounts, although MCM cannot impair the level of service provided to other clients in order to
accommodate an advisory request.
Client directed investment guidelines and restrictions must be provided to MCM in writing.
Item 17: Voting Client Securities
MCM has a fiduciary responsibility to ensure that all client proxies entrusted to us are received and voted
with the financial interest of our clients in mind. MCM has retained an independent proxy voting service
to oversee the proper receipt of proxies, to review the issues being voted, and to vote on these issues with
the best interest of our clients in mind. Clients may obtain information from MCM about how the firm
voted any proxies on behalf of their account(s).
Proxy Voting
Unless the client directs otherwise in writing, MCM is responsible for voting client proxies (However, the
client shall maintain exclusive responsibility for all legal proceedings or other type events pertaining to
the account assets, including, but not limited to, class action lawsuits.). MCM, in conjunction with its
engagement with Broadridge Financial Services, Inc. (“Broadridge”) shall vote proxies in accordance
with Glass Lewis & Co Proxy Paper Guidelines Investment Manager Policy, a copy of which is available
upon request. MCM, in conjunction with Broadridge Financial Services, Inc. shall monitor corporate
actions of individual issuers and investment companies consistent with MCM’s fiduciary duty on both
managed and unmanaged to vote proxies in the best interests of its clients. Although the factors which
MCM will consider when determining how it will vote differ on a case-by-case basis, they may, but are not
limited to, include the following: a review of recommendations from issuer management, shareholder
proposals, cost effects of such proposals, effect on employees and executive and director compensation.
Form ADV
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MAPLE CAPITAL MANAGEMENT, INC.
With respect to individual issuers, MCM may be solicited to vote on matters including corporate
governance, adoption or amendments to compensation plans (including stock options), and matters
involving social issues and corporate responsibility. With respect to investment companies (e.g., mutual
funds), MCM may be solicited to vote on matters including the approval of advisory contracts,
distribution plans, and mergers. MCM, in conjunction with Broadridge shall maintain records pertaining
to proxy voting as required pursuant to Rule 204-2 (c)(2) under the Advisers Act. Copies of Rules 206(4)-
6 and 204- 2(c)(2) are available upon written request. In addition, information pertaining to how MCM
voted on any specific proxy issue is also available upon written request. Requests should be made by
contacting the MCM Chief Compliance Officer.
Class Action Lawsuits
Unless the client directs otherwise in writing, MCM has retained the services of Chicago Clearing
Corporation (referred to as “CCC”) to file all eligible class action lawsuits on behalf of the client. CCC
researches, files, monitors, and expedites the distribution of class action settlements. When a claim is
settled and payments are awarded to MCM clients, it may be necessary to share client information, such
as name and account number, with CCC in connection with this service. In exchange for managing class
action filings, CCC earns a fee based on a flat percentage of all claims it collects on behalf of MCM’s
clients. This fee is collected and retained by CCC out of the claims paid by the claim administrator. The
client may opt out the service if they wish to file their own class action lawsuits by contacting MCM’s
Chief Compliance Officer.
Item 18: Financial Information
A. Prepayment of Fees
MCM does not solicit fees of more than $1,200, per client, six months or more in advance.
B. Financial Condition
MCM is a viable entity and it does not foresee any event that is likely to disrupt its ability to conduct
business. MCM has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients.
C. Bankruptcy
MCM has not been the subject of a bankruptcy proceeding.
Form ADV
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MAPLE CAPITAL MANAGEMENT, INC.
Supplemental Information
Part 2B – Brochure Supplement – Ramsey A. Luhr
Item 1: Cover Page
Ramsey A. Luhr, President and Senior Portfolio Manager, Shareholder
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Ramsey A. Luhr that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Ramsey A. Luhr is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Ramsey A. Luhr, President and Senior Portfolio Manager, Shareholder, born 1972
Education:
B.A. International Relations, Trinity College, 1994
Business Background:
Maple Capital Management, President and Senior Portfolio Manager, 2024 to present
Maple Capital Management, President, Chief Operating Officer, and Senior Portfolio Manager, 2004
to 2024
NL Capital Management, Inc., Vice President and Portfolio Manager, 2001 to 2004
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Ramsey A. Luhr is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Form ADV
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August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
22
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Elizabeth S. H. Lewis, CFA
Item 1: Cover Page
Elizabeth S. H. Lewis, CFA*, Senior Vice President, Client Portfolio Management Team Lead, Shareholder
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Elizabeth S. H. Lewis that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Elizabeth S. H. Lewis is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Elizabeth S. H. Lewis, CFA*, Senior Vice President, Client Portfolio Management Team Lead, Shareholder,
born 1979
Education:
B.S. Business Administration, University of Vermont, 2001
Business Background:
Maple Capital Management, Portfolio Management Team Lead, 2019 to present
Maple Capital Management, Portfolio Manager, 2012 to 2019
Equity Services, Inc., Senior Business Development Associate, 2008 to 2012
*The Chartered Financial Analyst (CFA) designation is an international professional designation offered
through CFA Institute. To earn the CFA charter, candidates must pass three exams, have at least four years of
investment experience, join the CFA Institute as a member and commit to abide by and annually reaffirm
their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct.
For more information about the CFA charter, visit www.cfainstitute.com.
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Elizabeth S. H. Lewis is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Form ADV
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August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
24
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Timothy J. Wooster
Item 1: Cover Page
Timothy J. Wooster, Portfolio Manager, Shareholder
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Timothy J. Wooster that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Timothy J. Wooster is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Timothy J. Wooster, Portfolio Manager, Shareholder, born 1980
Education:
B.A. Business Administration, Northern Vermont University (formerly Johnson State College), 2004
Business Background:
Maple Capital Management, Portfolio Manager, 2017 to present
First Advisors, First National Bank, Portfolio Manager, 2015 to 2017
Bar Harbor Bank & Trust, Portfolio Manager, 2013 to 2015
People’s United Bank, Portfolio Manager, 2007 to 2013
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Timothy J. Wooster is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
Form ADV
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August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
26
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Debbie L. Montgomery, CFP
Item 1: Cover Page
Debbie L. Montgomery, CFP®*, Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Debbie L. Montgomery that supplements the
Maple Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Debbie L. Montgomery is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Debbie L. Montgomery, CFP®*, Portfolio Manager, born 1962
Education:
B.S. Finance, Georgia State University, 1986
Business Background:
Maple Capital Management, Portfolio Manager, 2016 to present
DM Financial Planning, Inc., Independent Financial Advisor, 1994 to 2016
*Certified Financial Planner (CFP): Accredited by the National Commission for Certifying Agencies (NCCA), this
designation is issued by the Certified Financial Planner Board of Standards, Inc. (CFPBS) and is granted to
individuals who complete a CFP Certification Examination and as well as to meet the following prerequisites:
bachelor’s degree from an accredited college of university and three years of full time personal financial
planning experience. In order to qualify, the candidate must complete a CFP-board registered program or
meet a challenge status by holding another accreditation or designation. Once issued, the candidate is
required to complete 30 hours of continuing education every two years and must continuously meet the
standards administered by CFPBS.
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Debbie L. Montgomery is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Form ADV
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MAPLE CAPITAL MANAGEMENT, INC.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
28
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – David J. Bosworth
Item 1: Cover Page
David J. Bosworth, Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about David J. Bosworth that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about David J. Bosworth is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
David J. Bosworth, Portfolio Manager, born 1968
Education:
MS, Business Leadership & Management, Saint Michael’s College, 1999
B. S. Business, University of Vermont, 1990
Business Background:
Maple Capital Management, Portfolio Manager, 2022 to present
Community Trust Services, Portfolio Manager, 2017 to 2022
Merchants Trust Company, Portfolio Manager, 1999 to 2017
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
David J. Bosworth is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
Form ADV
29
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
30
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Clayton T. Shiver, CFA
Item 1: Cover Page
Clayton T. Shiver, CFA*, Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Clayton T. Shiver that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Clayton T. Shiver is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Clayton T. Shiver, CFA*, Portfolio Manager, born 1987
Education:
BBA Finance, University of Georgia, 2010
Business Background:
Maple Capital Management, Portfolio Manager, 2020 to present
Stadion Money Management, Portfolio Manager, 2015 to 2020
Stadion Money Management, Analyst, 2010 to 2015
*The Chartered Financial Analyst (CFA) designation is an international professional designation offered
through CFA Institute. To earn the CFA charter, candidates must pass three exams, have at least four years of
investment experience, join the CFA Institute as a member and commit to abide by and annually reaffirm
their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct.
For more information about the CFA charter, visit www.cfainstitute.com.
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Clayton T. Shiver is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Form ADV
31
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
32
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Fjolla Buza-Sotak
Item 1: Cover Page
Fjolla Buza-Sotak, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Fjola Buza-Sotak that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Fjolla Buza-Sotak is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Fjolla Buza-Sotak, Assistant Portfolio Manager, born 1992
Education:
M.A. Economics, City College of New York, 2017
B.S. Economics, Rochester Institute of Technology, 2014
Business Background:
Interactive Brokers, Institutional Client Onboarding, 2019 to 2021
Maple Capital Management, Assistant Portfolio Manager, 2021 to present
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Fjolla Buza-Sotak is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
33
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Richard J. Litchfield, CFA
Item 1: Cover Page
Richard J. Litchfield, CFA*, Senior Vice President & Fixed Income Portfolio Manager, Shareholder
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Richard J. Litchfield that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Richard J. Litchfield is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Richard J. Litchfield, CFA*, Senior Vice President & Fixed Income Portfolio Manager, Shareholder, born 1967
Education:
MBA, Boston University, 1995
B.S. Finance, Boston College, 1989
Business Background:
Maple Capital Management, Senior Vice President & Fixed Income Portfolio Manager, 2019 to
present
Opus Investment Management, Portfolio Manager, 1995 to 2019
*The Chartered Financial Analyst (CFA) designation is an international professional designation offered
through CFA Institute. To earn the CFA charter, candidates must pass three exams, have at least four years of
investment experience, join the CFA Institute as a member and commit to abide by and annually reaffirm
their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct.
For more information about the CFA charter, visit www.cfainstitute.com.
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Richard J. Litchfield is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Form ADV
34
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
35
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Connor G. Herbruck
Item 1: Cover Page
Connor G. Herbruck, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Connor G. Herbruck that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Connor G. Herbruck is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Connor G. Herbruck, Assistant Portfolio Manager, born 1998
Education:
B.A. Business Administration, University of Vermont – Grossman School of Business 2020
Business Background:
Maple Capital Management, Assistant Portfolio Manager, 2022 to present
Maple Capital Management, Client Service Specialist, 2020 – 2022
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Connor G. Herbruck is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
36
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Brody J. Hoffman, CFP
Item 1: Cover Page
Brody J. Hoffman, CFP, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Brody J. Hoffman that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Brody J. Hoffman is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Brody J. Hoffman, CFP, Assistant Portfolio Manager, born 1991
Education:
B.A. Business Administration, University of Vermont – Grossman School of Business 2017
Business Background:
LaGue, Inc., Property Manager, 2021 to 2022
IG Wealth Management, Consultant, 2017 to 2021
Maple Capital Management, Assistant Portfolio Manager, 2024 to present
Maple Capital Management, Client Service Specialist, 2022 to 2024
Mainline Chrysler, Sales Associate, 2016 to 2017
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Brody J. Hoffman is not actively engaged in any investment-related or non-investment-related business or
occupation outside of Maple Capital Management.
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
Form ADV
37
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
38
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Thomas W. Rawlings
Item 1: Cover Page
Thomas W. Rawlings, Chief Operating Officer / Chief Compliance Officer
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Thomas W. Rawlings that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Thomas W. Rawlings is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Thomas W. Rawlings, Chief Operating Officer / Chief Compliance Officer, born 1961.
Education:
Master’s Business Administration, Boston University, School of Management, Boston 2003
Bachelor of Science, University of Massachusetts, Boston 1997
Business Background:
Maple Capital Management, Chief Operating and Chief Compliance Officer, 2024 to present.
Rawlings Consulting Services, LLC, Managing Member, 2017 to 2024
Rothschild Asset Management, Chief Operating Officer, 2009 to 2016
O’Shaugnessy Asset Management, Chief Operating Officer, 2007 to 2009
Bear Sterns Asset Management, Head of Implementation, 2006 to 2008
State Street Global Advisors, Index Portfolio Manager, 1995 to 2006
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
Thomas W. Rawlings is the managing member of Rawlings Consulting Services, LLC (TWRCS). TWRCS has
no active clients. TWRCS serves in an advisory capacity to the firms trading technology infrastructure.
Item 5: Additional Compensation
None
Form ADV
39
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838
Thomas W. Rawlings activities are monitored by Ramsey A. Luhr, President & Senior Portfolio Manager,
Shareholder, Mr. Luhr’s phone number is 802-229-2838.
Form ADV
40
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Bryan A. Hall, CFA
Item 1: Cover Page
Bryan A. Hall, CFA, Fixed Income Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Bryan A. Hall that supplements the Maple Capital
Management brochure. A copy of that brochure precedes this supplement. Please contact Thomas W.
Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have any questions
about the contents of this supplement.
Additional information about Bryan A. Hall is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Bryan A. Hall, CFA, Fixed Income Portfolio Manager, born 1978.
Education:
B.S. Business Administration, University of New Hampshire, Durham, NH, 2000
Business Background:
Maple Capital Management, Fixed Income Portfolio Manager, 2024 to present.
MFS Investment Management, Fixed Income Analyst – Investment Officer, 2011 to 2024
MFS Investment Management, Research Associate, 2009 to 2011
MFS Investment Management, Fixed Income Trading Associate, 2007 to 2009
MFS Investment Management, Investment Product Analyst, 2006 to 2007
MFS Investment Management, Regional Sales Representative, 2004 to 2006
MFS Investment Management, Client Service Representative, 2002 to 2004
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Form ADV
41
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
42
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Miguel J. Rivas
Item 1: Cover Page
Miguel J. Rivas, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Miguel J. Rivas that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Miguel J. Rivas is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Miguel J. Rivas, Assistant Portfolio Manager, born 1996.
Education:
B.S. Business Administration, Mississippi State University, Starkville, MS, 2020
Business Background:
Maple Capital Management, Assistant Portfolio Manager, 2024 to present.
Cornerstone Investment Partners, Operations Analyst, 2021 to 2024
Deutsche Bank, KYC Analyst, 2020 to 2021
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
43
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Chris W. Arthur, CFA
Item 1: Cover Page
Chris W. Arthur, CFA, Client Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Chris W. Arthur that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Chris W. Arthur is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Chris W. Arthur, CFA, Client Portfolio Manager, born 1976.
Education:
MBA Finance, Boston University, Boston, MA, 2004
B.S. Business Administration, Susquehanna University, Selinsgrove, PA, 1998
Business Background:
Maple Capital Management, Client Portfolio Manager, 2025 to present.
Independent Consultant, Independent Consultant, 2024 to 2025
Eaton Vance, Portfolio Strategy Consultant, 2014 to 2023
LPL Financial, Portfolio Strategist, 2005 to 2014
State Street Global Advisors, Analyst, 1997 to 2005
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Form ADV
44
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
45
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Caitlyn Wilkin
Item 1: Cover Page
Caitlyn Wilkin, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Caitlyn Wilkin that supplements the Maple Capital
Management brochure. A copy of that brochure precedes this supplement. Please contact Thomas W.
Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have any questions
about the contents of this supplement.
Additional information about Caitlyn Wilkin is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Caitlyn Wilkin, Assistant Portfolio Manager, born 1998.
Education:
B.A. Economics, Connecticut College, 2021
Business Background:
Maple Capital Management, Assistant Portfolio Manager, 2026 to present
Maple Capital Management, Client Service Specialist, 2024 to 2026
Bracebridge Capital, Middle Office Trade Support Analyst, 2023 to 2024
Bracebridge Capital, Investment Operations Specialist, 2021 to 2023
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
46
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Georgi Ivanov, CFA
Item 1: Cover Page
Georgi Ivanov, CFA, Client Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Georgi Ivanov that supplements the Maple Capital
Management brochure. A copy of that brochure precedes this supplement. Please contact Thomas W.
Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have any questions
about the contents of this supplement.
Additional information about Georgi Ivanov is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Georgi Ivanov, CFA, Client Portfolio Manager, born 1972.
Education:
B.S. Electrical Engineering, University of Pennsylvania, 1996
B.S Bio Engineering, University of Pennsylvania, 1996
Master’s in Business Administration, Duke University, 2002
Business Background:
Maple Capital Management, Client Portfolio Manager, 2026 to present
Master Card, Inc., Director of Corporate Treasury, 2024 to 2025
Nexo, LLP, Vice President in Business Development, 2021 to 2023
Wells Fargo, Inc., Director of Risk, 2018 to 2021
Angel Oak Capital, Inc., Director of Risk, 2015 to 2018
Bank of America, Inc. SVP Global Enterprise Risk, 2006 to 2015
GE Capital, Inc. Financial Analyst, 2003 to 2006
Price Waterhouse Coopers, Management Consultant, 1998 to 2000
Deloitte Consulting, Systems Analyst, 1996 to 1998
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Form ADV
47
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
48
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Part 2B – Brochure Supplement – Timothy Mazurczak, CFA
Item 1: Cover Page
Timothy Mazurczak, CFA, Assistant Portfolio Manager
Maple Capital Management
535 Stone Cutters Way
Montpelier, VT 05602
This brochure supplement provides information about Timothy Mazurczak that supplements the Maple
Capital Management brochure. A copy of that brochure precedes this supplement. Please contact
Thomas W. Rawlings, CCO if you did not receive Maple Capital Management’s brochure or if you have
any questions about the contents of this supplement.
Additional information about Timothy Mazurczak is available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2: Educational Background and Business Experience
Timothy Mazurczak, CFA, Assistant Portfolio Manager, born 1992.
Education:
B.S. Accounting, Canisius University, 2015
Master’s in Accounting, Canisius University, 2016
Business Background:
Maple Capital Management, Assistant Portfolio Manager, 2026 to present
Dowling & Partners, Equity Research Associate, 2024 to 2026
Sterling Investment Counsel, Investment Analyst, 2021 to 2024
Northrop Grumman, Business Management Analyst, 2019 to 2021
Citi Research, Sr Equity Research Associate, 2018 to 2019
Citi Research, Equity Research Associate, 2016 to 2018
Item 3: Disciplinary Information
None
Item 4: Other Business Activities
None
Item 5: Additional Compensation
None
Item 6: Supervision
Maple Capital Management provides investment advisory and supervisory services in accordance with our
Policies and Procedures Manual and Code of Ethics. MCM’s Chief Compliance Officer (CCO), Thomas W.
Form ADV
49
August 5, 2026
MAPLE CAPITAL MANAGEMENT, INC.
Rawlings, is primarily responsible for the implementation of MCM’s policies and procedures. All of MCM’s
employees’ activities are monitored by the CCO and if any employee has questions regarding the policies and
procedures they can contact Thomas W. Rawlings, CCO at 802-229-2838.
Form ADV
50
August 5, 2026