# Bolton Investment

> Bolton Investment is an SEC-registered investment advisory firm in Towson, MD, registered since 1994, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 28, 2026.

- CRD: 104684
- Filed as: BOLTON INVESTMENT
- Legal name: Bolton Partners Investment Consulting Group, Inc.
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: Towson, MD
- Filing period: October 2026
- Form ADV filing dated: March 28, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/104684
- AdvisorCensus page: https://advisorcensus.com/firm/bolton-investment-towson-md-104684

## Quick answers

**How is Bolton Investment compensated?**
On its Form ADV (Item 5.E, October 2026), Bolton Investment reports these compensation arrangements: a percentage of assets under its management; hourly charges; fixed fees (other than subscription fees). The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Bolton Investment located?**
Bolton Investment's principal office is in Towson, MD, according to its Form ADV; the April 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Bolton Investment registered with the SEC or a state?**
Bolton Investment is an SEC-registered investment advisory firm, registered since 1994. Status as filed: Approved. CRD 104684.

**How much does Bolton Investment manage?**
Bolton Investment reports $249,134,519 in regulatory assets under management in its Form ADV filing dated March 28, 2026 (100% discretionary).

**How have Bolton Investment's assets and staff changed since 2021?**
In the Form ADV data for Bolton Investment: Regulatory assets under management: $40,303,089 in the October 2021 data and $249,134,519 in the October 2026 data, up 518%. Total employees: 8 in October 2021 and 11 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Bolton Investment serve?**
By number of clients on Form ADV Item 5.D: pension and profit sharing plans (but not the plan participants or government pension plans) (8); charitable organizations (1).

**Which custodians does Bolton Investment use?**
Bolton Investment's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Empower Retirement, Lincoln Financial Services, PNC Wealth Management LLC and Principal Financial Group as custodians holding 10% or more of its separately managed account assets.

**Does Bolton Investment report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/104684

**What changed in Bolton Investment's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 8 to 7. Regulatory assets under management went from $138,533,476 to $249,134,519 (+80%). Changed its office addresses in Boulder, CO. No longer lists an office in Blue Bell, PA.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

### Custodians (Schedule D, Section 5.K(3))
- Empower Retirement
- Lincoln Financial Services
- PNC Wealth Management LLC
- Principal Financial Group

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $249,134,519
- Discretionary: $249,134,519
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 8 | $247,073,167 |
| Charitable organizations | 1 | $2,061,352 |

### Advisory services (Item 5.G)
- Pension consulting services
- Selection of other advisers (including private fund managers)

### Firm details
- Registered since: 1994 (32 years)
- Employees: 11 total, 7 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CO, MD, PA, VA
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the April 2026 filing
- Boulder, CO

### Websites listed on Form ADV (Item 1.I)
- boltonusa.com
- LinkedIn @boltonusa

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | $40,303,089 | 8 | April 20, 2021 |
| October 2022 | $52,747,385 | 9 | May 16, 2022 |
| October 2023 | $37,362,082 | 9 | March 10, 2023 |
| October 2024 | $60,991,211 | 9 | June 6, 2024 |
| October 2025 | $138,533,476 | 10 | March 24, 2025 |
| October 2026 | $249,134,519 | 11 | March 28, 2026 |

Regulatory assets under management: $40,303,089 in the October 2021 data and $249,134,519 in the October 2026 data, up 518%.
Total employees: 8 in October 2021 and 11 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 8 to 7.
- Regulatory assets under management went from $138,533,476 to $249,134,519 (+80%).
- Changed its office addresses in Boulder, CO.
- No longer lists an office in Blue Bell, PA.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Bolton Investment (CRD 104684): Form ADV filing data as of October 2026.