Part 2A of Form ADV: Firm Brochure Congress Asset Management

Transcription

Part 2A of Form ADV: Firm Brochure
Congress Asset Management Company, LLP
2 Seaport Lane
5th Floor
Boston, MA 02210
Telephone: 617-737-1566
Email: info@congressasset.com
Web Address: www.congressasset.com
March 24, 2015
This Firm Brochure (or “Brochure”) provides information about the qualifications and business practices of Congress Asset
Management Company, LLP. If you have any questions about the contents of this Brochure, please contact us at 617-737-1566
or info@congressasset.com. The information in this Firm Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about Congress Asset Management Company, LLP also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD
number is 105161.
Congress Asset Management Company, LLP – Firm Brochure
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Item 2
Summary of Material Changes
Background Information
The Securities and Exchange Commission (the “SEC”) adopted regulations requiring Amendments to Form ADV in
July 2010. These rules required Registered Investment Advisors (Advisors) to develop and distribute to its Clients
in narrative format, a “Plain English” Brochure as its official disclosure document. The rules also require an Advisor
to provide a Summary of Material Changes document to its Clients along with an offer to provide a copy of the
complete Brochure at least annually or if there is a material change. Under the rules, if a Client wishes to receive a
copy of the Brochure, fulfillment of the request will be at the expense of the Advisor.
Summary of Material Changes
This Brochure dated March 24, 2015 provides information about the qualifications and business practices of Congress
Asset Management Company, LLP. Except for the items listed below, the business practices are substantially the same
as represented in this Firm’s previous annual updated Brochure, dated March 5, 2014.
Item 4. Ownership
The Estate of Alfred Alphonsus Lagan was removed as an Indirect Owner of Congress Asset Management Company, through its
holding of Lagan Holding Company, Trust.
Affiliated Investment Advisors
The Advisor is affiliated and under common control with Congress Wealth Management, LLC and Congress Capital
Partners, LLP. Details of the relationships are described in this Disclosure Brochure. Please see Item 10, “Other
Financial Industry Activities and Affiliations” on Page 9.
Item 15. Custody
Congress Asset has certain Client relationships where it believes it has, or may be deemed to have, custody pursuant
to Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Advisors Act”). For all such Client
accounts, (i) Congress Asset will obtain an annual surprise examination from an independent auditor; (ii) Client assets
are held at qualified custodian(s) of the Client’s choosing, who shall provide account statements directly to clients, at
least quarterly; (iii) Congress Asset will provide to each Client an account statement(s) at least quarterly, enabling
Clients to compare such information to their custody statements. Please see Item 15, “Custody” on page 13.
Annual Offer to Clients
At any time, you may view the current Brochure on-line at the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov.
You may also request a copy of this Brochure upon written request to:
Congress Asset Management
2 Seaport Lane
th
5 Floor,
Boston, MA 02210-2001
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Table of Contents
Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance-Based Fees and Side-By-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
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Item 4
Advisory Business
Firm Description and Ownership:
Congress Asset Management Company, LLP (“Congress Asset” or, the “Firm”) is a SEC registered investment adviser with its principal place of
business located in Boston, Massachusetts. Congress Asset began conducting business in 1985. The Firm is owned by Lagan Holding Company
Trust. and Lagan-Congress, Inc., who serve as general partners. Lagan Holding Company, Trust. owns 100% of Lagan-Congress, Inc.
Types of Advisory Services:
Overview
Congress Asset provides discretionary and model portfolio investment management services to individual and institutional clients (“Clients”). Clients
include charitable organizations, pension and profit sharing plans (including plans subject to the Taft-Hartley Act), state and municipal government
entities, corporations, taxable and tax-exempt institutions, high net worth individuals and commingled investment vehicles such as mutual funds.
Congress Asset also provides these services in the capacity of a sub-adviser to mutual fund advisors and to wrap account programs sponsored by
other investment advisers and broker-dealers (“Wrap Sponsors”).
Congress Asset is primarily a growth style equity investment manager and also provides skilled investment management services in the areas of
fixed income portfolios and balanced portfolios. The Firm also provides customized private equity services for institutional investors only. In addition,
Congress Asset also offers access to portfolio strategy, asset allocation, and construction advice to current and prospective institutional Clients.
Such breadth enables Congress Asset to construct portfolios consistent with each Client’s objectives and risk tolerances.
Congress Asset’s investment products available to Clients include:
• Large Cap Growth Equity
• Mid-Cap Growth Equity
• Small Cap Growth Equity
• Dividend Growth Equity
• Multi-Cap Growth Equity
• All Cap Opportunity
• Balanced
• Fixed Income
• Private Equity
Separately Managed Accounts (“SMA”)
Our firm provides continuous investment advice to individual and institutional Client SMAs. Each Client SMA is managed based on the Client’s immediate
and longer-term needs and goals. We also work with each Client to identify his or her time horizon, risk tolerance and liquidity needs. As appropriate,
we also review and discuss a Client's prior investment experience, as well as other background information to help us construct the most appropriate
investment portfolio.
Account supervision is guided by the Client's stated objectives (e.g., maximum capital appreciation, growth, income, or growth and income), as
well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Such reasons may be for personal, religious and statutory reasons.
Client portfolios will generally include advice regarding the following securities: exchange-listed securities, securities traded over-the-counter,
exchange-traded funds (“ETFs”), corporate debt securities (other than commercial paper), commercial paper, certificates of deposit, municipal
securities, mutual fund shares, United States Government securities, warrants, option contracts on securities and private equity limited partnership
interests (for institutions only).
Advisory Services to Wrap Sponsors
Discretionary portfolio management is also made available to Wrap Sponsors pursuant to a sub-advisory agreement with the Firm, where the Firm
will manage all or a portion of certain Wrap Sponsor’s Clients’ investment portfolios. In these arrangements the Wrap Sponsor, not the individual
investor, is the Firm’s advisory Client. Wrap Sponsors typically charge their Clients an all-inclusive “wrap fee” from which the investment advisor is
paid a portion of such fee. In addition, most Wrap Sponsors will require Congress Asset to direct brokerage on trades made by the Firm on behalf
of their wrap clients their designated broker-dealer.
Typically, the Wrap Sponsor will present Congress Asset as one candidate of several for the provision of investment management services to its
clients pursuant to the sponsor's wrap fee program. Congress Asset, along with the names of one or more other investment advisors, will be
supplied to those clients for whom the stated investment philosophy and policies of the advisor and providing its services appear suitable.
Each Wrap Sponsor is required to deliver to the wrap fee clients a wrap fee program Brochure and a copy of Congress Asset’s most recent Form ADV Part
2A, pursuant to the requirements of the Investment Advisers Act of 1940, as amended.
Congress Asset participates in wrap fee programs sponsored by: Adhesion Wealth Advisor Solutions Inc., Argentus Partners, LLC., Brinker
Capital Inc., Charles Schwab & Co, Inc., CIBC Wood Gundy, Citigroup Global Markets, Inc., Claraphi Advisory Network, Concord Equity Group
Advisors, Concord Wealth Management, Deutsche Bank Securities Inc., Edward D. Jones & Co., LLP, Envestnet Asset Management, Inc./
FundQuest Inc., Fifth Third Bank, Folio Dynamix, JP Morgan/Bear Stearns, KeyBank National Association, Ladenburg Thalmann, Lockwood
Advisors, Inc., LPL Financial Corp., Merrill Lynch UMA, Morgan Stanley Smith Barney LLC, Mount Yale UMA, Oppenheimer Asset Management,
Placemark Investments, Inc., RBC Capital Markets Group, RW Baird, Sawtooth Asset Management, Inc., Stephens, Inc., Stifel, Nicolaus &
Company, Inc., TD Ameritrade, UBS Financial Services, Inc., US Bank National Association, Wells Fargo Advisors, LLC
Congress Asset may terminate its services to one or more of its Clients under the agreement for any reason, or for no reason, upon at least 30 days
of prior notice.
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Mutual Fund Portfolio Management
Congress Asset provides discretionary investment management and related services to mutual funds (i.e., open-end investment companies registered
under the Investment Company Act of 1940, as amended). These funds are: The Congress Large Cap Growth Fund, the Congress Mid Cap Growth Fund,
and the Congress All Cap Opportunity Fund (the "Congress Funds").
Daniel A. Lagan and Gregg A. O'Keefe serve as the investment managers to the Congress Large Cap Growth Fund. Todd W. Solomon and Gregg A.
O’Keefe, serve as the investment managers to the Congress Mid Cap Growth Fund and Peter C. Andersen and Matthew T. Lagan serve as the
investment managers to the Congress All Cap Opportunity Fund.
Interested investors should refer to the Mutual Fund's prospectus and Statement of Additional Information ("SAI") for important information regarding
objectives, investments, time-horizon, risks, fees, and additional disclosures. These documents are available on-line at:
http://www.congressasset.com/funds/. Prior to making any investment in the Mutual Funds, investors and prospective investors should carefully
review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Funds. Each
Congress Fund’s prospectus is available through the Firm’s website: http://www.congressasset.com/funds/
Sub Advisory to Mutual Funds
Congress Asset provides investment sub-advisory services to the Princeton Futures Strategy Fund (the "Princeton Fund"), a mutual fund registered
under the Investment Company Act of 1940. As the investment manager to the fixed income portion of the Princeton Fund, Jeffrey R. Porter is
responsible for developing, constructing and monitoring the fixed income portion of the fund.
Interested investors should refer to the Princeton Fund's prospectus and SAI for important information regarding objectives, investments, timehorizon, risks, fees, and additional disclosures. These documents are available online at www.pfstrategyfund.com. Prior to making any investment in
the Princeton Fund, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms
and conditions applicable for investment in the fund.
Sub-Advisory Arrangements with Affiliates
Congress Asset also serves as sub-adviser to its two registered adviser affiliates: Congress Capital Partners, LLP (“Congress Capital Partners”) and
Congress Wealth Management, LLC (“Congress Wealth”). In its capacity as sub-adviser to Congress Capital, Congress Asset provides portfolio
management, administrative and operational support. Please refer to “Other Financial Industry Activities and Affiliations”, Item 10 of this Brochure for
more information regarding the Firm’s relationship with its affiliates.
Model Portfolio Management:
Congress Asset provides model portfolio management services to institutional Clients, primarily Wrap Sponsors of Unified Managed Account (“UMA”)
structures. Congress Asset will communicate model changes to the Wrap Sponsors. In turn, each Wrap Sponsor is responsible for effecting such
changes in their Client accounts.
Private Equity
Congress Asset provides discretionary and non-discretionary investment management services to pension and profit sharing plans that invest in limited
partnerships. Investment in these types of securities may involve certain additional degrees of risk and will only be recommended to institutional Clients
and only when consistent with the Client's stated investment objectives, tolerance for risk, liquidity and suitability.
Other Advisory Services
Congress Asset also offers access to portfolio strategy, asset allocation, and construction advice (“Portfolio Construction Services”) to its current and
prospective institutional Clients. Such service may be included as part of the investment management agreement or as part of a distribution/referral
or custody agreement. The Firm may also provide this service as a standalone arrangement. Fees for such services are generally based on a
percentage of the institutional Client’s assets under management. The Advisor at its discretion may also waive fees altogether.
Amount of Assets Managed
As of 12/31/2014, we were actively managing $ 6,328,086,176 of Clients' assets on a discretionary basis and $1,120,764,079 of Clients' assets on
a non-discretionary basis. The total assets under management were $7,448,850,255.
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Item 5
Fees and Compensation
Investment Advisory Fees
Overview
Congress Asset typically charges an investment advisory fee based on a percentage of the assets under its management. Fees are calculated on
either a monthly or quarterly basis, and may be payable either in advance based on the value of the account as of the beginning of each billing
period, or in arrears based on the value of the account at the end of each billing period. The account management fee is prorated for periods less
than a full billing cycle.
Congress Asset may, but generally does not, enter into performance based fee arrangements. All fee arrangements, terms and conditions of the fee
structure will be mutually agreed upon prior to entering into an Investment Management Agreement. See Item 6 for more information on performance
based fees.
Congress Asset retains the discretion to negotiate alternative fees on a Client-by-Client basis. Client facts, circumstances and needs are considered in
determining the fee schedule. These include but are not limited to: complexity of the Client, amount of assets to be placed under management, anticipated
future additional assets, assets under management in related accounts, complexity of Client specific guidelines and restrictions and special reporting/client
service requirements. Each Client’s fee is agreed to in writing within the investment management contract.
The Firm may group certain related Client accounts for the purposes of achieving the minimum account size requirements and determining the
annualized fee. Discounts may be offered to family members and friends or associated persons of our firm.
Discretionary Portfolio Management
Congress Asset's annual fees for Discretionary Portfolio Management Services are based upon a percentage of assets under management and
generally range from 0.10% to 1.00%. The investment advisory fees are negotiable and differ from one Client to another based on certain criteria such
as: amount of assets, Client type, style, customization, and other factors discussed above.
Mutual Fund Portfolio Management
The annualized fee for Mutual Fund Portfolio Management services is charged as a percentage of assets under management. Management fees are
accrued daily and paid monthly, in arrears. The Firm may also waive or defer all or a portion its advisory fee based upon an agreement with the
mutual fund to limit a fund’s overall expense ratio. Below is the fee schedule to the Congress Funds.
Fund Name
Management Fee
Congress Large Cap Growth Fund
0.50% per annum
Congress Mid Cap Growth Fund
0.60% per annum
Congress All Cap Opportunity Fund
0.60% per annum
Sub Advisory to Mutual Funds
Congress Asset is also a provider of sub advisory services to mutual fund advisors. Fees for this service are negotiable.
Sub Advisory to Affiliates
Congress Asset also serves as sub-adviser to its two registered adviser affiliates: Congress Capital Partners, LLP (“Congress Capital Partners”) and
Congress Wealth Management, LLC (“Congress Wealth”). Each sub-advisory agreement provides for investment management and trlated trading
and operational support.
In its capacity as sub-adviser to Congress Capital, Congress Asset is the investment manager to the Risk Managed Assets and Risk Managed
Satellites strategies (the “Risk Managed Series”). The strategies of the Risk Managed Series employ a strategic and tactical allocation of low cost
exchange traded funds (“ETFs”) with the ability to move quickly to cash under various market scenarios.
The Firm also serves as sub-advisor to Congress Wealth. The Firm acts as investment manager to certain Congress Wealth clients who wish to
solely contract with Congress Wealth, rather than contracting directly with Congress Asset.
Model Portfolio Management
Congress Asset’s annual fees for Model Portfolio Management Services are based upon a percentage of assets under management and generally
range from 0.20% to 0.50%. The annualized fee for Model Portfolio Management Services is charged as a percentage of assets under
management as negotiated with each Client, typically a Wrap Sponsor to a UMA program.
A minimum of $100,000 of assets under management is required for this service. This account size may be negotiable under certain
circumstances. Congress Asset may group certain related Client accounts for the purposes of achieving the minimum account size and determining
the annualized fee.
Private Equity
Congress Asset assesses an annualized fee of up to 0.50% on a Client investment in private equity limited partnership. For the first two years of
each investment, the fee is applied to total commitments made by the Client. Thereafter, the fee is applied to the amount of the Client’s invested
capital in each partnership. In certain cases, the Firm may enter into a flat fee arrangement, if appropriate to both the Client and Congress Asset.
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Termination of the Advisory Relationship
A Client agreement may be canceled by either party at any time and for any reason upon receipt of 30 days written notice. As disclosed above,
certain fees are paid in advance of services provided. Upon termination of any account, any prepaid and/or unearned fees will be promptly 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.
Other Fees
Additional Fees and Expenses:
Clients are also subject to fees and expenses charged by custodians and broker dealers for services such as safekeeping, brokerage and
administration of their account. In addition, Clients who were referred to Congress by another investment adviser may be subject to advisory fees
separate and apart from those of Congress Asset.
Mutual Fund and ETF Fees
Under certain circumstances Congress Asset may invest all or a portion of a Client’s assets in mutual funds and/or ETFs. Fees paid to Congress
Asset for investment advisory services are separate and distinct from the fees and expenses charged by such funds to their shareholders. These
fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, a distribution fee and charges for fund
operating expenses. If the fund also imposes sales charges, a Client may pay an initial or deferred sales charge.
In cases where a Client of Congress Asset is invested in a Congress Fund, the Congress Asset advisory fee will be waived relating to the amount of assets
invested in the Congress Fund.
ERISA Accounts
Congress Asset 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"), and regulations under the Internal Revenue Code. As such, Congress Asset 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. Congress Asset may only charge fees for investment advice about products for which it and/or its related persons
do not receive any commissions or 12b-1 fees, or conversely, when such fees are used to offset Congress Asset's advisory fees.
Item 6
Performance-Based Fees and Side-By-Side Management
Performance Based Fees
Congress Asset may, but generally does not, enter into performance based fee arrangements with its Clients. In such cases, fee arrangements
will be based on a percentage of assets under management plus a percentage of the difference between the performance of the Client’s
account and that of an appropriate index.
Side by-side Management
The Firm recognizes that managing Client accounts with a performance based fee arrangement may create conflicts where an account with a
performance based fee may receive allocations of certain investment opportunities over another Client accounts. The Firm believes that
opportunities for such conflict are mitigated by the high level of liquidity for comparable securities among all its Clients, The Firm’s policies and
procedures with regard to trading, its code of ethics and account review process.
Item 7
Types of Clients
As discussed above in Item 4, Congress Asset provides discretionary and model portfolio investment management services to individual and
institutional Clients. Clients include charitable organizations, pension and profit sharing plans (including plans subject to the Taft-Hartley Act), state
and municipal government entities, taxable and tax-exempt institutions, high net worth individuals and commingled investment vehicles such as
mutual funds. Congress Asset also provides these services in the capacity of a sub-adviser and through wrap accounts sponsored by other
investment advisers or broker-dealers.
Generally, a minimum of $100,000 of assets under management is required for this service. This account size may be negotiable under certain
circumstances. Congress Asset may group certain related Client accounts for the purposes of achieving the minimum account size and determining
the annualized fee.
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Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Overview - Equities
Congress Asset employs a view that superior long-term performance of a company’s stock price is generated by companies which consistently grow
earnings and cash flow. Stock selection is primarily based on a research-driven bottom up approach, balanced by a congressional approach, where
each investment strategy is governed by an investment product committee (“IPC”). The IPC is where research and recommendations are reviewed,
debated and decided upon. Each of Congress Asset’s IPC’s contain at least one representative from the Firm’s Investment Oversight Committee
(“IOC”). The IOC is responsible for oversight of all investment activity and for the Firm’s general investment policies.
Congress Asset uses many research techniques which may be summarized as follows:
Idea Generation: Congress Asset exercises continuous and proactive idea generation. Portfolio managers and research analysts identify
possible investment opportunities using numerous tools, such as quantitative screening, third-party research reports, periodicals, news articles,
direct company meetings, press releases, industry conferences and any other useful and reliable information sources. The best ideas move
forward to the Analysis stage.
Fundamental Analysis: The Firm’s portfolio managers and research team performs its own analysis of the companies identified as having the most
compelling investment opportunity. The teams validate key quantitative metrics such as earnings growth, cash flows and balance sheet strength and
other key factors such as competitive advantages, market leadership, product development and pricing power. The teams also assesses the
relevant external conditions of the economic and industry sectors related to each company. In addition, the teams also assess the management
of each compa ny. Lastly, for companies which are still compelling to invest in, the decision to invest is debated within each’s own IPC and
compared to the companies already within the relevant investment strategy.
Overview – Fixed Income
Congress Asset’s investment philosophy is to maximize potential return per unit of risk using fundamental and relative valuations that employ a
combination of top down and bottom up techniques to deliver a consistent pattern of relative returns with minimal periods of underperformance.
The Fixed Income Investment Policy Committee is the decision maker for all fixed income activity. The committee is also the central
coordinating body that sets, implements, and supervises our screening process and investment policy. The Fixed Income IPC sets the sector
allocation weights, duration targets, and reviews credit analysis performed by analysts and portfolio managers. The Fixed income IPC contains
at least one member from the IOC.
Top Down analysis: This can include identifying global and domestic trends (i.e., fiscal policy, monetary policy, fund flows, etc.), anticipating
future yield curve shape and position, determining which sectors to overweight and underweight via spread analysis, and identifying undervalued
or overvalued securities.
Bottom Up analysis: A multistep process that can include identifying attractive issuers through proprietary screening tools, identifying mispriced
securities through daily evaluation of broker runs, selecting individual securities for possible investment and processing potential through a
break-even analysis, and comparative analysis of security versus security purchase and sale.
Additional research techniques may be utilized (depending on the asset class being evaluated) and can be summarized as follows:
Quantitative Screening: Each fixed income product has its own universe of securities in which it may invest. The universe is screened and
reduced based primarily on security indicative features which can include, but are not limited to, maturity date, issuance size, credit ratings,
market of issue, and other bond-specific features.
Fundamental Analysis: The Firm’s portfolio managers and research team performs its own analysis of existing and potential issuers using our proprietary
fundamental model. We seek to ensure proper payment of interest and principal by assessing the overall financial health of issuers using a variety of metrics
as well as peer-based analyses.
Investment Strategies
Congress Asset considers themselves investors and not traders. The Firm typically acquires a security with the intent holding it as a long-term
investment. However, circumstances may arise where it is in the best interest of the Firm’s Clients to sell sooner than expected. For example, a
run-up in a securities price to a level higher than our analysis supports may cause us to exit or trim that position. Conversely, an unforeseen
event, either internal or external to the securities issuer, may also cause us to exit or trim the position.
Congress Asset employs various investment strategies based on the objectives and strategies of its Clients. Client portfolios with similar
investment mandates, strategies and guidelines are generally managed similarly. Long term (securities held for at least one year), short term
(securities sold within one year), trading (securities sold within thirty days) and option strategies, including option writing, may all be used if
permitted by the applicable client investment guidelines. The Firm may also borrow securities in connection with short sales, borrow money to
invest in additional portfolio securities or engage in transactions in futures contracts for some Clients. Congress Asset may also provide asset
allocation services to certain Clients, on either a discretionary or non-discretionary basis, with periodic rebalancing.
In employing investment strategies, Congress Asset may use certain strategies in an attempt to “hedge” or “neutralize” various risks associated
with positions in a Client’s portfolio. The instruments used to engage in these hedging strategies include various derivative instruments, such as
options, warrants, interest rate swaps, interest rate caps and other derivative securities. The Firm’s attempts to partially or fully hedge a portfolio
may not be successful and may cause the portfolio to incur a loss.
Upon request and after discussion and agreement with the Client, the Firm will incorporate environmental, social and governance factors into its
fundamental analysis to help identify risks and opportunities and to the extent that they are material to investment performance. In addition, the
Firm will also employ certain socially conscious screens upon specific request and direction from our Clients.
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Risk of Loss
Securities investments are not guaranteed and you may lose money on your investments. Each investment style or strategy will carry with it
different levels of risk. Our investment styles and strategies can be matched with each Client's unique combination of desired returns, investment
objectives, cash flow needs, and personal risk tolerance to determine the most suitable investments.
All investments in securities involve risk. It is possible that a Client’s investment objectives will not be achieved or that a Client will lose all or a
portion of their investments. The risks all investors face include the following:
Market Risk: All securities investments are subject to changes in the market place. At times, movements in the market can be significant, which will
cause the value of an investor’s account to change. For example, in 2008 the markets experienced significant broad-based decreases, due in part to
a wide spread credit crisis and significantly negatively impacted investors’ portfolios.
Investment Selection Risk: Congress Asset’s analysis of an investment may be incorrect and may result in selections of investments that suffer
losses or underperformance relative to other investments.
Credit Risk: The issuer of a fixed-income security could default on its obligation to pay principal and/or interest or its credit rating could be
downgraded, resulting in loss of part or all such security or result in such security becoming illiquid for some period of time.
Interest Rate Risk: As interest rates rise, the value of fixed-income securities is likely to decrease. Securities with longer durations tend to be more
sensitive to changes in interest rates, and are usually more volatile than securities with shorter durations. In a rising interest rate environment a
Client’s fixed income portfolio may lose value.
Client Imposed Investment Restrictions Risk: Clients who place restrictions on Congress Asset from investing in certain industries or specific
companies for social, religious, statutory or other reasons, may result in Congress Asset forgoing investment opportunities which are in the best
economic interest of the Client. Such restrictions may result in performance less favorable than other Client accounts managed by the Firm without
such restrictions. Further, Clients may impose proxy voting requirements which may cause Congress Asset to vote in a manner not in the best
economic interest of its Clients.
Risks for all forms of analysis: 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. Information which the Firm gathers and in-part depends upon to be accurate and unbiased
includes, but is not limited to: corporate annual reports, filings with the Securities and Exchange Commission (SEC), company press releases,
research material reported by others, financial newspapers and magazines, corporate ratings/analytical services, government reports, etc.
Item 9
Disciplinary Information
Congress Asset is required to disclose any legal or disciplinary events that are material to a Client's or prospective Client's evaluation of our advisory
business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10
Other Financial Industry Activities and Affiliations
General
Congress Asset is not affiliated with any broker dealer, custodian, or non-advisory service provider which performs services to the Firm, its
affiliates or its Clients. In addition, Congress Asset does not engage in financial industry activities except for the advisory services performed
and disclosed in this Brochure.
The Firm is affiliated with Congress Wealth Management and Congress Capital Partners, both of which are investment advisers registered with
the SEC and both of which are under common control with the Firm. In addition, certain officers of the Firm are associated with one or both
affiliates with regard to responsibility and ownership. In addition, some employees of Congress Asset are separately licensed as registered
representatives of Quasar Distributors LLC, an unaffiliated limited purpose broker-dealer and a subsidiary of U.S. Bank Corp (“Quasar” and
taken together with Congress Capital Wealth Management and Congress Capital Partners, “Related Persons”)
While Congress Asset and its Related Persons discussed below endeavor at all times to put the interest of the Clients first as part of their
fiduciary duty, Clients should be aware that the receipt of additional compensation directly or indirectly by the Firm or its Related Persons may
create a conflict of interest and may affect the judgment of these Related Persons and their employees when making recommendations.
Where appropriate, Congress Asset and its employees may recommend the various investment and investment-related services of the Related
Companies to our advisory Clients. The Related Companies and their employees may also recommend the advisory services of Congress Asset
to their clients. The services provided by the Related Companies and the related compensation they may receive from Clients are separate and
distinct from the advisory services provided by and fees paid to Congress Asset. No Congress Asset client is obligated to use the services of any
of the Related Companies.
To address these potential conflicts the Firm and its two affiliated investment advisers have taken the following actions:
• Each affiliate shares the same Chief Compliance Officer who has full transparency into each organization;
• Executive management of each affiliate and the Chief Compliance Officer maintain frequent and open communication which facilitates
identification, analysis and remediation of real and perceived conflicts;
• Each affiliate requires its employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of
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interests in such activities are properly addressed;
• Each affiliate periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly
addressed by our firm; and
• Each affiliate educates its employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and
independent basis for the investment advice provided to clients.
Relationship with Congress Wealth Management
Generally, Congress Wealth Management (CRD No. 149446; SEC No. 801-69988) recommends to its clients Congress Asset, as an
investment manager for those strategies disclosed in this Brochure. Congress Wealth Management clients enter into a separate investment
management agreement with Congress Asset (a ‘dual contract’ arrangement) for which Congress Wealth may retain discretion to increase or
decrease assets managed by Congress Asset. For certain legacy clients of Congress Wealth Management, a ‘single contract’ agreement exists
where Congress Asset manages Congress Wealth clients’ assets pursuant to a sub advisory agreement between Congress Wealth
Management and Congress Asset.
Certain senior officers of Congress Wealth Management are also associated with Congress Asset. Paul A. Lonergan, President of Congress
Wealth Management also serves on the Management Committee of Congress Asset.
Certain senior officers of Congress Asset are also associated with Congress Wealth Management. Daniel Lagan, President of Congress Asset
and Christopher Lagan, Managing Director and Chief Operating Officer of Congress Asset are members of Congress Wealth Board of
Directors. In addition, Peter C. Anderson, Senior Vice President and Portfolio Manager for Congress Asset also serves as Chief Investment
Officer of Congress Wealth Management.
The principal owners of Congress Wealth Management are Harborview Partners 2012, LLC (the majority owner) and Lagan Wildwood
Investments LLC. Lagan Wildwood Investments LLC is wholly owned by Lagan Holding Company, Inc.
Relationship with Congress Capital Partners
Congress Capital Partners (CRD No. 170030; SEC No. 801-79030), is a Massachusetts Limited Liability Partnership. Congress Capital
Partners is the advisor for the Risk Managed Series and has appointed Congress Asset as sub adviser to provide day-to-day portfolio
management, trading, portfolio accounting and reporting services to third-party intermediaries.
Certain persons and senior officers of Congress Asset are also associated with Congress Capital Partners. Brent Ciliano is a Senior Vice
President of Congress Asset and serves as Chief Investment Officer of Congress Capital Partners. Paul Lonergan serves on the Congress
Asset Management Committee and serves as President of Congress Capital Partners.
Congress Capital Partners is primarily owned by Congress Capital, LLC. Congress Capital, LLC is controlled by Lagan Wildwood II and
Harborview II MMXII. Lagan Wildwood II is wholly owned by Lagan Holding Company Inc.
Relationship with Unaffiliated Broker-Dealer
Some employees of Congress Asset are separately licensed as registered representatives of Quasar Distributors LLC, an unaffiliated limited
purpose broker-dealer and a wholly owned subsidiary of U.S. Bank Corp. Quasar serves as the principal underwriter to the Congress Funds.
Dual employees of the Firm and Quasar, in their separate capacity as distributors, can effect securities transactions to purchase or sell the
Congress Funds.
Congress Funds
Congress Asset is the investment adviser to the Congress Funds, registered mutual funds trusteed at US Bancorp and distributed by Quasar.
From time to time, Congress Asset and/or its affiliates may recommend that clients buy or sell shares of the Congress Funds. In cases where
Congress Asset recommends its Clients invest through the Congress Funds, the Firm will waive its advisory fee on the assets invested in the
Congress Funds. The Congress Funds’ Prospectus and Statement of Additional Information are available on-line at:
www.congressasset.com/funds.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Congress Asset has adopted a Code of Ethics, pursuant to Rule 204A-1 of the Investment Advisers Act of 1940. The Code of Ethics sets forth
high ethical standards of business conduct, including compliance with applicable federal securities laws.
Congress Asset’s personnel owe a duty of loyalty, fairness and good faith towards its Clients, and have an obligation to adhere not only to the
specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics.
The Firm’s Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual
securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior
approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for
oversight, enforcement and recordkeeping provisions.
Congress Asset's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While the Firm does not
believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a
10
personal or professional capacity.
Congress Asset may recommend that clients buy or sell securities or investment products in which Congress Asset, its officers and its employees
have a financial interest. Conversely, officers and employees may buy and sell for themselves securities which Clients hold. To safe guard against
conflicts with the Firm’s Clients, each employee and his or her immediate family members, as well as designated interns and contractors, are
required to pre-clear all ‘covered securities’ trades, as defined in the Code of Ethics, for his or her own account. Covered securities pursuant to the
Code of Ethics also includes shares of the Congress Funds. Each pre-clearance request is reviewed by an investment professional designated by
the Chief Compliance Officer to ensure trading by officers and employees for their personal accounts is not prior to or contemporaneous with
transactions effected by the Firm on behalf of its Clients.
The Firm’s Code of Ethics also requires each employee to disclose each outside business activity they may have and to pre-clear with the
Firm’s management and its Chief Compliance Officer each prospective outside business activity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to
info@congressasset.com, or by calling us at 617-737-1566.
Item 12
Brokerage Practices
General
The Firm has the responsibility to effect orders correctly, promptly and in the best interests of its Clients. Congress Asset has the duty to treat
all its Clients fairly, ensuring that over time no Client is advantaged or disadvantaged compared to other Clients. In the event a trade error
occurs in the handling of any Client transactions due to the Firm's actions, or inaction, or actions of others, Congress Asset will seek to identify
and correct any errors as promptly as possible without disadvantaging the Client or benefiting the Firm.
Congress Asset recognizes that brokerage is the property of the Clients, and as such, is to be allocated to broker-dealers in a manner that serves
the interests of its Clients. It also recognizes an ongoing duty to seek to obtain best execution. While the firm endeavors to obtain the best
combination of price and execution for its Clients, “best execution” does not necessarily mean it will pay the lowest commission or spread.
The firm also seeks competitively priced brokerage services where the broker-dealer can provide value-added, company-specific, and thematic
industry research, including meetings with management and conferences. Additional factors in selecting a broker-dealer include, but are not limited
to: quality of investment research; liquidity of the market in a security; financial stability of the broker-dealer; promptness of execution; quality of
settlement; the broker’s ability to handle a desired block; and efficiency in clearing and settling trades.
Research and Soft Dollars
Congress Asset may use brokers who provide useful research and securities transaction services even though a lower commission may be
charged by a broker who offers no research services and minimal securities transaction assistance. Some research services may be useful in
servicing all our Clients while some research may be useful for only certain Client accounts.
Congress Assets investment professionals periodically review the quality of research provided by brokers. The review is coordinated by the
Director of Research and results in a ‘research vote’ which is presented to the Firm’s Best Execution Committee for review. Consideration for
retaining or replacing brokers occurs at this meeting.
Consistent with obtaining best execution for Clients, Congress Asset may direct brokerage transactions for Clients' portfolios to brokers who
provide third-party research and execution services to Congress Asset and, indirectly, to Congress Asset's Clients. These services, which are
eligible pursuant to Section 28(e) of the Securities Exchange Act of 1934, are designed to augment the Firm’s internal research and investment
strategy capabilities. The Firm believes that the acquisition of such research through soft dollars is in the long-term benefit to all its Clients.
Congress Asset recognizes that when using Client brokerage commissions to obtain research or brokerage services, it receives a benefit to the
extent that Congress Asset does not have to produce such products internally or compensate third-parties with its own money for the delivery of
such services. Therefore, such use of Client brokerage commissions results in a conflict of interest, because Congress Asset has an incentive to
direct Client brokerage to those brokers who provide research and services, even if such brokers do not offer the best price or commission rates
for our Clients. Further, broker-dealers selected may be paid commissions for effecting transactions for our Clients that exceed the amounts other
broker-dealers would have charged for effecting the same transactions. However, Congress Asset endeavors to determine in good faith that such
amounts are reasonable in relation to the value of the brokerage and/or research services provided by those broker-dealers.
Certain items obtainable with soft dollars may not be used exclusively for either execution or research services. In such cases, the cost of such
"mixed-use" products or services will be fairly allocated and Congress Asset makes a good faith effort to determine the percentage of such
products or services which may be considered as investment research. The portions of the costs attributable to non-research usage of such
products or services are paid by the Firm to the broker-dealer in accordance with the provisions of Section 28(e) of the Securities Exchange Act of
1934.
Congress Asset uses products and services including investment recommendations, investment research, and financial publications providing
corporate financial data, financial statistical data, economic data and forecasts, and systems for arranging and assimilating data. Third party
research includes the following products and services:
Bloomberg’s Bloomberg Research
S&P Capital IQ
Value Line Publishing
Congress Asset’s Soft Dollar Committee conducts periodic soft-dollar reviews, analyzing price and commissions offered by the various brokers
used and volume of Client commissions directed to each broker. Moreover, we perform a qualitative ranking of all brokers used by polling our
trading staff, research analysts, and portfolio managers.
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Order Allocation Trade Aggregation
When decisions are made to buy or sell the same security simultaneously for a number of accounts, Congress Asset may aggregate the purchase or
sale into a single trade order (a “bundled” trade) if it deems this to be appropriate and in the best interests of the accounts involved. Bundle trading
may allow us to execute trades in a timely, and equitable manner, at the same average share price or spread for each Client account. Congress Asset
will typically aggregate trades among Clients whose accounts can be traded at a given broker.
Congress Asset's policy prohibits any allocation of trades in a manner that favors one type of Client account over another. In addition to
executing bundled trades, as described above, Congress Asset will also rotate the trading order of its discretionary and directed groupings, in
cases where a portfolio model change is required. As a model change in a given investment strategy impacts all Clients in that investment
strategy, the Firm feels it necessary to rotate the order of Client groupings to ensure equitable trading over time. Generally, unified management
accounts (“UMA”), are excluded from the trade rotation and are traded following completion of the rotation.
Directed Brokerage
Some Clients designate a particular broker or dealer through which trades are to be made (“directed trades”). In addition, wrap-fee arrangements
generally require Congress Asset to direct all brokerage transactions to the sponsoring broker-dealer. Where a Client directs trades, Congress Asset
may not able to negotiate commission rates or spreads and is not able to obtain the same execution it receives for other Clients. This means that
directed-trade Clients may receive worse prices than Clients who delegate trading responsibility to Congress Asset. Additionally, Clients who direct
trades to a particular broker or dealer often pay higher commissions, greater spreads, or receive less favorable net prices than they would if
Congress Asset were able to select brokers or dealers.
Brokerage for Client Referrals
Brokers that the Firm selects to execute transactions may from time to time may refer Clients to our firm. Congress Asset will not make
commitments to any broker or dealer to compensate that broker or dealer through brokerage or dealer transactions for Client referrals; however, a
potential conflict of interest may arise between the Client's interest in obtaining best price and execution and Congress Asset's interest in receiving
future referrals.
Item 13
Review of Accounts
General
Congress Asset portfolio managers continually review Client account to ensure they are managed to meet the Clients goals, risk tolerances, liquidity
needs and other stated objectives. The Firm endeavors to meet with each Client and/or their appointed agent annually, or when circumstances
warrant, to review changes in their profile, discuss past performance, share forward looking views as they are relevant and provide
recommendations. In the interim, Clients and/or their appointed agents are provided quarterly portfolio account appraisals for their review and
comparison to other statements they may receive from broker dealers, custodians, trust companies, etc.
Review of Separately Managed Accounts (“SMA”)
`
Underlying securities of each Client SMA are continually monitored. Formal account reviews are held at least semi-annually by the Account Review
Committee. Additional account reviews may be held due to market events, disruptions or trends. Client accounts are reviewed in the context of
Congress Asset’s model portfolios, approved lists, cash holding and each Client's stated investment objectives and guidelines.
Account Review Committee meetings are attended by members of the Investment Oversight Committee, Operations and members from each investment
strategy’s Investment Policy Committee.
Review of Wrap Accounts
Underlying securities in SMA and UMA Wrap Accounts are continually monitored. Formal account reviews are held at least semi-annually by the
Wrap Account Review Committee. Additional account reviews may be held due to market events, disruptions or trends. Client accounts are reviewed
in the context of Congress Asset’s model portfolios, approved lists, cash holding and each Client's stated investment objectives and guidelines. Service
levels of Wrap Account sponsors and trading platforms are also reviewed.
Wrap Account Review Committee meetings are attended by a member of the Investment Oversight Committee, Operations and members from each
investment strategy’s Investment Policy Committee.
Review of Mutual Funds
Congress Asset continually reviews and monitors each mutual fund for which it is the advisor or sub-advisor, in accordance with the Investment
Company Act, the policies and procedures adopted by each mutual fund’s board of directors/trustees and investment objectives set forth in the
each mutual fund’s Prospectus. The Firm reviews each fund with its board as well as the business of the Firm annually, as required under Section
15c of the Investment Company Act.
12
Item 14
Client Referrals and Other Compensation
General
Congress Asset may pay referral fees to independent persons or firms ("Solicitors") for introducing Clients to us. Whenever we pay a referral fee,
we require the Solicitor to provide the prospective Client with a copy of this document (our Firm Brochure) and a separate disclosure statement that
includes the following information:
• The Solicitor's name, Congress Asset’s name and the relationship with our firm;
• The fact that the Solicitor is being paid a referral fee by Congress Asset;
• The terms of the fee paid or to be paid by Congress Asset; and
• Whether the fee paid to Congress Asset by the Client will be increased above Congress Asset’s normal fees in order to compensate the Solicitor.
As a matter of firm practice, the advisory fees paid to us by Clients referred by Solicitors are not increased.
Solicitation Arrangements
Congress Asset had a strategic partnership with ARK Global LLC (“ARK”), a licensed broker-dealer, for ARK to provide sales services for fixed
income products to Congress Asset. This agreement expired in 2011, however Congress pays ARK a percentage of the management fees
generated from any fixed income assets the ARK representatives raised for Congress Asset.
Other Compensation
Congress Asset is advisor to the Congress Mutual Funds and compensates certain broker-dealers for sale of the Congress Mutual Funds to
Clients who purchase the retail classes of the Fund's shares.
Item 15
Custody
Congress Asset has certain Client relationships where it is deemed to have custody pursuant to Rule 206(4)-2 of the Investment Advisers Act of
1940, as amended. For all such Client accounts, (i) Congress Asset will obtain an annual surprise examination from an independent auditor of
accounts for which Congress Asset is deemed to have custody; (ii) Client assets are held at qualified custodian(s) of the Client’s choosing, who
shall provide custody account statements directly to each Client, at least quarterly; (iii) Congress Asset will provide to each Client an account
statements at least quarterly, enabling Clients to compare such information to their custody statements
Clients are urged to compare the account statements received directly from their custodians to the performance report statements provided by the
Advisor.
Item 16
Investment Discretion
Clients may hire Congress Asset to provide discretionary asset management services, in which case we place trades in a Client's account without
contacting the Client prior to each trade to obtain the Client's permission. Our discretionary authority includes the ability to determine the security
to buy or sell, and/or determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign an investment management agreement (“IMA”) with our firm. Within the IMA or by separate
written instructions, Clients may limit discretionary authority and/or place upon the Firm reasonable investment restrictions. Clients may also
change or amend such limitations by once again providing us with written instructions.
Item 17
Voting Client Securities
Congress Asset votes proxies for certain Client accounts when such authority is granted. Any Client may choose to vote proxies on their own
account.
Congress Asset will vote proxies in the best economic interests of its Clients and in accordance with our established policies and procedures. In
the case of ERISA Clients, Congress Asset accepts its fiduciary responsibility to vote proxies in the best interest of plan participants and their
beneficiaries.
Congress Asset will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a
record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each
written Client request for information on how the adviser voted proxies. Congress Asset also uses a third party research firm to assist in the decision
making process for proxy voting.
13
With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies.
Clients may instruct us to vote proxies according to particular criteria (for example, to always vote with management, or to vote for or against a
proposal to allow a so-called "poison pill" defense against a possible takeover). These requests must be made to Congress Asset in writing. Clients
may also instruct us on how to cast their vote in a particular proxy contest by email to info@congressasset.com, or in writing to Congress Asset, 2
Seaport Lane, 5th Floor, Boston, MA 02210.
Clients and prospective Clients should be aware that Congress Asset Management typically follows the recommendation of the AFL-CIO when voting
proxies for Taft-Hartley Clients, while at the same time is actively soliciting new business from the Taft-Hartley market. Voting to such
recommendations may at times be different from how we vote our other Clients’ proxies and in opposition to the interests of such other Clients.
From time to time conflicts may arise with regard to how Congress Asset should vote or abstain a particular proxy vote. Generally, in such cases the
Chair of the Congress Asset Proxy Committee and the Chief Compliance Officer will be notified. If a true conflict is identified, a meeting of the Proxy
Committee will be called to order to review the conflict and determine how the proxy will be voted.
We will neither advise nor act on behalf of the Client in legal proceedings involving companies whose securities are held in the Client’s account(s),
including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, Clients may direct us to transmit copies of class
action notices to the Client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely
manner.
Clients may obtain a copy of our complete proxy voting policies and procedures by contacting Congress Asset by telephone at 617-737-1566, by
email to info@congressasset.com, or in writing to Congress Asset 2 Seaport Lane, 5th Floor, Boston, MA 02210. Clients may request, in writing,
information on how proxies for his/her shares were voted.
Item 18
Financial Information
As Congress Capital does not require or solicit payment of fees in excess of $1,200 per Client more than six months in advance of services
rendered it is not required to include a financial statement with this Brochure.
Congress Asset is well capitalized with sufficient financial resources to fund continuing operations, growth, and meet all obligations to its Clients.
Further, Congress Asset has not been the subject of a bankruptcy petition at any time during the past ten years.
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2015 PRIVACY & PROXY NOTICE
PRIVACY POLICIES AND PROCEDURES
The trust and confidence of our customers is important to Congress Asset Management Company. For this reason, we are
careful in the way we collect and handle non-public, personal information about our clients (“Client Information”). This
Privacy Notice describes our policies and practices regarding Client Information and how it is obtained, disseminated, and
protected.
Information We Collect
We may collect Client Information from the following sources:
•
Information we receive on contracts or other forms, such as name, address, date of birth, and social security
number
•
Information relating to transactions with us, our affiliates and others, such as the purchase and sale of securities
and account balances
•
Information we receive from third parties, such as custodians, wealth management and financial services firms, as
required or permitted by law
Information We Disclose
We disclose Client Information about our present or former Clients to third parties only to the extent required or permitted by
law. Such sharing of Client Information is applied to:
•
Everyday business purposes such as processing transactions, maintaining and or servicing your account
•
Cooperating with regulatory authorities, responding to court orders and legal investigations
•
Taking reasonable and necessary steps to prevent fraud, unauthorized transactions, etc.
Opting Out
Our current business practices require us to obtain written permission from you before we may disclose any Client
Information in a way outside of what is discussed above. In addition, in the event we wish to share Client Information which
requires us to obtain an “opt-out” (or, an “opt-in”) notice from you, we will do so prior to sharing such information.
Information Security
•
We continue to evaluate our efforts to protect confidential Client information and to keep our privacy policy and
practices current
•
We restrict access to Client Information to employees and service providers who are involved in providing products
and services to our clients
•
Employees with access to Client information may not use or disclose such information, except for Congress Asset
Management business use
•
We maintain physical, electronic, and procedural safeguards in order to protect Client Information.
•
When there is a need to dispose of confidential Client information, we require our employees to shred, not discard
the information
If you have any questions regarding our Privacy Policy, call us at 800-542-7888 or write to us at 2 Seaport Lane, Boston, MA
02210.
PROXY POLICIES AND PROCEDURES
PROXY POLICIES
Responsibility
Congress Asset Management Company’s responsibility as an investment manager and plan fiduciary, as outlined in rule
206(4)-6 under the Investment Advisers Act of 1940, and the Employee Retirement Income Security Act of 1974 and
subsequent Department of Labor policy statements, includes the duty to vote proxies on behalf of our clients when proxy
voting authority has been delegated to us. Congress Asset Management Company accepts its fiduciary responsibility to vote
proxies under these circumstances. This statement is intended to set forth those policies and guidelines to be followed in
1
carrying out our responsibility.
General Principles of Voting
Proxy voting rights have been declared by the Department of Labor to be valuable plan assets and therefore must be
exercised in accordance with the fiduciary duties of loyalty and prudence. This policy statement has been carefully crafted to
meet the requirements of loyalty and prudence and will be employed by the Proxy Committee in its proxy voting procedures
and decisions.
The duty of loyalty requires that a voting fiduciary exercise its proxy voting authority solely in the interests of its clients, or
plan participants and beneficiaries and for the exclusive purpose of providing plan benefits to participants and beneficiaries.
The voting fiduciary is prohibited from subordinating the interests of participants and beneficiaries to unrelated objectives.
The duty of prudence requires that proxy voting authority be exercised with the care, skill, prudence, and diligence that a
similarly situated prudent person knowledgeable in such matters would exercise. Thus, in making proxy voting decisions,
issues based on the merits of each. Congress Asset Management Company shall seek out information from a variety of
sources to determine what is in the long term economic best interest of its clients, plan participants, and beneficiaries prior to
making a proxy voting decision.
In keeping with its fiduciary responsibilities, Congress Asset Management Company will vote proxies in accordance with the
“economic best interests” of its clients, plan participants and beneficiaries. Congress Asset Management Company will
consider the long-term impact of business plans on all affected parties including shareholders, debt holders, employees,
retired workers, and communities in which the firm operates.
Decisions Free of Outside Influence
Generally, Congress Asset Management Company will vote on the recommendation of the issuers management, however,
Congress shall take into consideration the general positions of trustees and other fiduciaries in deciding how to vote proxies.
Congress Asset Management Company currently utilizes the services of Broadridge Investor Communications, an
independent provider of proxy voting services. Such services may include voting execution, comprehensive reporting, and
supporting justification. However, any influence imposed upon us by a person or persons who have a direct personal or
financial interest in the outcome will be rejected as a violation of ERISA and our moral obligation to plan participants, and
clients. On contested issues the guiding principle shall be the long term “economic best interests” of all affected parties.
The interest of any one group shall not dominate the decision to the detriment of other affected parties.
Clients and prospective clients should be aware that Congress Asset Management typically follows the recommendation of
the AFL-CIO when voting proxies for Taft-Hartley clients, while at the same time is actively soliciting new business from the
Taft-Hartley market. Voting to such recommendations may at times be different from how we vote our other clients’ proxies
and in opposition to the interests of such other clients.
PROXY PROCEDURES
Proxy Committee
The Proxy committee shall have responsibility for setting the proxy voting policy at Congress Asset Management Company.
Proxies will be voted in the economic best interest of each individual client, ERISA plan participant, and beneficiaries. The
Proxy Committee will use all available resources to help in evaluating proxy issues, and setting policies that are appropriate
for each client. Congress Asset Management Company has an agreement with Broadridge Investor Communications to
provide integrated third party research and electronic, automated, rules based voting capabilities via the Broadridge
ProxyEdge service for each individual proxy.
In the event of a vote that falls outside of the standard proxy voting rules for Congress Asset Management, the Proxy
Committee will meet to review a specific vote. When the Proxy Committee reaches a decision concerning the proxy vote in
question, Broadridge ProxyEdge shall be instructed to vote accordingly and no further action shall be required. A simple
majority of the Proxy Committee shall be required for a final ruling on proxy issues.
Record Keeping
1)
Proxy Committee minutes and meeting material including the basis for any voting decision including whether the
advice of any individual outside of the organization was acted upon.
2)
Records will be maintained detailing how proxies were voted and for which accounts they were voted.
Records of proxy voting will be made available to Clients and ERISA Plan Sponsors upon a written request by email to
proxies@congressasset.com or by mail to Congress Asset Management, 2 Seaport Lane, 5th Floor, Boston, MA 02210.
PROXY COMMITTEE:
Daniel A. Lagan
Gregg A. O’Keefe
Dory Bowers
2
Part 2B of Form ADV: Brochure Supplement
Congress Asset Management Company, LLP
2 Seaport Lane
5th Floor
Boston, MA 02210
617-737-1566
03/31/2012
This brochure supplement provides information about the investment professionals employed by
Congress Asset Management Company, LLP that supplements the Congress Asset Management
Company, LLP brochure. You should have received a copy of that brochure. Please contact Daniel A.
Lagan if you did not receive the Congress Asset Management Company, LLP brochure or if you have any
questions about the contents of this supplement.
Additional information about the investment professionals employed by Congress Asset Management
Company, LLP are available on the Securities and Exchange Commission’s website at
www.adviserinfo.sec.gov
Alfred Alphonsus Lagan
Born: 1935
Education
• New York University Graduate School; M.B.A., Investments; 1964
• Iona College; B.A., Economics; 1956
Mr. Lagan received his Bachelor of Arts degree in Economics with a minor in Philosophy from Iona College in 1956.
While working at Bankers Trust he attended the New York University Graduate School of Business Administration where
his studies focused on investments and international business. In 1964, he received his Master of Business
Administration degree with distinction.
Business Experience
• Congress Asset Management; Chairman; from 07/1999 to Present
• Congress Asset Management; President; from 01/1985 to 06/1999
• Putnam Advisory Company; Senior Vice President; from 01/1974 to 12/1984
• Bowery Savings Bank; Senior Vice President; from 02/1968 to 12/1973
• Congress Trust National Association; Vice Chairman; from 12/2006 to 11/2009
• Congress Trust National Association; Chairman; from 12/1997 to 12/2006
• Congress Trust National Association; President; from 12/1997 to 02/2002
• Congress Wealth Management; Director; from 04/2009 to Present
Mr. Lagan is the founder of Congress Asset Management Company, LLP. After four years service in the U. S. Navy, he
joined Bankers Trust Company in New York as an Investment Associate in the Trust Department. In 1964 he joined
Burnham & Co. (predecessor firm to Drexel Burnham Lambert) as an Investment Associate. In this role, he reported to
the senior partners of the firm, researched potential investments for them, assisted in management of client portfolios, and
communicated with clients. He also assisted in the management of 2 offshore funds, Worldwide Fund NV and Worldwide
Fund Ltd., which were set up to manage investments of foreign clients. In1972, he joined the Bowery Savings Bank as
Vice President Investments where he managed the bank's stock portfolio, reporting to the Executive Vice President and
the Investment Committee of the Board. He was promoted to Senior Vice President in 1973. In 1974 he joined Putnam
Capital Management as Senior Vice President and Director specializing in the investment management of smaller
corporate pension funds under management. In1984, he left Putnam and founded Congress Asset Management. He
remains the Chairman of Congress Asset Management and is Chairman of the Board of Congress Wealth Management,
LLC.
Alfred Alphonsus Lagan earned the following designation(s) and is in good standing with the granting authority:
• CFA; CFA Institute; 1972
The CFA designation is an international professional certification offered by the CFA Institute to financial analysts who
completed a series of three examinations, possessed a bachelor's degree from an accredited institution (or had an
equivalent education or work experience), and at that time had 36 months of qualified professional work experience. CFA
charter holders are obligated to adhere to a strict Code of Ethics and Standards governing professional conduct.
Mr. Lagan is Chairman of the Board of Congress Wealth Management, LLC. Alfred Alphonsus Lagan does not
receive commissions, bonuses or other compensation on the sale of securities or other investment products. He
is not engaged in any other business or occupation that provides substantial compensation or involves a
substantial amount of his time. Alfred Alphonsus Lagan does not receive any economic benefit from a nonadvisory client for the provision of advisory services.
Alfred Alphonsus Lagan has no reportable disciplinary history. He is Chairman of the Board of Congress Asset
Management Company, LLP and is subject to the Company's Code of Ethics and the Company's written
Compliance Program.
Supervisor: N/A
Title: N/A
Phone Number: 617-737-1566
Daniel A. Lagan
Born: 1964
Education
• Boston College; M.B.A., Finance; 1993
• St. Michael's College; B.A., Accounting; 1987
The curriculum for the Accounting degree from St. Michael's College requires students complete general humanities,
business classes, and a number of classes focusing on accounting, tax, and audit issues. Students must maintain a
minimum GPA of 2.0 while earning at least 124 credit hours. Mr. Lagan received the degree of Master's of Business
Administration with a specialization in Finance from Boston College in 1993. The core curriculum in the Evening MBA
Program provides a strong foundation in managerial, analytical, and practical management skills. Students participate in
the Business Development Workshop aimed at building their analytical, presentation, and teamwork skills while
performing new venture planning exercises. Evening Program study is capped by two integrative courses which look at
competitive strategy and social issues from a management perspective. Evening students must complete 56 credits of
coursework. Students choose from a wide range of electives to earn 18 credits allowing them to pursue individual
interests and enhance their functional expertise.
Business Experience
• Congress Asset Management; President; from 07/1999 to Present
• Congress Asset Management; Executive Vice President; from 08/1989 to 06/1999
• Price Waterhouse; Auditor; from 09/1987 to 04/1989
• Congress Trust National Association; Executive Vice President & Trust Officer; from 02/1999 to 11/2009
Mr. Lagan has been employed by Congress Asset Management since 1989. He currently serves as President and Chief
Investment Officer. He has been President since June, 1997. In this role, he is responsible for all business aspects of the
company with senior managers of operations, sales, and investments reporting to him. Mr. Lagan served as Co-Chief
Investment Officer from January, 2005 to September, 2007. In this role, he was directly responsible for the large cap
growth product and was chair of the Investment Oversight committee. He also works with the heads of each investment
strategy including fixed income, mid cap, and all cap opportunity. Prior to joining Congress Asset Management, Mr.
Lagan was a staff auditor for Price Waterhouse from August, 1987 to April, 1989.
Daniel A. Lagan earned the following designation(s) and is in good standing with the granting authority:
completed a series of three examinations, possessed a bachelor's degree from an accredited institution ( or had an
equivalent education or work experience ), and at that time had 36 months of qualified professional work experience.
CFA charter holders are obligated to adhere to a strict Code of Ethics and Standards governing professional conduct.
Mr. Lagan is a member of the Board of Directors of Congress Wealth Management, LLC. Daniel A. Lagan does
not receive commissions, bonuses or other compensation on the sale of securities or other investment products.
He is not engaged in any other business or occupation that provides substantial compensation or involves a
substantial amount of his time. Daniel A. Lagan does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
Daniel A. Lagan has no reportable disciplinary history and all trades are reviewed daily by a member of the Management
Committee. The review is performed using a monthly rotation of four individuals who are members of the Management
Committee including Lawrence A. Ward, the firm's Chief Compliance Officer. Each of the individuals receives minutes of
all Investment Policy Committee actions and list of approved securities. All accounts are reviewed formally on a quarterly
basis to assure conformance to investment policy and client guidelines.
Supervisor: Alfred A. Lagan
Title: Chairman
Christopher Michael Lagan
Born: 1970
Education
• Boston University; M.B.A., Management; 1999
• St. Michael's College; B.S., Business; 1992
Mr. Lagan received a Bachelor of Science degree in Business Administration from Saint Michael's College, Colchester,
Vermont, in 1992. In January, 1999 he received a Master's of Business Administration from Boston University's Graduate
School of Management.
Business Experience
• Congress Asset Management; Senior Vice President; from 02/1999 to Present
• Congress Asset Management; Research Analyst; from 02/1997 to 02/1999
• Rentex Inc; Purchasing Agent; from 07/1992 to 07/1993
• Congress Trust National Association; Vice President and Trust Officer; from 02/1999 to 12/2005
Mr. Lagan has worked for Congress Asset Management since 1993. Since 2002 he has been a Principal and member of
the Management Committee that formulates firm-wide strategic planning to advance the company's mission and
objectives. Mr. Lagan is chair of the Private Equity Committee. In this role, he oversees sourcing, due diligence, and
commitments to over $1 billion in private equity allocations for several of Congress' institutional clients. Mr. Lagan serves
as an advisory board member for several private equity funds including Westport Senior Living Fund, L.P., Paladin Capital
Partners Fund, Paladin Homeland Security Fund, and GESD Investors. He also serves as a member of the Board of
Directors of Congress Wealth Management, LLC. From 1998 to 2001 he was a Research Analyst where he evaluated
companies being considered for investment; performed financial analysis using discounted cash flow and other valuation
methods; researched companies being considered for purchase, and made buy and sell recommendations to portfolio
managers. Prior to 1998 he was the Operations Manager of Congress Asset Management. From 1992 - 1993, Mr. Lagan
was a Purchasing Agent for Rentex Incorporated in Boston.
Christopher Michael Lagan earned the following designation(s) and is in good standing with the granting authority:
completed a series of three examinations, possessed a bachelor's degree from an accredited institution (or had an
equivalent education or work experience), and at that time had 36 months of qualified professional work experience. CFA
charter holders are obligated to adhere to a strict Code of Ethics and Standards governing professional conduct.
Mr. Lagan is a member of the Board of Directors of Congress Wealth Management, LLC. Christopher Michael
Lagan does not receive commissions, bonuses or other compensation on the sale of securities or other
investment products. Christopher Michael Lagan is not engaged in any other business or occupation that
provides substantial compensation or involves a substantial amount of his time. Christopher Michael Lagan does
not receive any economic benefit from a non-advisory client for the provision of advisory services.
Christopher Michael Lagan has no reportable disciplinary history and all trades are reviewed daily by a member of
the Management Committee. The review is performed using a monthly rotation of four individuals who are
members of the Management Committee including Dan Lagan. Each of the individuals receives minutes of all
Investment Policy Committee actions and list of approved securities. Dan Lagan is Chief Investment Officer and
also chairs the Investment Oversight Committee. All accounts are reviewed formally on a quarterly basis to
assure conformance to investment policy and client guidelines.
Supervisor: Daniel Lagan
Title: President
Matthew Terence Lagan
Born: 1973
Education
• University College Dublin; M.B.A., Business; 2003
• Bridgewater State College; B.S., Aviation Science; 1995
The core curriculum of the B.S., Aviation Science features a skills-centered, outcomes based distribution model of general
education that allows students a wide choice of courses and the flexibility to integrate the requirements of their major with
broader, liberal arts education that is required of responsible citizens of the 21st Century. The Department of Aviation
Sciences offers a B.S. degree with concentrations in flight training and aviation management. Mr. Lagan received a
Master's of Business Administration from the University of Dublin in 2003. The program is designed to give students a
deep insight into how to run a business as a general manager. Students earn a comprehensive business education while
gaining practical experience in finance, strategy, marketing, accounting, economics, human resources, leadership,
communications, and information technology.
Business Experience
• Congress Asset Management Company; Senior Research Analyst; from 01/2003 to Present
• Giantllop Network; Recruiter; from 08/2000 to 08/2001
• NetGenesis; Recruiter; from 09/1999 to 08/2000
• Ambit Technology; Recruiter; from 02/1997 to 07/1999
Since January 2003, Mr. Lagan has been employed by Congress Asset Management with primary responsibilities
including Equity Analysis and Portfolio Management. As an equity analyst, he provides research coverage within the
financialand energy sectors. His duties include presentations to the investment policy committees, making buy/sell
recommendations, and participation on conference calls and in client meetings. Prior to joining Congress Asset
Management, Mr. Lagan worked as an independent contractor for various start up companies providing technical
recruiting services. From 1997 to 1999, he was a technical recruiter with Ambit Technology responsible for finding
employment for technical professionals throughout New England. From 1995 to 1997, he was a marketing assistant at
ADESA Auctions responsible for expanding dealer relationships with the auction while ensuring a smooth operating
environment for dealers buying and selling at the auction.
Matthew Terence Lagan earned the following designation(s) and is in good standing with the granting authority:
Matthew Terence Lagan does not receive commissions, bonuses or other compensation on the sale of securities
or other investment products. He is not engaged in any other business or occupation that provides substantial
compensation or involves a substantial amount of his time. He does not receive any economic benefit from a
non-advisory client for the provision of advisory services.
Matthew Terence Lagan has no reportable disciplinary history and all trades are reviewed daily by a member of
the Management Committee. The review is performed using a monthly rotation of four individuals who are
members of the Management Committee including Dan Lagan. Each of the individuals receives minutes of all
Investment Policy Committee actions and list of approved securities. Dan Lagan is Chief Investment Officer and
also chairs the Investment Oversight Committee. All accounts are reviewed formally on a quarterly basis to
assure conformance to investment policy and client guidelines.
Title: President
Peter C. Andersen
Born: 1954
Education
• Harvard University; M.P.A., Finance & Investments; 1993
• Yale University; M.S., Physics; 1978
• Northeastern University; B.S., Physics & Math; 1976
Mr. Andersen received a B.S. in Physics & Math from Northeastern University in 1976. This four year program addressed
traditional studies of physics and math, but provided a concentration in theoretical physics. Course work focused more on
mathematical physics, quantum field theory, and multidimensional calculus. He earned his masters degree in physics
from Yale in 1978 where he was awarded the Skinner Fellowship. Coursework included rigorous graduate physics
classes including mathematical physics, quantum field theory, and general relativity. He earned his MPA from Harvard
University in 1993. The MPA program was a one year program that enabled him to flexibly choose the curriculum and
courses at Harvard Business School, Harvard Law School, and MIT's Sloan School of Management.
Business Experience
• Congress Asset Management; Senior Vice President; from 07/2008 to Present
• Dreman Value Management; Director; from 10/2006 to 07/2008
• Congress Asset Management; Senior Vice President; from 10/2003 to 10/2006
• Delaware Investments; Senior Vice President; from 09/2000 to 12/2002
• Conseco Capital Management; Senior Vice President; from 09/1996 to 09/2000
Mr. Andersen currently manages portfolios for institutions and individuals. He first started working with Congress Asset
Management, LLP from October 2003 to October 2006 as a portfolio manager and returned to the firm in a similar role in
July 2008. In his role as portfolio manager, he analyzes company's financial statements and conducts fundamental
research on stocks using data and spreadsheets to form an opinion on the company's financial condition. He also chairs
the All Cap Opportunity Investment Policy Committee. During is time with Dreman Value Management, he performed
security research with a focus on high yield bond portfolio management. Prior to Congress Asset Management, LLP, he
worked at Delaware Investments where he was a portfolio manager of high yield bond portfolios consisting of both private
and public company's debt instruments. He supervised 10 analysts and 2 bond traders. Prior to Delaware Investments,
he worked for Conseco Capital Management as a high yield portfolio manager.
Peter C. Andersen earned the following designation(s) and is in good standing with the granting authority:
Peter C. Andersen is employed by Congress Wealth Management as a Senior Chief Investment Officer. In this
role he is responsible for managing both equity and fixed income accounts for Congress Wealth Management
which is a client of Congress Asset Management who acts as a sub-advisor. He does not receive commissions,
bonuses or other compensation on the sale of securities or other investment products. He is not engaged in any
other business or occupation that provides substantial compensation or involves a substantial amount of his time.
He does not receive any economic benefit from a non-advisory client for the provision of advisory services.
Peter C. Andersen has no reportable disciplinary history and all trades are reviewed daily by a member of the
Management Committee. The review is performed using a monthly rotation of four individuals who are members of the
Management Committee including Dan Lagan. Each of the individuals receives minutes of all Investment Policy
Committee actions and list of approved securities. Dan Lagan is Chief Investment Officer and also chairs the Investment
Oversight Committee. All accounts are reviewed formally on a quarterly basis to assure conformance to investment policy
and client guidelines.
Title: President
Dorene L. Anderson
Born: 1971
Education
• Suffolk University Graduate School; M.B.A., Finance & Economics; 2001
• Roger Williams University; B.A., Psychology; 1993
Ms. Anderson earned her bachelors degree from Roger Williams University in 1993 with a concentration in Psychology
and a minor in Business Administration. Students of Roger Williams University must satisfy the university's core
curriculum including electives. During her time there she was a member of the National Honor Society, Psi Chi during her
junior and senior years. She earned her MBA from Suffolk University in 2001 focusing on finance and economics. The
Suffolk Executive MBA provides a team oriented approach to learning that focuses on management, leadership,
government policy, and global business. Case studies, lectures, and hands on management simulations are used to
develop a well rounded professional. All students must complete a capstone research project tailored to their work
environment and career goals before graduation.
Business Experience
• Congress Asset Management; Vice President; from 10/2007 to Present
• Frontier Capital Management; Vice President; from 03/1998 to 10/2007
Ms. Anderson joined Congress Asset Management in 2007 as Vice President of Client Service and in that role is the
primary relationship manager on accounts. She handles day to day requests from clients and consultants while acting as
liaison between clients and portfolio managers. She also attends client and prospective client meetings and works on
new business initiatives with the external sales team. Prior to Congress Asset Management, LLP she worked at Frontier
Capital Management as Vice President responsible for conducting client meetings and assisting portfolio managers of
high net worth, tax sensitive clients. Prior to her role as Vice President, she was an Assistant Vice President responsible
for client service. In this role, she worked closely with the financial advisors of large broker dealers. She began her
career with Frontier as a member of the administration and client service team where she updated marketing materials,
maintained databases, and completed RFPs and RFIs.
Dorene L. Anderson does not receive commissions, bonuses or other compensation on the sale of securities or
other investment products. She is not engaged in any other business or occupation that provides substantial
compensation or involves a substantial amount of his time. She does not receive any economic benefit from a
non-advisory client for the provision of advisory services.
Dorene L. Anderson has no reportable disciplinary history and all marketing material is required to be reviewed by Dan
Cross and the Compliance Officer prior to use. Each marketing person is required to maintain a log of marketing calls and
the materials used. Mr. Cross also holds scheduled meetings with the marketing staff.
Supervisor: Paul Lonergan
Title: Managing Director, Sales Phone Number: 617-737-1566
Jeff Barricelli
Born: 1975
Education
• Boston College; M.B.A.; 2007
• Bates College; B.A., Economics; 1997
Business Experience
• Congress Asset Management; Private Equity Analyst; from 01/2007 to Present
• Congress Asset Management; Investment Associate; from 06/2004 to 01/2007
• Enterprise Investments; Assistant Portfolio Manager; from 01/1998 to 03/2004
• Mass Mutual Insurance; Insurance & Investment Representative; from 06/1997 to 01/1998
Since June 2004, Mr. Barricelli has been employed by Congress Asset Management. His current role is as a Private
Equity Analyst. In this role, he serves on the Private Equity Committee and performs due diligence activities, monitors
and reports on current portfolio investments, and evaluates potential new investments. Prior to this role, he worked as a
performance analyst and was responsible for maintaining GIPS compliance within the firm and reporting the firm’s
composite performance and characteristics to consultants, databases, and potential clients.
Jeff Barricelli earned the following designation(s) and is in good standing with the granting authority:
Jeff Barricelli is not engaged in any other investment-related activities. He does not receive commissions,
Jeff Barricelli has no reportable disciplinary history. Christopher Lagan supervises Mr. Barricelli in his role as
private equity analyst in preparing due diligence reviews of potential and existing private equity investments and
presents investment recommendations to the private equity investment policy committee which oversees private
equity selection.
Supervisor: Christopher Lagan
Title: Senior Vice President
John M. Beaver
Born: 1969
Education
• Babson College; M.B.A.; 2002
• Colby College; B.A., American Studies; 1992
Mr. Beaver attended the two-year graduate program at Babson College that required study covering a wide range of
business topics while achieving a grade point average of greater than 2.8. His degree from Colby College required a four
year course of study and a grade point average of greater than 2.0.
Business Experience
• Congress Asset Management; Credit Analyst; from 06/2002 to 12/2006
• Massachusetts Financial Services Company; Quantitative Research Analyst; from 11/1996 to 08/2002
• Fidelity Investments; Performance Analyst; from 09/1992 to 07/1996
Mr. Beaver began his career with Fidelity Investments in 1992 as a performance analyst. In this role he
compared Fidelity mutual funds to peer competitors and reported the results to senior management. In his role as
quantitative research analyst with Massachusetts Financial Services, he supported fixed income research at the
firm with portfolio analysis specifically related to security modeling, performance attribution, scenario analysis, and
portfolio optimization. In his current role as portfolio manager with Congress Asset Management, he performs
economic analysis, fundamental research, security research, portfolio analysis, decision support, and
performance reviews. He is a member of the Fixed Income investment oversight committee and the All Cap
Opportunity investment oversight committee.
John M. Beaver earned the following designation(s) and is in good standing with the granting authority:
John M. Beaver is not engaged in any other investment-related activities. He does not receive commissions,
John M. Beaver has no reportable disciplinary history and all trades are reviewed daily by a member of the
Management Committee. The review is performed using a monthly rotation of four individuals who are members
of the Management Committee including Dan Lagan. Each of the individuals receives minutes of all Investment
Policy Committee actions and list of approved securities. Dan Lagan is Chief Investment Officer and also chairs
the Investment Oversight Committee. All accounts are reviewed formally on a quarterly basis to assure
conformance to investment policy and client guidelines.
Supervisor: Daniel A. Lagan
Title: President
Noel Blair
Born: 1978
Education
Mr. Blair attended Cornell University until the year 2000 in pursuit of a degree unrelated to his career in Finance. Since
February 2001, he has been employed by Congress Asset Management and has held several positions at the company.
He is currently a research analyst with the firm and a CFA Charter Holder.
Business Experience
• Congress Asset Management; Investment Analyst; from 01/2005 to Present
• Congress Asset Management; Operations Team Leader; from 09/2001 to 2/2004
From 2005 to 2007, Mr. Blair was a research analyst with Congress Asset Management where he performed
research analysis, portfolio management, and special projects. His research focused on energy and utilities and
involved analyzing and presenting financial data and industry trends to the investment committees and making
investment recommendations. His portfolio management duties involved assisting the firm's President with client
trading and communications. Since 2008 his duties have included analysis and presentation of the financial data
and industry trends of public companies and recommending investments for a number of industry sectors. He is a
member of the Mid Cap investment policy committee.
Noel Blair earned the following designation(s) and is in good standing with the granting authority:
Noel Blair is not engaged in any other investment-related activities. He does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products. He is not engaged in any other business or
occupation that provides substantial compensation or involves a substantial amount of his time. He does not receive any
economic benefit from a non-advisory client for the provision of advisory services.
Noel Blair has no reportable disciplinary history. The senior research analyst supervises Mr. Blair in his compilation and
arrangement of financial data reported by public companies in order to make investment recommendations to the
investment policy committees which oversee security selection at the firm. All trades are reviewed daily by a member of
the Management Committee. The review is performed using a monthly rotation of four individuals who are members of
the Management Committee including Dan Lagan. Each of the individuals receives minutes of all Investment Policy
Supervisor: Matt Lagan
Title: Senior Research Analyst
Matthew S. Boyce
Born: 1977
Education
• Assumption College; B.S., Philosophy; 2000
The curriculum at Assumption College prepares students for graduate work in Philosophy and requires 40 credits to earn
the degree. Mr. Boyce also studied marketing as a minor which required 21 credits covering management, marketing,
accounting, and electives. The study of philosophy and marketing provides students with an understanding of risks and
reward as well as the ability to analyze and respond to business challenges.
Business Experience
• Congress Asset Management; Regional Vice President; from 01/2008 to Present
• Congress Asset Management; Internal Sales; from 10/2003 to 12/2007
• Congress Asset Management; Operations; from 06/2001 to 09/2003
Mr. Boyce has been with Congress Asset Management since 2001 and has worked in various roles with the firm. From
2003 to 2007 he was a sales associate in the retail sales department. From 2007 to 2009 he was a Regional Vice
President responsible for new business development and client relationship management focused on the brokerage
community. Since 2009 he has been a Vice President responsible for new business development and client relationship
management within the retail and institutional spaces.
Matthew S. Boyce is not engaged in any other investment-related activities. He does not receive commissions,
Matthew S. Boyce has no reportable disciplinary history and all marketing material is reviewed and approved by the Chief
Compliance Officer prior to being distributed by sales and marketing staff. Sales and marketing staff maintain marketing
logs of all pre-approved materials provided to prospects and clients.
Supervisor: Paul Lonergan Title: Managing Director, Sales
Brent Ciliano, CFA
Born: 1970 (10/23/1970)
Education
• Drexel University; B.S., Finance & Accounting; 1994
Students with a concentration in finance and accounting obtain a thorough understanding of the basic concepts,
principles, operating procedures, and analytical techniques in the various areas of finance. The concentration prepares
students for careers in private business firms, including positions involving forecasting and budgeting for financial
resources, cost-effectiveness analysis, control of expenditures, evaluation and financing of new projects, and evaluation
of alternative methods of financing; in the investment field, including positions in banks, brokerage houses, and financial
institutions that participate in the various money and capital markets; and in the public sector, including positions at the
federal, state, and local government levels.
Business Experience
•
•
•
•
•
•
Congress Asset Management; Senior Vice President; from 3/1/2012 to Present
Goldman Sachs Asset Management; Vice President, Head of Portfolio Strategy Group; from 7/2007
to 2/29/2012
SEI Investments; Managing Director, Investment Strategy Group; from 12/2005 to 07/2007
Merrill Lynch Investment Managers, Vice President, from 03/2002 to 12/2005
Merrill Lynch & Co., Vice President, from 12/1997 to 3/2002
Arthur Andersen, Senior Consultant, from 09/1994 to 12/1997
Brent Ciliano has been employed by Congress Asset Management as Senior Vice President responsible for new business
development since 3/1/2012. Prior to joining Congress, he was Head of Asset Allocation & Portfolio Strategy with
Goldman Sachs & Co. in New York where he was responsible for setting investment policy, strategy, and asset allocation
Goldman’s largest institutional clients. Prior to Goldman, he was Managing Director for SEI Investments responsible for
setting investment policy and strategy for SEI’s Wealth Network Group. In this role advised clients on investment policy,
asset allocation, manager search & selection, manager due diligence, portfolio rebalancing, and performance attribution
analysis. Prior to SEI, he held several positions with Merrill Lynch including product development & strategy, sales, asset
management, and mergers & acquisitions. Brent began his career with Arthur Anderson in 1994.
Brent Ciliano earned the following designation(s) and is in good standing with the granting authority:
•
CFA; CFA Institute; 2007
Brent Ciliano is not engaged in any other investment-related activities. He does not receive commissions, bonuses or
other compensation on the sale of securities or other investment products. He is not engaged in any other business or
Brent Ciliano has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: Managing Director, Sales
Daniel J. Cross
Born: 1969
Education
• Boston College; B.S., Finance; 1991
Mr. Cross received a Bachelor of Science degree in Finance from Boston College in 1991. The Carroll School of
Management combines both business and liberal arts courses with the belief that broad knowledge, rather than
specialized training, best prepares students to be effective in an ever changing world. Students must complete 38 three
credit courses for a total of 114 credits including the University core curriculum, the Carroll School core curriculum, and
departmental concentration requirements. Relevant course work included Accounting, Economics, Statistics,
Management, Operations, Marketing, Organizational Behavior, and Basic Finance.
Business Experience
• Boston Capital Partners; Regional Vice President; from 10/1993 to 07/2000
• Barry Murphy and Company; Registered Representative; from 01/1992 to 09/1993
Mr. Cross has been employed by Congress Asset Management since 2000. He is responsible for business development
in the Institutional, Broker / Dealer, and Registered Investment Advisor communities. He supervises the sales team in all
related sales and marketing functions including meetings with prospects to review and discuss the firm and its investment
strategies. Sales and marketing efforts include the use of pre approved product profiles, presentation books, and other
pre-approved marketing materials about the investment products and strategies.
Daniel J. Cross is not engaged in any other investment-related activities. He does not receive commissions,
Daniel J. Cross has no reportable disciplinary history and all marketing material is reviewed and approved by the
Chief Compliance Officer prior to being distributed by sales and marketing staff. Sales and marketing staff
maintain marketing logs of all pre-approved materials provided to prospects and clients.
Michael S. Daly
Born: 1972
Education
• St. Michael's College; B.A., Political Science; 1995
The liberal arts curriculum at St. Michael's focuses on four basic principles including enhancement of citizenship,
appreciation and cultivation of the arts and sciences, critical thinking, and communication.
Business Experience
• Liberty Financial Companies; Sales; from 01/1996 to 02/2000
Mr. Daly held a variety of positions with the Liberty Financial Companies. He began his career as a business service
representative assisting clients and brokers with inquiries related to insurance products. In 1998, he became a marketing
representative providing detailed product information to brokers and distributors. He also assisted the Regional Vice
President with sales presentations and meetings. In 2000, he joined Congress Asset Management as a sales and
marketing associate working in a sales support capacity. Since 2001, he has been a member of the sales team as a vice
president responsible for sales and marketing. He is also responsible for key account management and relationship
management with consultants and the brokerage community.
Michael S. Daly is not engaged in any other investment-related activities. He does not receive commissions,
Michael S. Daly has no reportable disciplinary history and all marketing material is reviewed and approved by the
Chief Compliance Officer prior to being distributed by sales and marketing staff. Sales and marketing staff
maintain marketing logs of all pre-approved materials provided to prospects and clients.
Supervisor: Paul Lonergan Title: Managing Director, Sales Phone Number: 617-737-1566
Daniel P. Driscoll
Born: 1971
Education
• Bryant College; B.S., Finance; 1994
The curriculum at Bryant College focuses on providing rigorous academic programs that integrate business and
liberal arts to develop the skills and critical thinking that are essential to every profession. The concentration in
finance focuses on corporate financial management, investments, capital markets, and financial institutions.
Students must complete 122 credits covering finance, business, and various liberal arts electives.
Business Experience
• Boston Capital; Sales; from 01/1996 to 03/2001
• Spag's Supply; Retail; from 04/1989 to 05/1994
Mr. Driscoll began his career as a disability claims examiner with Paul Revere Insurance responsible for disability
claims reviews. In 1996 he was employed by Boston Capital as an internal sales representative supporting an
outside sales wholesaler. During his time with Boston Capital, he became a NASD registered representative
series 6, 22, and 63 and was promoted to Regional Vice President managing a staff of 10 sales representatives.
In 2001 he joined Congress Asset Management as a Regional Vice President responsible for business
development and client service for the sub-advisory channel. In 2010, he was named vice president business
development and his role expanded to include institutional sales.
Daniel P. Driscoll is not engaged in any other investment-related activities. He does not receive commissions,
Daniel P. Driscoll has no reportable disciplinary history and all marketing material is reviewed and approved by the Chief
logs of all pre-approved materials provided to prospects and clients.
Supervisor: Paul Lonergan Title: Managing Director, Sales Phone Number: 617-737-1566
Brian J. Durkin
Born: 1967
Education
• University of Massachusetts at Amherst; B.A., Economics; 1989
The curriculum for the Economics major at the University of Massachusetts at Amherst provides students with an
understanding of both micro and macro economics. Microeconomics analyzes the individual behavior of households,
business firms, and governmental entities. Macroeconomics focuses upon aggregate economic performance of nations
and their interdependencies in the global economy.
Business Experience
• Congress Asset Management; Director of Operations; from 03/2007 to Present
• Brian J. Durkin; Independent Consultant; from 06/2006 to 03/2007
• Cadence Capital Management; Direct of Operations & Treasurer; from 02/2001 to 05/2006
• Thomson Financial; New England Sales Manager; from 02/1999 to 01/2001
• Interlynx Technology; Project Manager & Territory Manager; from 05/1994 to 11/1999
• Putnam Investments; Team Leader; from 07/1992 to 04/1994
• Fidelity Investments; Account Manager; from 07/1989 to 06/1992
Mr. Durkin began his career in 1989 with Fidelity Investments as an auditor responsible for the ongoing review of several
401(k) retirement plans. In 1990 he was promoted to Account Manager responsible for relationship management
between the 401(k) clients and Fidelity Investments. In 1992, he joined Putnam Investments as a Team Leader
responsible for managing a team of professionals providing ongoing operational support to the $1 billion MCI 401(k) Plan.
In 1994, he joined a start up software and professional services firm that developed voice and web-based self service
applications for corporations and financial services firms. In 1999, Mr. Durkin joined Thomson Financial as the New
England Sales Manager responsible for consultative sales and service to prospects and clients of Thomson Financial who
purchased or were considering purchasing the PORTIA Portfolio Management & Accounting System and the OpenTrader
Trade Order Management System. In 2001, he joined Cadence Capital Management as Director of Operations
responsible for investment operations, systems, information technology, and administration. In 2003, he added the
responsibility of Treasurer and implemented corporate finance and accounting for the firm following an acquisition by
Rosemont Partners. In this role, he lead a team of 2 accountants and was responsible for all aspects of the company's
financials including accounting, payables / receivables, payroll, budget, forecasting, and reporting. In 2006, Mr. Durkin
became an independent consultant working with institutional money managers to improve those firm’s workflows by
combining staffing analysis, workflow automation tools, and client relationship management solutions to achieve best
practices. After a brief consulting engagement with Congress Asset Management, Mr. Durkin was hired as Director of
Operations for the firm. In this role, he is responsible for managing a team of 12 professionals covering operations, equity
trading, trade settlements, information technology, accounting, and administration.
Brian J. Durkin is not engaged in any other investment-related activities. He does not receive commissions,
Brian J. Durkin has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
E. Martine Elie
Born: 1972
Education
• Northeastern University; M.B.A.; 1999
• Ecole des Hautes Etudes Commerciales (HEC Montreal); B.B.A.; 1994
Ms. Elie received an MBA from Northeastern 1999 with a concentration in finance. In order to receive the degree
from Northeastern, students must earn 60 credits. Her undergraduate degree from HEC Montreal was earned in
1994. The curriculum consists of business and finance courses. Students must complete 30 credits per year
over 3 years for a total of 90 credits.
Business Experience
• Congress Asset Management; Research Analyst; from 06/1999 to 01/2002
• Credifinance Securities (formerly Majendie Charlton Securities); Analyst; from 05/1995 to 06/1997
• Congress Trust National Association; Vice President and Trust officer; from 08/2005 to 09/2009
Ms. Elie began her career with Majendie Securities as a research analyst. She contributed to the investment decisions for
the firm’s managed portfolios by providing company, industry, and marketing information to portfolio managers. She
joined Congress Asset Management in 1999 as a research analyst covering consumer staples, consumer discretionary,
industrials, and healthcare sectors. In this role she was responsible for the compiling and arrangement of financial data
reported by public companies in order to make investment recommendations to the investment committees. In 2001 she
became a portfolio manager responsible for institutional and private clients. She is currently a member of the private
equity, large cap growth, and global all cap growth equity committees.
E. Martine Elie earned the following designation(s) and is in good standing with the granting authority:
E. Martine Elie is not engaged in any other investment-related activities. She does not receive commissions, bonuses or
other compensation on the sale of securities or other investment products. She is not engaged in any other business or
occupation that provides substantial compensation or involves a substantial amount of her time. She does not receive
any economic benefit from a non-advisory client for the provision of advisory services.
E. Martine Elie has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
John G. Fitzgerald
Born: 1964
Education
• Suffolk University; M.B.A.; 1991
• University of Massachusetts; B.B.A., Finance; 1986
Mr. Fitzgerald received an MBA from Suffolk University in 1991. The MBA curriculum required students to complete a 16
course program of which 8 were core and 8 were elective. Each student must achieve a 2.5 grade point average to
graduate. He received a bachelor of business administration from the University of Massachusetts in 1986 with a
concentration in finance. The curriculum combines business and liberal arts courses to give students a foundation in
critical thinking and reasoning. Students must complete 120 credits and maintain a 2.0 grade point average in the
students chosen major in order to graduate.
Business Experience
• MG Financial; Principal; from 09/1996 to 06/2001
• Gannett Welsh & Kotler; Vice President; from 08/1994 to 8/1996
• Wellington Management Company; Assistant Vice President; from 01/1989 to 07/1994
• Putnam Investor Services; Senior Accountant; from 01/1986 to 12/1988
• Congress Trust National Association; Vice president and Trust Officer; from 04/2002 to 06/2009
Mr. Fitzgerald began his career in 1986 with Putnam Investor Services as a senior accountant responsible for preparing
financial statements and tax work papers on several mutual funds for periodic audit by the funds outside auditors. He
joined Wellington in 1989 as a financial analyst preparing corporate financial statements, budgets, and cash flow analysis
of senior management. He was promoted to Assistant Vice President responsible for preparing and communicating fund
and market analytics on client portfolios. In 1994 he joined Gannett Welsh & Kotler as Vice President responsible for
providing high net worth individuals with personal financial advice involving manager selection, asset allocation, and
estate and tax planning. In1996, the firm spun off into MG Financial where he continued providing independent financial
consulting services to high net worth individuals. He joined Congress Asset Management in 2001 as a portfolio manager.
He is a member of the private equity and mid cap investment oversight committees.
John G. Fitzgerald earned the following designation(s) and is in good standing with the granting authority:
John G. Fitzgerald is not engaged in any other investment-related activities. He does not receive commissions, bonuses
or other compensation on the sale of securities or other investment products. He is not engaged in any other business or
John G. Fitzgerald has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
Brian T. Guild
Born: 1977
Education
• Bentley University; B.S., Economics-Finance; 2000
• Northeastern University; M.B.A., Business; 2011
Mr. Guild graduated from Bentley University in 2000. Bentley University's curriculum provides students with many options
for shaping an academic program that fits their unique skills, interests, and goals. Students must complete 122 credit
hours of course work to graduate while maintaining a minimum 2.0 grade point average. In 2011 he completed his MBA
from Northeastern University. Northeastern’s curriculum emphasizes problem solving, team work, project management,
communication, quantitative analysis, and essential management skills. Students must earn 60 semester hours of credit
to graduate.
Business Experience
• Congress Asset Management; Research Analyst; from 05/2008 to Present
• Congress Asset Management; Fixed Income Trader; from 11/2001 to 05/2008
• Congress Asset Management; Portfolio Accountant; from 08/2000 to 11/2001
Mr. Guild began his career in 2000 as a portfolio accountant with Congress Asset Management. From 2001 to 2008 he
was a fixed income trader responsible for obtaining best execution for fixed income trades. He made weekly
presentations to the investment team on market and economic trends and events. Since 2008 he has worked as a
research analyst in the fixed income department. In this role he provided company, industry, and market information to
the investment team to assist them in their decision making. He develops analytical, quantitative, and relative valuation
models. He is a member of the fixed income investment policy committee
Brian T. Guild is not engaged in any other investment-related activities. He does not receive commissions,
Brian T. Guild has no reportable disciplinary history. He is supervised by Jeffrey R. Porter who is the director of
fixed income. He analyzes fixed income securities and portfolios in order to make investment recommendations
to the investment policy committees which oversee security selection at the firm.
Supervisor: Jeffrey R. Porter
Title: Executive Vice President and Director of Fixed Income
Srikanth Gullapalli
Born: 1976
Education
• University of Saint Thomas; M.S., Software Engineering; 2003
• Vignana Jyothi Institute of Management; P.G., Business Management; 1999
• Osmania University; B.Com.; 1997
Business Experience
• Congress Asset Management; Systems Engineer/Research Analyst; from 08/2005 to Present
• Eze Castle Integration; Network Engineer; from 09/2003 to 07/2005
• Karvy Consultants; Management Executive; from 03/1999 to 03/2000
Mr. Gullapalli began his career in 1999 as a Management Executive with Karvy Consultants responsible for back office
management activities for mutual funds including data collection, NAV calculations, transaction processing, and problem
resolution. In 2003 he joined EzeCastle Integration as a network engineer responsible for managing and supporting the
information technology infrastructure for approximately 40 registered investment advisor firms in the Boston area. He
joined Congress Asset Management in 2005 as a network engineer and operations analyst responsible for managing data
collection and maintenance for operations and client investment accounts. In 2009 he began assisting the research team
with certain companies and sectors. In 2010 he began covering the telecommunications, semi conductor, and IT services
sectors as a member of the research team. He is a member of the Mid Cap IPC.
Srikanth Gullapalli earned the following designation(s) and is in good standing with the granting authority:
Srikanth Gullapalli is not engaged in any other investment-related activities. He does not receive commissions,
Srikanth Gullapalli has no reportable disciplinary history. The senior research analyst supervises Mr. Gullapalli in
his compilation and arrangement of financial data reported by public companies in order to make investment
recommendations to the investment policy committees which oversee security selection at the firm.
John R. Hogan
Born: 1945
Education
• Clark University; B.A., Economics; 1967
Clark University is a small, private, liberal arts-based research university committed to scholarship and inquiry that
addresses social and human imperatives on a global basis. Mr. Hogan graduated from Clark University in 1967. He is
also a graduate of the University of Chicago Executive Management Program.
Business Experience
• Blue Cod Technologies; Senior Consultant; from 01/1999 to 05/2002
• Covenant Group; Vice President; from 05/1994 to 12/1998
• Hanover Insurance; Vice President; from 11/1988 to 01/1994
Mr. Hogan has worked at Congress Asset Management since 2002. He is a member of the management committee that
sets the company's strategic direction, establishes company-wide growth initiatives, and directs client service initiatives.
Further, he has had oversight responsibilities for operations, trading, and systems administration. Prior to joining
Congress Asset Management he held senior operations and technology positions in the financial industry. He was Chief
Information Officer of the Hanover Insurance Companies and the Covenant Group. He was also a Senior Consultant with
Blue Cod Technologies, a financial technology consulting company.
John R. Hogan serves on the Board of Directors of Congress Wealth Management, LLC. He does not receive
commissions, bonuses or other compensation on the sale of securities or other investment products. He is not
engaged in any other business or occupation that provides substantial compensation or involves a substantial
amount of his time. He does not receive any economic benefit from a non-advisory client for the provision of
advisory services.
John R. Hogan has no reportable disciplinary history and all trades are reviewed daily by a member of the Management
Committee. The review is performed using a monthly rotation of four individuals who are members of the Management
Committee including Dan Lagan. Each of the individuals receives minutes of all Investment Policy Committee actions and
list of approved securities. Dan Lagan is Chief Investment Officer and also chairs the Investment Oversight Committee.
All accounts are reviewed formally on a quarterly basis to assure conformance to investment policy and client guidelines.
Title: President
Nancy T. Huynh
Born: 1973
Education
• Harvard University; A.L.M., Management; 2007
• Colby College; B.A., International Studies; 1996
Colby College's International Studies Curriculum offers a rigorous approach to global affairs and covers four core
disciplines (anthropology, economics, government, and history) requiring students to become knowledgeable about
multiple geographic areas and gain an understanding of policy-making processes that affect the international arena by
studying abroad for at least one semester. Students must earn a minimum of 128 credit hours with at least 64 credits
hours in residence. Harvard's Master of Liberal Arts in Finance curriculum requires students take 12 courses while
earning 48 credits comprised of 8 required courses and 4 electives while maintaining a 3.0 grade point average.
Business Experience
• Congress Asset Management; Investment Administrator; from 01/2000 to 12/2000
• Congress Asset Management; Portfolio Accountant; from 06/1998 to 12/1999
• Museum of Science; Membership Relations; from 08/1996 to 01/1998
Ms. Huynh has worked with Congress Asset Management since 1998. She has been a research analyst since 2001.
Her responsibilities include providing analytical support to the portfolio managers, preparing quarterly earnings reports,
performing financial and market analysis of publicly traded companies in the Materials and Consumer Discretionary
universe, and making formal presentations to the investment policy committees. She is a member of the large cap
investment policy committee.
Nancy T. Huynh is not engaged in any other investment-related activities. She does not receive commissions, bonuses or
Nancy T. Huynh has no reportable disciplinary history. The senior research analyst supervises Ms. Huynh in her
compilation and arrangement of financial data reported by public companies in order to make investment
Matthew P. Leahy
Born: 1977
Education
•
•
BostonCollege;M.B.A.,Management;2011
UniversityofVermont;B.S.,Business;2000
Mr.LeahyreceivedaBachelorofSciencedegreeinBusinessAdministrationfromUniversityofVermont,
Burlington,Vermont,in2000.InMay,2011hereceivedaMaster'sofBusinessAdministrationfromtheCarroll
GraduateSchoolofManagementatBostonCollege.
Business Experience
•
•
•
•
•
•
•
CongressAssetManagement;ConsultantRelations;from02/2012toPresent
CongressWealthManagement;InstitutionalSales;from01/2011to02/2012
CongressAssetManagement;Co‐PortfolioManager;from06/2011to01/2011
CongressAssetManagement;ResearchAnalyst;from02/2007to01/2011
CongressAssetManagement;InvestmentAdministrator;from10/2005to02/2007
CongressAssetManagement;Operations;from06/2002‐10/2005
INVESCO;PortfolioAccountant;from07/2000‐03/2002
Mr.LeahyhasworkedforCongressAssetManagementsince2002.SinceFebruary2012,Mr.Leahyhasmanaged
consultantrelationsintheinstitutionalmarketplaceforCongressAssetManagement.Heisresponsiblefor
fosteringcurrentanddevelopingnewconsultantrelationshipsforthefirm.Mr.Leahy’stimeasananalystand
portfoliomanageraffordhimtremendousknowledgeofandexperiencewithourstrategies.Thisfoundationallows
Mr.Leahytoworkwithconsultantstoidentifyapropermanagerfitforourstrategiesaspartofabroaderpoolof
assetsfortheendclient.During2011Mr.LeahyworkedinInstitutionalSalesforCongressWealthManagement
focusingonEndowments,Foundations,andDefinedBenefitPlans.Hewasresponsiblefordevelopingcustomized
strategiestomeettheneedsofinstitutionalclients.Withananalyticalbackground,Mr.Leahyintegratesaliability
drivenapproachtonavigatetoday’scomplexinstitutionalenvironment.Mr.LeahybeganhiscareeratCongressin
2002andhasworkedthroughoutthefirmintrading,equityresearchandmostrecentlyasaco‐portfoliomanager
in2010andInstitutionalSalesin2011.
Matt Leahy earned the following designation(s) and is in good standing with the granting authority:
Matt Leahy is not engaged in any other investment-related activities. She does not receive commissions, bonuses or
Matt Leahy has no reportable disciplinary history and all trades are reviewed daily by a member of the
Supervisor: Brent Ciliano
Title: Senior Vice President
Paul A. Lonergan
Born: 1967
Education
• University of Massachusetts Amherst; Bachelor of Arts; Communications; 1999
• University of Pennsylvania; 1999 - 2000
Mr. Lonergan graduated from the University of Massachusetts and has completed executive programs in
Management and Leadership at the University of Pennsylvania’s Wharton School.
Business Experience
• Congress Asset Management Company, LLP; Managing Director, Sales; from 1/2012 to Present
• Congress Wealth Management, LLC; President; from 9/2009 to Present
• Congress Trust, N.A.; President; from 1/2007 to 3/2009
In January 2011, Mr. Lonergan began working for Congress Asset Management as Managing Director, Sales. He focuses on the management of sales activities for the firm. Mr. Lonergan is the President of Congress Wealth Management.
He is responsible for the overall delivery of our wealth management experience to our clients, and serves on the
Congress Wealth Board of Directors. Prior to joining Congress Wealth Management, he was President of Congress
Trust, N.A.. In 2010 Paul was nominated for an Investment News Community Leadership Award. These awards
honor financial advisers who make a difference in their communities. He currently serves as the head of the St.
Peter School Board in Cambridge, as well as on the Boards of Mentoring at Risk Athletes and the Laboure Center
in South Boston. Paul is also a member of the Board of Directors for Congress Asset Management. Paul is a
member of the Development Committee of North Cambridge Catholic High School, and is a past member of the
finance committee of the Boston Chamber of Commerce. He and his wife Anne reside in Cambridge with their
three children.
Paul A. Lonergan is engaged in other investment-related activities at Congress Wealth Management, LLC. He
does not receive commissions, bonuses or other compensation on the sale of securities or other investment
products. He is not engaged in any other business or occupation that provides substantial compensation or
involves a substantial amount of his time. He does not receive any economic benefit from a non-advisory client
for the provision of advisory services.
Paul A. Lonergan has no reportable disciplinary history and all marketing material is reviewed and approved by the Chief
logs of all pre-approved materials provided to prospects and clients. Supervisor: Daniel Lagan
Title: President
Jessica L. Moss
Born: 1977
Education
• Indiana University – Southeast Campus; Master of Science in Strategic Finance; 2005
• University of Louisville; B.S., Finance; 1999
The Indiana University Southeast Master of Science in Strategic Finance (MSSF) degree program addresses issues that are of significance to accounting and corporate finance professionals. MSSF students are required to complete a total of 36 graduate credit hours and fulfill a community service requirement. The Bachelor of Science with a Major in Finance degree program is designed to prepare graduates to apply critical thinking and problem solving skills, either individually or in teams, in order to creatively and ethically solve problems in a global marketplace. The Major in Finance degree program requires a minimum of 126 undergraduate credit hours, which includes general education classes, business breadth, and finance depth coursework. The University of Louisville College of Business is accredited by The Association to Advance Collegiate Schools of Business. Business Experience
• Quasar Distributors LLC; Registered Rep; from 2/2012 to Present
• National Asset Management/Invesco; Institutional Sales; from 7/2000 to 11/2011
In October 2011, Jessica began working for Congress Asset Management as Vice President, Institutional Sales. Jessica focuses on new business generation for the firm. Jessica began her investment career in July 2000 at National Asset Management as a Client Service Associate. National Asset Management was acquired by Invesco in April 2001. Jessica’s role changed in 2002 when she began working as a Portfolio Analyst, serving as a liaison between the equity investment management team and client service personnel. In 2006 Jessica joined Invesco’s Sales & Service team as a Director. In this role, she was responsible for relationship management and new business generation for institutional investors located in the central United States. Jessica L. Moss earned the following designation(s) and is in good standing with the granting authority:
FINRA Series 6, 63; 2012
Jessica L. Moss is a FINRA Registered Representative Series 6 and Series 63. She is employed by Quasar
Distributors, a limited purpose broker-dealer providing certain underwriting and distribution services the Congress
Large Cap Growth Fund. Congress Asset Management is the Advisor to the Congress Large Cap Growth Fund.
Jessica L. Moss is not engaged in any other investment-related activities. She does not receive commissions,
bonuses or other compensation on the sale of securities or other investment products. She is not engaged in any
other business or occupation that provides substantial compensation or involves a substantial amount of her
time. She does not receive any economic benefit from a non-advisory client for the provision of advisory services.
Jessica L. Moss has no reportable disciplinary history and all marketing material is reviewed and approved by the Chief
logs of all pre-approved materials provided to prospects and clients. Supervisor: Paul Lonergan
Thomas B. Murphy
Born: 1950
Education
• Bowdoin College; B.A., History; 1972
• Purdue University; Ph.D.; 1979
Mr. Murphy has a Ph.D. from Purdue University and a B.A. from Bowdoin College. He has been a CFA charter
holder since 1987. A Ph.D. involves graduate level course work and the completion of a dissertation supervised
by a faculty committee, while a B.A. involves the completion of required undergraduate courses over a four year
span.
Business Experience
• Congress Asser Management; Senior Vice President; from 07/2001 to Present
• Congress Asset Management; Vice President; from 04/1999 to 07/2001
• Commercial Union; Senior Investment Analyst; from 08/1991 to 09/1995
Mr. Murphy is currently a Senior Vice President and Portfolio Manager with Congress Asset Management. In this
role he manages diversified portfolios for both institutions and individuals consisting of securities approved for
purchase by the investment policy committees. Mr. Murphy is a member of the large cap investment policy
committee, the global all cap growth investment policy committee, and the investment oversight committee. Prior
to joining Congress Asset Management, he served as an equity and credit analyst with three large financial
institutions. In this capacity, he was responsible for researching and analyzing publicly traded companies to
assess if they were suitable investments for the institutions common stock and fixed income portfolios.
Thomas B. Murphy earned the following designation(s) and is in good standing with the granting authority:
Thomas B. Murphy is not engaged in any other investment-related activities. He does not receive commissions,
Thomas B. Murphy has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
Amy B. Noyes
Born: 1968
Education
• Northeastern University; M.B.A.; 1995
• Castleton State College; B.S., Finance; 1990
The Business Administration core curriculum at Castleton State College provides a foundation of general business
knowledge. Students fulfill general education requirements as well as the specific requirements of the chosen major while
earning at least 122 credits over eight semesters. The Northeastern full-time M.B.A. program is a 60 credit program that
can be completed in 24 months. In the first year, students take foundation courses and participate in a career
management course that helps one prepare for corporate residency. The first year also includes a globalization
requirement fulfilled by participating in the International Field Study Program. The second year of the program includes
courses that emphasize strategy and enterprise growth, including a Business Plan Project where teams of students
deliver actionable business growth plans for Northeastern's corporate partners.
Business Experience
• Congress Asset Management Company; Vice President; from 01/2002 to Present
• Congress Asset Management Company; Portfolio Manager; from 01/2001 to 01/2002
• Congress Asset Management Company; Research Analyst; from 06/1996 to 01/2001
• New England Insurance and Investment; Senior Investment Analyst; from 09/1995 to 05/1996
• Fidelity Investments; Research Assistant; from 09/1994 to 04/1996
• Newbury, Piret & Companies, Inc.; Controller & Office Manager; from 06/1991 to 09/1994
Ms. Noyes began her career with Newbury, Piret, & Companies in 1991 as Controller and Office Manager responsible for
a personal estate and a trust fund valued at $7 million. In this role, she monitored and presented the investment
performance monthly to the President. During this time, she defined and implemented two accounting systems for the
corporation and personal estate. In 1994, she joined Fidelity Investments as Research Assistant to the Director of Global
Research. In this role, she consulted with the Chief Economist, Portfolio Managers, and Country Managers. In 1995 she
joined New England Insurance and Investment as the Senior Information Investment Analyst where she analyzed,
reported, and projected investment results for the assets under management used by the Chief Investment Officer and
Board of Directors. In 1996, Ms. Noyes joined Congress Asset Management as a research analyst. In this role, she was
a generalist responsible for generating, analyzing, and presenting new investment opportunities. Beginning in 1998, Ms.
Noyes became responsible for portfolio management of institutional, individual, and sub-advisory client portfolios. She is
a member of the mid cap investment policy committee. She has been a past member of the large cap investment policy
committee. She is involved in due diligence and client conference calls and meetings.
Amy B. Noyes earned the following designation(s) and is in good standing with the granting authority:
Amy B. Noyes is not engaged in any other investment-related activities. She does not receive commissions,
bonuses or other compensation on the sale of securities or other investment products. She is not engaged in any
other business or occupation that provides substantial compensation or involves a substantial amount of her time.
She does not receive any economic benefit from a non-advisory client for the provision of advisory services.
Amy B. Noyes has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
Gregg A. O'Keefe
Born: 1960
Education
• Boston College; MBA, Finance; 1989
• Boston University; B.S.B.A., Accounting; 1982
The curriculum at Boston University's School of Management is balanced between a core requirement of courses and a
broad variety of electives. Students must complete 33 courses comprised of business core courses, business elective
courses, and liberal arts electives. The curriculum at the Carroll School of Management at Boston College provides a
foundation in managerial, analytical, and practical management skills. Students must complete 56 credits of course work
including 18 hours of electives which allows them to enhance their experience.
Business Experience
• Congress Asset Management; Executive Vice President; from 07/01/1999 to Present
• Congress Asset Management; Senior Vice President; from 05/01/1986 to 06/30/1999
• Trustee & Investors Co., Inc.; Analyst; from 06/01/1982 to 04/30/1986
• Congress Trust National Association; Vice President & Trust Officer; from 12/01/1997 to 10/30/2005
• Congress Trust National Association; Vice President; from 10/01/2005 to 11/30/2009
From 1982 to 1986, Mr. O'Keefe was an analyst at Trustee & Investors, Co., Inc. responsible for analyzing industry trends
as well as the financial statements of public companies. This analysis assisted portfolio managers in their investment
decisions. He joined Congress Asset Management in 1986 and has held numerous positions in addition to his role as a
Portfolio Manager. Currently, Mr. O'Keefe is a member of the Management Committee of Congress Asset Management
which oversees the operations of the company as well as its strategic direction. He is a member of the Investment
Oversight Committee that is responsible for governance and oversight of all the company's investment products. He is a
member of the large cap growth investment policy committee, the mid cap investment policy committee, and chairman of
the dividend growth investment policy committee. The committees oversee security selection of their underlying product.
Gregg A. O'Keefe earned the following designation(s) and is in good standing with the granting authority:
Gregg A. O'Keefe is not engaged in any other investment-related activities. Gregg A. O'Keefe does not receive
commissions, bonuses or other compensation on the sale of securities or other investment products. Gregg A.
O'Keefe is not engaged in any other business or occupation that provides substantial compensation or involves a
substantial amount of his time. Gregg A. O'Keefe does not receive any economic benefit from a non-advisory
client for the provision of advisory services.
Gregg A. O'Keefe has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
John B. O'Reilly
Born: 1964
Education
• Bryant College; M.B.A., Finance; 1992
• Providence College; B.A., History; 1986
Providence College offers a liberal arts education that is comprehensive, interdisciplinary, and substantive. Providence
College offers a unique Development of Western Civilization program that allows students to see connections and
relationships between academic disciplines. The core curriculum grounds students in scientific literacy and instills a basic
understanding of the range of human interactions through the varied lenses of psychology, sociology, anthropology, art,
history, literature, theology, and philosophy. Bryant College's MBA program integrates the most current business
management theory with the best business practices to enable graduates to lead people and effectively manage
resources in a complex global marketplace. The MBA program’s course work includes strategy, leadership, management,
accounting, finance, marketing, operations, and technology. The curriculum balances the technical, data driven,
quantitative skills to make objective decisions with the interpersonal communication skills necessary to work effectively
with people at all levels and from all cultures. These topics are integrated throughout the curriculum to develop an
understanding of all aspects of business.
Business Experience
• Mellon Private Asset Management; Portfolio Manager; from 07/2000 to 06/2001
• State Street Bank & Trust; Vice President; from 03/1991 to 07/2000
In his time with Congress Asset Management, LLP, Mr. O'Reilly has held numerous positions in addition to his role as
Portfolio Manager for institutions and individuals. From June 2001 to December 2006, he was Director of Equity
Research leading a team of six equity analysts who were responsible for the compilation and arrangement of financial
data reported by public companies in order to make investment recommendations to the Investment Policy Committee.
Simultaneously, he provided equity research coverage of a number of companies. Currently, he is Chair of the Global All
Cap Growth Equity Committee. In this role, he sets the agenda for committee meetings and leads the discussion and
selection of equity securities for the Global All Cap Growth Equity portfolios.
John B. O'Reilly earned the following designation(s) and is in good standing with the granting authority:
The CFA designation is an international professional certification offered by the CFA Institute to financial analysts
who completed a series of three examinations, possessed a bachelor's degree from an accredited institution ( or
had an equivalent education or work experience ), and at that time had 48 months of qualified professional work
experience. CFA charter holders are obligated to adhere to a strict Code of Ethics and Standards governing
professional conduct.
John B. O'Reilly is not engaged in any other investment-related activities. He does not receive commissions,
All trades are reviewed daily by a member of the Management Committee. The review is performed using a monthly
rotation of four individuals who are members of the Management Committee including Dan Lagan. Each of the individuals
receives minutes of all Investment Policy Committee actions and list of approved securities. Dan Lagan is Chief
Investment Officer and also chairs the Investment Oversight Committee. All accounts are reviewed formally on a
quarterly basis to assure conformance to investment policy and client guidelines.
Title: President
Jeffery R. Porter
Born: 1964
Education
• East Carolina University; M.B.A.; 1990
• North Carolina State University; B.A., Accounting, Business Management, & Finance; 1987
Mr. Porter received two Bachelor degrees, Accounting and Business Management, from North Carolina State University.
The curriculum initially has courses focused on theory and subsequently offers courses which are more applicationoriented. Students must compete 120 total semester hours to earn a Bachelors degree. He also received a Master's of
Business Administration with a concentration in Finance from East Carolina University. Students must earn a minimum of
60 semester hours to graduate.
Business Experience
• Congress Asset Management; EVP & Director Fixed Income; from 03/2010 to Present
• Prelude Asset Management; Co-Founder & Chief Executive Officer; from 06/2009 to 03/2010
• Kellport Capital Management/Crescam Asset Management; Co-Founder; from 04/2005 to 05/2009
• Partners HealthCare Systems, Inc.; Director of Portfolio Management; from 06/1997 to 03/2005
• North Carolina Retirement Systems; Investment Professional; from 08/1992 to 04/1997
• KPMG Peat Marwick; Staff Auditor; from 08/1990 to 04/1992
Mr. Porter began his career with KPMG in 1990 as a Staff Auditor. In 1992, he joined the North Carolina Retirement
Systems as a Credit Analyst in charge of investment grade debt and private debt. He transitioned to the position of Fixed
Income Trader where he executed trades for a variety of fixed income instruments with over sixty broker-dealers.
Subsequently, he became a Fixed Income Portfolio Manager responsible for managing the $22 billion dollar Long-Term
Fund. In this role, he determined relative value, executed trades, and established strategy for the fund. He also assisted
in the management of the $8 billion Short-Term Fund. Mr. Porter was responsible for determining strategy for the overall
fixed income program at the North Carolina Retirement Systems. In 1997, Mr. Porter joined Partners HealthCare System,
Inc. (PHS) as Director of Portfolio Management & Private Equity responsible for actively managing the internal fixed
income portfolios, executing trades with the broker-dealer community, and conducting fundamental relative value credit
analysis on numerous debt issuers. Mr. Porter was responsible for formulating and recommending overall fixed income
allocation strategies and was a member of the PHS Investment Committee. In 2005, Mr. Porter became founder and
CEO of Crescam Asset Management, (later re-named Prelude Asset Management, a spin-out form from PHS, where he
continued to manage the same fixed income assets he managed while employed by PHS. In 2010, Prelude Asset
Management was acquired by Congress Asset Management. Mr. Porter became Executive Vice President & Director of
Fixed Income. He is chairman of the Fixed Income Investment Policy Committee, the decision making body for all fixed
income strategies managed by Congress Asset Management. He is a member of the firm's management committee.
Jeffery R. Porter earned the following designation(s) and is in good standing with the granting authority:
Jeffery R. Porter is not engaged in any other investment-related activities. He does not receive commissions,
Jeffery R. Porter has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
Todd W. Solomon
Born: 1970
Education
• New York University; M.B.A.; 1996
• Georgetown University; B.S. B.A., Management; 1992
The curriculum at Georgetown University's McDonough School of Business combines business and liberal arts courses to
give students a foundation in critical thinking and reasoning. During the first two years, the primary academic emphasis is
on liberal arts courses, business courses, courses supporting a concentration, and free electives. In the final two years,
the focus shifts to business courses. Students must complete both 40 courses and 120 semester hours to graduate. The
Master's of Business Administration degree from the Leonard N. Stern School of Business at New York University
requires students earn 60 credits and maintain a 2.5 grade point average. Mr. Solomon's M.B.A. was earned with
specializations in Finance and Economics.
Business Experience
• United States Trust Company of Boston; Investment Officer; from 05/1998 to 02/2001
• Fidelity Management & Research Company; Sector Research; from 08/1996 to 05/1998
• The Pioneer Group, Inc.; Assistant Analyst; from 01/1993 to 08/1994
From 1992 to 1994, Mr. Solomon was a Mutual Fund Accountant at Pioneer Investments responsible for calculating the
daily net asset value of several mutual funds and preparation of financial statements for periodic audits by Arthur
Andersen. In 1993, he began working as an Assistant Equity Analyst at Pioneer Investments responsible for analyzing
the financial statements of public companies and making investment recommendations to several mutual fund portfolio
managers. In 1996, Mr. Solomon was employed by Fidelity Management and Research Company as a Sector Research
Specialist. In this role, he provided company, industry, and market information to analysts and portfolio managers to
assist in their investment decisions. In 1999, he joined the Unites States Trust Company of Boston as an Equity
Research Analyst and Portfolio Manager. His responsibilities included making investment recommendations for client
portfolios based on the compilation and arrangement of financial data reported by public companies to the Securities
Research Committee overseeing security selection at the firm and implementing those decisions for certain client
accounts. In 2001, Mr. Solomon joined Congress Asset Management. In his time with the firm, he has held numerous
positions in addition to his role as Portfolio Manager for institutions and individuals. From 2007 to 2009 he was Director of
Equity Research responsible for leading six equity analysts who were responsible for the compilation and arrangement of
financial data reported by public companies in order to make recommendations to the Investment Policy Committee which
oversees security selection at the firm. Currently, Mr. Solomon is Chair of the mid cap growth committee. In this role, he
supervises the discussion and selection of equities for the mid cap growth client portfolios.
Todd W. Solomon earned the following designation(s) and is in good standing with the granting authority:
completed a series of 3 examinations, possessed a bachelor's degree from an accredited institution ( or had an equivalent
education or work experience ), and at that time had 36 months of qualified professional work experience. CFA charter
holders are obligated to adhere to a strict Code of Ethics and Standards governing professional conduct.
Todd W. Solomon is not engaged in any other investment-related activities. He does not receive commissions,
Todd W. Solomon has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President
Ryan G. Tumbry
Born: 1977
Education
• University at Albany; B.S., Finance; 1999
Business Experience
• Congress Asset Management; Operations and Trading; from 10/2001 to 12/2005
• Abbott Personnel Consulting; Temp; from 05/2001 to 10/2001
• Abercrombie and Fitch; Manager; from 02/2000 to 05/2001
Mr. Tumbry joined Congress Asset Management in 2004 as an Operations Analyst responsible for portfolio
reconciliation, client requests, manager requests, and quarterly reporting. In this role he also joined the team that
supported two senior portfolio managers and assisted them with order entry for approximately 170 accounts. He
also interacted with clients. In 2006, he became the performance analyst and attribution analyst. In this role he
was responsible for the calculation, maintenance, and distribution of all firm data to interested parties. In 2007, he
became a research analyst responsible for performing financial and market analysis of public companies,
preparing quarterly earnings reports, and making formal presentations to the investment policy committees. His
current coverage is in the Technology and Telecomm sectors, and has previously covered the Utility, Consumer
Staples, and Pharmaceuticals & Biotech sectors. He is a member of the Mid Cap Investment Policy Committee.
Ryan G. Tumbry earned the following designation(s) and is in good standing with the granting authority:
Ryan G. Tumbry is not engaged in any other investment-related activities. He does not receive commissions,
Ryan G. Tumbry has no reportable disciplinary history. The senior research analyst supervises Mr. Tumbry in his
compilation and arrangement of financial data reported by public companies in order to make investment
Lawrence A. Ward
Born: 1931
Education
• Ohio State University; BS, Finance; 1957
The Finance major is designed to prepare students of financial management in all types of businesses, firm, and financial
institutions. Students take course work in corporate finance in which they study the effects of financial policy on
stockholder wealth. They study different types of investments and their relative merits, the role of financial institutions
including the study of asset and liability management, and investment management.
Business Experience
• Congress Asset Management; EVP & Chief Compliance Officer; from 1989 to Present
• Congress Trust, N.A.; Chairman; from 12/2006 to 11/2009
• Congress Trust, N.A.; President; from 02/2002 to 12/2006
• Putnam Advisory Company; Senior Vice President; from 01/1981 to 10/1987
• Montgomery Ward & Co., Inc.; Assistant Treasurer; from 09/1966 to 09/1980
Mr. Ward has over 47 years experience in the investment industry and has been employed with Congress Asset
Management, LLP since June 1989. Currently he is Executive Vice President, Chief Compliance Officer, a
member of the Management Committee, a member of the Large Cap Committee, and a member of the Fixed
Income Investment Policy Committee. In addition to the Chief Compliance Officer responsibilities, he manages
portfolios for institutions and individuals. The portfolios consist of securities approved by the investment policy
committees. The portfolios are structured to conform to the client guidelines emphasizing diversification to
minimize market and securities risk. As Chief Compliance Officer, he oversees the conformance of all employees
to the Code of Ethics, personal securities trading policy, firm policies and procedures, and regulations. The
Management Committee oversees the operation of the firm as well as its strategic direction. The Investment
Policy Committees select the securities to be used by the portfolio managers.
Prior to joining Congress Asset Management, LLP he was a Senior Portfolio Manager and member of the
Investment Policy Committee a Putnam Advisory Company. He managed portfolios for institutions that were
structured to conform to client investment guidelines using securities approved by the Investment Policy
Committee. In 1966 he joined Montgomery Ward & Company as Investment Manager of the Montgomery Ward
Retirement Trust, The Montgomery Ward Profit Sharing Trust, Pioneer Trust & Saving Bank, and Montgomery
Ward Life Insurance Company. His responsibilities included recommending investment policy, security selection,
and overseeing the implementation of those decisions. In 1970, he was promoted to Assistant Treasurer Investments of Montgomery Ward & Company with similar responsibilities. In 1976 he was named Managing
Trustee of the Montgomery Ward & Company Retirement Trust. In this role, he made investment policy
recommendations to the Trustees, selected securities for the portfolios, executed trades with the broker-dealer
community, supervised the implementation of all investment activity, and established the agenda for the Board of
Trustees monthly meeting.
Lawrence A. Ward earned the following designation(s) and is in good standing with the granting authority:
Lawrence A. Ward is not engaged in any other investment-related activities. He does not receive commissions, bonuses
or other compensation on the sale of securities or other investment products. He is not engaged in any other business or
Lawrence A. Ward has no reportable disciplinary history and all trades are reviewed daily by a member of the
Title: President

Part 2A of Form ADV: Firm Brochure Congress Asset Management

Transcription

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