F L PUTNAM INVESTMENT MANAGEMENT CO.

Data as of: 04/10/2026
FL
Address
6 KIMBALL LANE
LYNNFIELD, MA 01940
SEC Approved Registration: July 30, 1984
Employees: 160
Investment Advisory Staff: 90

Staff performing investment advisory functions and research

Leadership

STAUFFER, SUSANNE

DIRECTOR

10/2014

FLAHERTY, ELLEN

DIRECTOR, CLERK, SR. VP, COO

12/2001

GOSULE, ALAN, LEE

DIRECTOR

01/2008

LEPPER, MEREDITH

DIRECTOR

01/2008

OSTERBERG, RICHARD

DIRECTOR

01/2008

MANNING, REED, THOMAS

PRESIDENT, CHIEF EXECUTIVE OFFICER, DIRECTOR

12/2015

TIMMERMANS, MICHAEL, SCOTT

CHIEF LEGAL OFFICER

10/2021

MARKS, KEITH, STANLEY

CHIEF COMPLIANCE OFFICER

10/2025

Advisory Overview

A. Description of Advisory Firm
F.L.Putnam Investment Management Company (FLP) provides discretionary and non-discretionary investment management, investment advisory, investment consulting, and financial planning services. We have a diverse clientele that includes individuals and their families as well as foundations, endowments, secondary schools, educational institutions, religious organizations, corporations, registered investment companies, and other investment advisers. We were founded in 1983 and have been registered as an investment adviser with the Securities and Exchange Commission since 1984. Registration as an investment adviser does not imply a certain level of skill or training. FLP is majority-owned by F.L. Putnam Securities Company, Inc., a domestic corporation incorporated under the laws of the Commonwealth of Massachusetts. Our offices are in Lynnfield, Needham, Mashpee, and Boston, Massachusetts; Portland, Maine; Wolfeboro, New Hampshire; Providence, Rhode Island; Reston, VA; and Amherst and New York, New York. FLP acknowledges that it is a fiduciary, with respect to its clients, within the meaning of that term under ERISA.

B. Types of Advisory Services
Our primary business activity is to provide investment advisory and investment management services to individual and institutional clients on a discretionary basis and financial planning services for individuals and their families. We provide investment advisory services to registered investment companies, including the AOG Institutional Fund, which we sponsor and advise. We provide investment management services to some clients on a non-discretionary basis. Additionally, we assist clients with a wide range of investment consulting services. We do not provide brokerage services involving the buying and selling of financial products such as mutual funds, annuities, or insurance for transaction-based compensation.

C. Tailored Investment Management and Advisory Services
Investment Management and Advisory Services
Our investment management and investment advisory services are tailored to the individual needs of each client based on information that each client has provided to us. We provide ongoing and continuous reviews of investment management accounts for institutional and non-institutional clients. Clients may impose investment restrictions on investing in certain securities or types of securities or may direct FLP to hold certain securities. Our first step in working with our clients is to gather information that will help clients define realistic investment goals, determine income needs, and assess the appropriate level of investment risk and loss a client is willing and/or able to assume. We then develop a written investment policy statement that is reviewed with each client, or we review a clients existing investment policy statement. The written investment policy statement serves as a guide for the management of a client's account by the assigned investment advisor(s). Each non-institutional client is typically assigned a team consisting of a client advisor and/or an investment advisor, and an account administrator. Each institutional client is typically assigned a team consisting of a primary portfolio manager, and/or a supporting investment advisor, and an account administrator.

Each clients allocation to equities, fixed income, cash, and alternative investments is based upon their individual goals and objectives, taking into consideration their investment time horizon, risk tolerance, return requirements, income and liquidity needs, as well as other considerations that are unique to that client. The result of this process is a portfolio that is constructed around each clients goals with the flexibility to address shorter term risks and opportunities as they emerge.

We leverage internally managed and third-party investment strategies to create customized portfolios to meet each clients unique needs. These options span equity, fixed income, and alternative investment asset classes, delivered through individual securities, exchange traded funds, third-party managers, and externally managed mutual funds. We will select our proprietary mutual fund, AOG Institutional Fund (AOGFX), for some client accounts. FLP is compensated for its investment management of AOGFX based upon a percentage of the assets of the fund. Because this fee for fund investment management will be higher than the investment management fee otherwise assessed to clients for FLPs management of the assets of their account not allocated to the fund, FLP has a conflict of interest when we select AOGFX for our clients. As in all cases, when managing assets on behalf of its clients, FLP will only make a client investment in AOGFX when it believes such investment is in the best interests of its clients and aligns with their respective investment objectives, restrictions and goals.

FLP uses a third-party platform to facilitate discretionary management of assets held in client accounts that are part of defined contribution plans (including, for example, 401k and HSA participant accounts) (Held Away Accounts). Through the third-party platform, FLP does not have direct access to any client log-in credentials to affect trades. FLP is not affiliated with the platform and receives no compensation from the platform. FLP does pay a fee to the platform provider. For clients that hire FLP to manage their defined contribution plans, a link is provided to the client that allows them to connect their account(s) to the platform. Once a client account(s) is connected to the platform, FLP will have access to review the current account allocations and investment options, and to rebalance or reallocate the account based upon the clients investment goals and risk tolerance. FLP will review the account on an ongoing basis and will make any changes to the account to meet the requirements of each client based on information that the client has provided to us.

FLP has a long-standing practice in socially responsible investing. Many clients are concerned with the religious, ethical, social justice, environmental, and other non-financial aspects of their investments. These concerns differ from client to client. Clients can exclude (or include) particular activities from their investment portfolios. Within portfolios applying a socially responsible investing approach, we select investments that we believe will provide the potential for a favorable return but are also consistent with those beliefs and ethical preferences that clients have made known to us. FLP provides clients with periodic reports describing the applicable non-financial aspects of each company in their portfolios. Clients must request these services. We continuously communicate with our clients, but clients must notify us about any changes in their financial circumstances and needs so that we can take these changes into consideration when managing their portfolio(s).

Financial Planning
FLP offers financial planning services to our individual and family clients, which may cover investment analysis, income tax planning, insurance analysis, retirement planning, education funding, estate planning, cash flow analysis, assistance with budgeting, and preparation of personal balance sheets as well as numerous other items related to a clients financial profile. Financial planning services can be provided in conjunction with our investment management and advisory services or can be provided on a standalone basis. Based upon a review of information and data provided by the client, a written plan or other agreed-upon deliverable will be prepared that includes our analysis of each clients current financial conditions, proposed changes, or recommendations. We recommend that clients review their financial plan at least annually or following any significant change to their personal or financial circumstances. We do not provide any accounting, tax, or legal advice and we do not prepare any financial statements, tax returns, or legal documents in connection with the implementation of any financial plan.

Standalone financial planning services are rendered only after a written agreement for such services has been executed. The written agreement specifies the parties to the agreement, the date of the agreement, its duration, how and on what terms the agreement may be terminated, and the scope of the services to be provided. After delivery of a written plan or other financial planning product each standalone financial planning client is responsible for the implementation, acceptance, or rejection of the recommendations included in the written plan or other financial planning product. FLP does not have a duty to update the financial planning services, plans, or recommendations, unless such duty is specifically addressed in our client agreements. If there are any material changes in the clients financial circumstances and needs during the course of a project, clients must update FLP so that we can take these changes into consideration.

DPL Financial Partners, LLC (DPL) is a third-party provider of a platform of insurance consultancy services to its clients with a current or future need for insurance products. DPL offers FLP membership to its platform for a fixed annual fee and, through DPLs licensed insurance agents who are also registered representatives of The Leaders Group, Inc. (The Leaders Group), an unaffiliated SEC-registered broker-dealer and FINRA member, offer FLP a variety of services relating to fee-based insurance products. These services include, among others, providing FLP with applications to assist in evaluating insurance needs, educating and acting as a resource to members regarding insurance products generally and specific insurance products owned by their clients or that their clients are considering purchasing, and providing members access to and product marketing support regarding fee-based products that insurers have agreed to offer through DPLs platform. For providing platform services to FLP, DPL receives service fees from the insurers that offer their fee-based products through the platform and a fee from FLP for being a member of the platform. These service fees are based on the insurance premiums received by the insurers. DPL is licensed as an insurance producer in Kentucky and other jurisdictions where required to perform the platform services. Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers offering their products through the platform, and registered representatives of The Leaders Group. Since FLP can earn fees for the investment management of a portfolio within the insurance product a client selects, to the extent FLP believes the client will hire FLP to manage the investment options contained within an insurance product, FLP has a conflict of interest in recommending such insurance product.

Separately Managed Accounts
FLP provides separately managed account (SMA) services on a fully discretionary basis. Clients using its SMA services do not receive additional investment advisory services described above. After gaining an understanding of a clients particular investment objectives, assets are invested in accordance with one of FLPs SMA equity or fixed income strategies, including our socially responsible and thematic sustainable strategies. Clients may impose investment restrictions on investing in certain securities or types of securities.

AOG Institutional Fund (AOGFX)
AOGFX is a Delaware statutory trust that is registered under the Investment Company Act of 1940, as amended (the 1940 Act). AOGFX operates as an interval fund. FLP is the sponsor of AOGFX and has been retained by AOGFX to serve as its investment adviser, subject to the supervision of AOGFXs Board of Trustees. In this role, FLP provides continuous asset management services to the fund, including coordinating the day-to-day investment and operational activities of the fund, and working with the funds service providers. AOGFX invests in assets designed to provide exposure to a mix of private, institutional illiquid alternative/ non-traditional investments, supplemented by a liquid investment allocation. The fund invests in both income-producing assets and assets selected for long-term capital appreciation. AOGFX invests in a variety of alternative investment vehicles including private equity, venture capital, private credit and debt instruments, and real estate. FLP actively sources investment opportunities for the fund, leveraging its investment research and due diligence experience investing in alternative investments.

FLP Atrato Consulting
FLP Atrato Consulting offers customized services to clients, including investment advisory, due diligence, portfolio construction, risk analysis, and monitoring of new or existing portfolios. FLP Atrato Consulting provides various financial consulting services including, but not limited to, third-party manager due diligence, evaluation, selection and monitoring, advisor oversight, asset allocation advice, client reporting, investment policy design, and portfolio review services.

FLP assists its clients in identifying various private investment funds by performing manager due diligence and by constructing and monitoring customized portfolio solutions. In addition, FLP works with independent wealth managers and advisors to augment their capabilities in providing alternative investment advisory solutions to their underlying clients. After consultation with FLP, the client, when investing in any fund, will invest directly in such fund and will enter a direct contractual relationship with such fund or its general partner.

Schwab Institutional Intelligent Portfolios
In addition to our standard investment approaches, our firm also provides portfolio management services through Institutional Intelligent Portfolios, an automated, online investment management platform for use by independent investment advisors and sponsored by Schwab Wealth Investment Advisory, Inc. (the Program and SWIA, respectively). Through the Program, we offer clients a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange traded funds (ETFs) and a cash allocation. The clients portfolio is held in a brokerage account opened by the client at SWIAs affiliate, Charles Schwab & Co., Inc. (CS&Co). FLP is independent of and not owned by, affiliated with, or sponsored or supervised by SWIA, CS&Co or their affiliates (together, Schwab). The Program is described in the Schwab Wealth Investment Advisory, Inc. Institutional Intelligent Portfolios Disclosure Brochure (the Program Disclosure Brochure), which is delivered to clients by SWIA during the online enrollment process.

FLP, and not Schwab, is the clients investment advisor and primary point of contact with respect to the Program. Our firm is solely responsible, and Schwab is not responsible, for determining the appropriateness of the Program for the client, choosing a suitable investment strategy and portfolio for the clients investment needs and goals, and managing that portfolio on an ongoing basis. SWIAs role is limited to delivering the Program Disclosure Brochure to clients and administering the Program so that it operates as described in the Program Disclosure Brochure.

FLP has contracted with SWIA to provide it with the technology platform and related trading and account management services for the Program. This platform enables us to make the Program available to clients online and includes a system that automates certain key parts of the FLP investment process (the System). The System includes an online questionnaire that helps us determine the clients investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that FLP will recommend a portfolio via the System in response to the clients answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but our firm then makes the final decision and selects a portfolio based on all the information FLP has about the client. The System also includes an automated investment engine through which our firm manages the clients portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). FLP does not receive a portion of a wrap fee for our services to clients through the Program. Clients do not pay fees to SWIA in connection with the Program, but FLP does charge clients a fee for its services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to Schwab as part of the Program. Schwab does receive other revenues in connection with the Program, as described in the Program Disclosure Brochure. FLP does not pay SWIA fees for its services in the Program so long as we maintain $100 million in client assets in accounts at Schwab that are not enrolled in the Program. If FLP does not meet this condition, then we must pay SWIA an annual fee of 0.10% (10 basis points) on the value of FLP clients assets in the Program. This is a conflict of interest because the fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Program be maintained with Schwab. See Item 12 below for a description of FLPs broker and custodian recommendations.

The Program Disclosure Brochure includes a discussion of various risks associated with the Program, including the risks of investing in ETFs, as well as risks related to the underlying securities in which ETFs invest. In addition, the Program Disclosure Brochure also discusses market/systemic risks, asset allocation/strategy/diversification risks, investment strategy risks, trading/liquidity risks, and large investment risks.

D. Participation in Wrap Fee Programs
We do not participate in any wrap fee programs.

E. Amount of Client Assets Managed on a Discretionary Basis
The amount of assets under our discretionary management as of December 31, 2025: $9,639,734,328
The amount of assets under our non-discretionary management as of December 31, 2025: $75,698,845
The additional amount of assets under our advisement as of December 31, 2025: $4,278,492,475

Data Source: The information presented on this profile is sourced from the firm's Form ADV and ADV Part 2 Brochure documents filed with the SEC.OCIO Analytics makes every effort to ensure the accuracy of this information but cannot guarantee its completeness or accuracy. For the most current and comprehensive information, please contact the firm directly.

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