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Lancaster: investment adviser
Lancaster Labs, LLC, doing business as Lancaster, is an investment adviser registered with the SEC (file 801-134850, CRD 339389). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $8.6M
- Discretionary
- 100%
- Accounts
- 25
- Employees
- 3
- In advisory roles
- 3
- Disclosures
- 0
SEC adviser record · Full Form ADV (PDF)
The firm reports no custody of client cash or securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| High net worth individuals | 25 | $8.6M | 100.0% |
How it is paid
- A percentage of assets under your management
Services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Lancaster Systematic, Inc. | Company (U.S.) | Manager | E 75% or more | Oct 2025 | Yes |
Indirect owners (Schedule B)
| Owner | Owns a stake in | Type | Stake | Control | Public company |
|---|---|---|---|---|---|
| James Vincent Perrello | Lancaster | Person | D 50% to 75% | Yes | |
| Ron Bezoza | Lancaster | Person | C 25% to 50% | Yes |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
Lancaster Labs ADV Part 2A - March 2026, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
Lancaster Labs, LLC (“Lancaster” or the “Firm”), headquartered in New York, New York, is a Delaware Limited Liability Company (“LLC”) that was formed in October 2025. The LLC is a wholly-owned subsidiary of Lancaster Systematic, Inc. (the “Company”), a company founded in September 2023 as a Delaware corporation. Lancaster is the investment advisory affiliate that leverages the Company’s proprietary software and algorithms. The units of Lancaster Labs, LLC are owned 100% by the Company. Listed below are the individuals and/or entities controlling 25% or more of the Company:
James Perrello, Chief Executive Officer Ron Bezoza, Chief Revenue Officer and Chief Compliance Officer
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Lancaster Labs, LLC provides discretionary investment management services to Clients. We are engaged both as a sub-advisor to wealth management platforms and wrap program sponsors and as a primary advisor to direct Clients. Our investment advisory services focus on quantitative fixed income investment strategies delivered to Client’s via separately managed accounts (“SMAs”) with a specialty in the systematic provision of market liquidity. We use proprietary technology that integrates artificial intelligence, quantitative analytics, algorithmic execution, and portfolio construction into a systematic and repeatable process. Our objective is to provide Clients with ongoing, tax-exempt income and the potential for enhanced total returns without taking on material additional interest rate or credit risk relative to each Strategy’s respective benchmark. Lancaster’s advice is limited to municipal bonds and other fixed income instruments. In certain situations, Lancaster may allow Clients to customize their account based on their unique circumstances; however, Lancaster is not obligated to offer this feature. Clients may place restrictions on their accounts, such as sell restrictions for certain securities or groups of securities. All restrictions must be provided to Lancaster in writing by the Client. Lancaster may decline to manage accounts where Client restrictions conflict with our investment process. Lancaster participates in certain wrap fee programs as a sub-advisor. We manage wrap accounts in the same manner as non-wrap (or “direct”) Client accounts, using the same strategies, research, and trading approach. Lancaster receives a portion of the overall wrap fee charged by the program sponsor in the form of an investment management fee as compensation for our advisory services. When serving as a sub-advisor, Lancaster relies on the Client’s financial or primary advisor or wrap program sponsor to review the Client’s investment objectives, risk tolerance, liquidity profile, and prior investment experience before recommending our Strategies. When acting as the primary advisor, Lancaster collects this information directly from each Client through a series of questions designed to assess suitability for investment in a Lancaster Strategy. As of December 31, 2025, Lancaster managed $0.0 million in Client assets on a discretionary basis and $0.0 million on a non-discretionary basis.
Item 5. Fees and compensation
Lancaster charges advisory fees as a percentage of assets under management. For separately managed accounts, our annual fee is generally 0.30% of assets under management plus performance fees, for qualified clients. Fees are negotiable in certain scenarios and may depend on factors, including but not limited to, account size, mandate complexity, and investment objectives. Performance-Based Fees: In addition, asset-based advisory fees, we may charge performancebased fees to qualified clients.
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A qualified client generally includes a natural person or company that has at least $1,200,000 under management with us immediately after entering into the advisory contract, or that has a net worth of more than $2,200,000 at the time the contract is entered into (excluding the value of the person's primary residence), or that is a qualified purchaser as defined under Section 2(a)(51)(A) of the Investment Company Act of 1940. Where performance-based fees are charged, the specific fee structure, including the performance hurdle rate, measurement period, high-water mark provisions, and applicable rates, will be set forth in the Client's individual investment advisory agreement. Performance-based fees are typically calculated based on realized and unrealized gains in the Client's account over the applicable measurement period, subject to a high-water mark to ensure that performance fees are not charged on the same gains more than once. Please see Item 6 (“Performance-based Fees and Side-by-Side Management”) for additional information regarding fees. Fees are typically billed monthly in arrears, unless the Client’s agreement provides otherwise. We may deduct fees directly from the Client’s custodial account or we may bill the Client, or the Client’s other advisor, directly. Wrap fee program sponsors typically handle billing. In these cases, we may receive our portion of the wrap fee directly from the sponsor. In wrap fee programs, Clients pay a single fee to the program sponsor. The sponsor then pays us a portion of that wrap fee for our advisory services. In addition to our advisory fees, wrap fee program Clients are responsible for custodial fees, brokerage fees and transaction costs, mutual fund or ETF expenses, and any other fees charged by third-party service providers. Please see Item 12 (“Brokerage Practices”) for additional information regarding brokerage costs. Clients in wrap fee programs should be aware that wrap fees may be higher or lower than the combined cost of purchasing advisory, brokerage, and custodial services separately. Clients should be aware that similar advisory services may be available from other investment advisers for similar or lower fees. ERISA Accounts: For employee benefit plans and individual retirement accounts (“IRAs”) that are an advisory Client, Lancaster is deemed to be a fiduciary pursuant to the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 (the "Code"). To avoid prohibited transactions, we only charge advisory fees for investment advisory services related to our products, or Strategies, and do not receive commissions or 12b-1 fees. We do not require or solicit payment of more than $1,200 in fees, six months or more in advance of services being provided. Clients may terminate their advisory agreement at any time by providing written notice. If services are terminated, we will promptly refund any prepaid but unearned fees. If fees are billed in arrears, a final pro-rated bill will be sent for services provided through the termination date. An executive of Lancaster, Ron Bezoza, has an outside business interest as a registered
representative of March Capital Corporation, a broker-dealer. Through this affiliation, Mr. Bezoza can receive commissions for certain activities, including the distribution of private funds, direct investment offerings, and the facilitation of investment banking transactions. Mr. Bezoza devotes less than five percent of his professional time to these outside activities. Because Mr. Bezoza can receive compensation in connection with the sale or distribution of certain investments, this creates a potential conflict of interest. Specifically, Mr. Bezoza could have an incentive to recommend products that generate commissions rather than those that are solely in the best interest of a Client. We address this conflict by disclosing the potential conflict of interest to Clients, ensuring that Clients are free to purchase investment products through other unaffiliated brokers or agents, maintaining internal oversight of recommendations to help ensure that investment advice remains aligned with Client needs and objectives, and restricting Mr. Bezoza from selling brokerage or public market fixed income products to clients of Lancaster. Mr. Bezoza may receive an economic benefit for providing advisory services to individuals who are not clients of Lancaster Labs, LLC. This economic benefit is based, at least in part, on the number or amount of sales, client referrals, or new accounts at March Capital Corporation as a result of Mr. Bezoza’s outside business activities. Clients should be aware that, while commissions may represent a portion of Mr. Bezoza’s outside compensation, they do not constitute any portion of Lancaster Labs, LLC’s revenue.
Item 6. Performance-based fees and side-by-side management
We may charge performance-based fees to certain eligible clients. As noted in Item 5, performance-based fees are only charged to "qualified clients" as defined under Rule 205-3 of the Investment Advisers Act of 1940, as amended. Not all clients are eligible for or subject to performance-based fee arrangements. Clients subject to performance-based fees will have the specific terms, including the applicable rate, hurdle rate, measurement period, and high-water mark provisions, set forth in their individual investment advisory agreement. Trade Allocation and Side-By-Side Management: We have trade allocation processes designed to address the conflicts of interest inherent in side-by-side management.
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Trade orders for the same security placed on behalf of multiple accounts on the same day will generally be aggregated where possible and allocated in a manner that is fair and equitable across all participating accounts over time. No account will be systematically favored in the allocation of aggregated orders. Our Chief Compliance Officer periodically reviews trade allocations across account types.
Item 7. Types of clients
We provide investment advice to individuals and families, high net worth individuals, and certain institutions acting on behalf of Clients (such as trusts, investment companies, pension plans or other advisory accounts). We establish accounts with Clients directly or through third parties. Accounts are generally managed on a discretionary basis. This means we make day-to-day investment decisions for the account in line with the Client’s investment management agreement. Please see Item 16 (“Investment Discretion”) for additional information regarding our discretionary authority. Our standard minimum account size is $250,000. We may waive this minimum at our discretion on a case-by-case basis. Accounts that fall below this level can be harder to manage effectively. In those cases, we may end our management services as allowed under the Client’s agreement.
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Accounts may be funded with cash or cash equivalents or in-kind with securities that are free of liens. We decide which securities are eligible for in-kind funding at account opening and on an ongoing basis with respect to in-kind contributions. Securities we do not accept will be transferred back to the Client. If a Client transfers in securities without prior notice, we may reject or sell those assets at our discretion. We are not responsible for any losses, taxes, or other consequences from unauthorized or improper transfers. Clients may terminate our services at any time. At the Client’s request, we may facilitate closing the account and liquidate the holdings or we may facilitate the transfer of holdings to an account specified by the Client. During the liquidation process resulting from account termination, any prior investment guidelines or restrictions will not apply to the account.
Item 8. Methods of analysis, investment strategies and risk of loss
Methods of Analysis: We use a quantitative and systematic approach to managing Client accounts. Our process combines more quantitative portfolio construction techniques with artificial intelligence. In evaluating securities, we analyze the Client’s account on a holistic basis and consider metrics such as geographic distribution, maturity profile and duration, call provisions, issuer and obligor concentration, credit ratings, sector allocations, and valuations relative to comparable securities. We may apply artificial intelligence and quantitative models to evaluate pricing and trading opportunities. These tools help us identify relative value, monitor market liquidity, and support systematic decision-making. Investment Strategy: Our primary focus is on intermediate-term municipal bonds. We seek to generate returns by:
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building diversified portfolios across sectors, geographies, and obligors using trading algorithms designed to provide liquidity in the market and capture potential execution-based opportunities actively buying and selling bonds when relative value shifts are identified
Our investment approach is active and trading-oriented, meaning accounts will typically experience frequent turnover. Trading frequency may vary depending on market conditions, cash flows, and the specific characteristics of a Client’s account. Because our strategy involves frequent trading, Clients may experience higher realized capital gains, leading to higher taxes as well as potentially increased brokerage commissions and transaction costs. We believe that our active and systematic approach can provide opportunities for enhanced returns, but there can be no assurance that these strategies will be successful. Lancaster does not guarantee the performance of any investment strategy or Client account. Past performance is not indicative of future returns. Investing in securities carries inherent risks, and a Client may lose part or all of their invested capital. Clients should only commit capital they can afford to lose. The risks described in this Brochure are not exhaustive; other risks, including those not currently foreseeable or contained in this document, may also adversely affect Client account performance. Market and Investment Risks:
Market Risk: The value of securities held in a Client account fluctuate with market conditions and may rise and fall day to day, so investments may lose value. Investment Risk: All securities involve risk. There is no assurance that any particular security, asset class, or investment strategy selected by Lancaster will be profitable, will equal any specific performance level(s), or achieve a Client’s investment goals. Different securities carry varying levels of risk, and the same security may present different risks at different times. A Client may lose some or all their investment. Risk of Loss: Securities investments are not guaranteed and you may lose money on your investments. Fixed Income Security Risks: Interest Rate Risk: Fixed-income securities typically decline in value when interest rates rise and increase in value when rates fall. Duration is a common measure of interest rate risk. Duration measures a bond’s expected life on a present value basis, taking into account the bond’s yield, interest payments and final maturity. Longer-tenor bonds and bonds with higher duration generally have higher price sensitivity to interest rate changes than shorter-maturity securities. Credit Risk: Credit risk measures the possibility that a debt issuer will fail to make required principal or interest payments and the related risk that the value of a security may decline due to concerns about the issuer's ability to make such payments. A downgrade in the credit rating of an issuer, or broader concerns about its financial condition, may also cause the market value of its bonds to fall. Default Risk: If an issuer fails to meet its required interest or principal payment obligations, a Client account may face significant loss of income as well as principal. Defaults can result in substantial losses and are not limited to below-investment-grade issuers. Income Risk: A Client’s income from fixed-income holdings may decline if prevailing interest rates fall. Prepayment Risk: Issuers may repay bonds prior to maturity, particularly when interest rates fall. Debt securities frequently have call features that allow the issuer to repurchase the security prior to its stated maturity. An issuer may redeem an obligation if it can refinance the debt at a lower cost due to declining interest rates or an improvement in the issuer’s credit rating. This requires reinvestment of principal at lower rates, which can reduce income. Extension Risk: During periods of rising interest rates, the average life of certain types of securities may be extended because of lower than expected principal payments. This may lock in a below market interest rate, increase the security's duration and reduce the value of the security. This is known as extension risk. Reinvestment Risk: Refers to the possibility that an investor will have to reinvest their interest payments or principal at a lower rate than the current rate, especially during a period of declining interest rates. This occurs because new fixed-income investments may offer lower yields, leading to reduced future income for the investor. Duration Risk: Duration is a measure that relates the expected price volatility of a fixed income security to changes in interest rates. The duration of a fixed-income security may be shorter than or equal to the full maturity of a fixed-income security. Fixed-income securities with longer durations have more risk and will decrease in price as interest rates rise. Inflation Risk: The value of assets or income from investments may be lower in the future as
inflation decreases the value of money. As inflation increases, the value of a portfolio’s assets can decline, as can the value of a portfolio’s distributions. Event Risk: Event risk in fixed income investing refers to the potential for a sudden, unexpected, and significant decline in a security's value due to an unusual event. Unlike systemic risks such as interest rate and inflation risk, event risk is typically isolated, and can be specific to a single issuer, industry, or region. Municipal Bond Risks: Municipal Market Risk: Economic conditions, political or legislative changes, public health crises, uncertainties related to the tax status of municipal securities, or the rights of investors in these securities may negatively impact the yield or value of a municipal security. Tax Risk: Federal, state, or local governments may alter tax laws, potentially reducing or eliminating the tax-exempt interest income benefits associated with certain or all municipal securities. Municipal Issuer Risk: Municipal issuers vary widely in financial strength and disclosure practices. Some issuers may fail to provide sufficient financial information, limiting transparency. Investment Strategy Risks: Investment-Grade Risk: Investment-grade municipal bond ratings may be downgraded, potentially reducing their value. Ratings are opinions, are subject to change and are not guarantees of credit quality. Non-Diversification Risk: A strategy that invests in fewer securities may experience greater risk because it is "non-diversified", as changes in one security's value may have a more significant effect on account performance. Intermediate Duration Risk: A strategy focused on intermediate duration fixed-income securities may earn less income and may provide lower total returns than longer duration strategies. New Strategy Risk: A newly launched, or soon to be launched, strategy has no performance track record. Actual outcomes may differ significantly from expectations. Benchmark Risk: Using existing benchmarks as a reference point for investing decisions doesn’t guarantee performance that is similar to that of the benchmarks. At any point in time, Lancaster’s investment decisions may lead to a portfolio to underperform the market and / or its benchmark, especially depending on the preferences and customizations selected by the Client. Frequent Trading and Turnover Risk: High turnover may increase transaction costs and trigger adverse tax consequences for Client accounts. Hypothetical Performance Risk: Back-tested or simulated performance is inherently limited. It does not reflect actual market conditions, trading costs, or investor behavior, and should not be relied upon as indicative of future performance. Illiquid Investment Risk: Illiquid investment risk exists when certain investments are or become difficult to purchase or sell. Difficulty in selling such investments may result in sales at disadvantageous prices, affecting the value of your investment in the Strategy. Technology, Data, and Model Risks: Quantitative Model Risk: Lancaster uses proprietary and third-party models to inform investment decisions. Models rely on assumptions, historical data, and judgment in their construction. Broadly
speaking, models used by Lancaster have inherent limitations, including the possibility of design and data input errors. Our models may fail to keep up with changes in markets and the behavior of market participants over time. Risks of unintended errors and malfunctions are inherent in each component of the programming process. Lancaster will, from time to time, make changes to the investing algorithms and services that it provides. Additionally, it is possible that Lancaster itself may experience computer equipment failure, loss of internet access, computer viruses, cyberattacks, or other events that prevent access to Lancaster’s software-based service. Artificial Intelligence Risk: Lancaster and certain third parties may employ artificial intelligence (“AI”) in business or investment processes. AI models are highly complex and may generate inaccurate or biased outputs, disclose confidential data, take incorrect actions, or raise intellectual-property and compliance issues. Lancaster may have little to no visibility over the accuracy and completeness of such models from third parties. The regulatory environment for AI is evolving and could increase compliance burdens. Malicious actors may also misuse AI to attack financial systems. External Vendor Risk: Lancaster relies on data, software, and services provided by third parties. Errors, malfunctions, or discontinuation of such services may impair account management necessitating a change in Lancaster's methodology without advance notice. Data Source Risk: Data sourced from third-party vendors or services may be inaccurate or unavailable. Failure of a vendor to provide data used by Lancaster may negatively impact the performance of a Client Account. Electronic Trading Risk: Electronic platforms may experience system outages, slowdowns, or breaches. These may lead to varying response times or delayed execution, missed opportunities, security issues, or erroneous trades. Operational and Organizational Risks: Operational Risk: Failures in Lancaster’s systems, processes, or personnel, or in those of its service providers, may lead to losses in Client accounts. Conflicts of Interest: Lancaster’s business activities may create conflicts that disadvantage certain Client accounts while benefiting others. Lancaster seeks to mitigate conflicts, but not all conflicts can be eliminated. Valuation Risk: Securities that lack active markets may be valued using models or dealer quotes. Such estimates may prove inaccurate and differ or affect reported Client account values. Cybersecurity Risk: Lancaster and its service providers may suffer data breaches or cyberattacks. Such incidents may expose Client information, disrupt services, or cause losses to Clients and Client accounts. Key Personnel Risk: Lancaster’s success depends heavily on certain professionals. Loss of key personnel may disrupt operations. Force Majeure: Client account investments may be vulnerable to a force majeure event, including acts of God, war and strike, which could result in the loss of profitability for the investments. Legal, Regulatory, and Counterparty Risks: Legislative & Regulatory Risk: Client account performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to, changes in investment advisor or securities trading regulation, and changes in the tax code.
Counterparty Risk: Accounts may be exposed to the credit risk of counterparties, including brokers, dealers, custodians, and clearing agents. A counterparty’s failure to perform could cause losses within Client accounts. Other Risks: Disclosure Limitations: This summary does not cover every possible risk associated with investing in a Lancaster strategy. Markets evolve, strategies change, and new risks emerge over time. No assurances can be made that profits will be achieved, or that substantial losses will not be incurred. Lancaster’s ability to evaluate market behavior may prove to be incorrect, resulting in a significant or total loss of Client and/or End Investor capital. Lancaster may also make future changes to the technology and data employed or change the approach to portfolio management, resulting in different outcomes than anticipated. Clients should carefully consider their own risk tolerance before investing.
Item 9. Disciplinary information
Lancaster 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
Broker-Dealer Registration: March Capital Corporation is a registered broker-dealer. Certain of Lancaster’s management persons are registered representatives of March Capital Corporation and act in such capacities if necessary or appropriate to perform their responsibilities. None of the Adviser, any affiliate, nor their employees are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading Adviser, or a representative of the foregoing. The Adviser does not receive, directly or indirectly, compensation from investment advisers that it recommends or selects for its Clients.
Item 11. Code of ethics, participation in client transactions and personal trading
An executive of Lancaster, James Perrello, serves as an Advisor of SOLVE, a company providing pre-trade fixed income pricing data. Mr. Perrello does not own shares of SOLVE. In addition, Lancaster is a Client of SOLVE. There is no financial incentive provided to Lancaster for the usage of SOLVE’s services. Mr. Perrello also serves as an Advisor of MultiLynq, a company providing electronic fixed income trading technology. Mr. Perrello owns shares of MultiLynq, which in total is less than 5% of MultiLynq’s outstanding shares. In addition, Lancaster is a client of MultiLynq though Mr. Perrello will not be compensated by MultiLynq for Lancaster’s usage of MultiLynq’s services. Mr. Perrello can receive an economic benefit for providing services to individuals who are not clients of Lancaster Labs, LLC. These services provided do not constitute investment
Read the rest of Item 11 (142 more words)
advisory services. This economic benefit is based, at least in part, on the number or amount of sales or client referrals to MultiLynq as a result of Mr. Perrello’s outside business activities. These activities represent less than five percent of Mr. Perrello’s time and income and are thus not considered substantial. Lancaster has adopted a Code of Ethics that applies to all employees. The purpose of the Code is to help ensure that employees’ personal securities transactions do not conflict with transactions made on behalf of Clients. Employees must provide the Firm’s Chief Compliance Officer (“CCO”) with copies of all brokerage and investment accounts in which they hold a beneficial interest on a regular basis. Our Code of Ethics is available to Clients and prospective Clients upon request. To obtain a copy, please contact our Chief Compliance Officer, Ron Bezoza, at ron@lancaster.am.
Item 12. Brokerage practices
Lancaster executes municipal bond transactions in the over-the-counter market, where trades are typically handled on a “trade-away”, or “prime brokerage”, basis rather than routed through the Client’s custodian. The negotiated price may include a broker/dealer mark-up or mark-down, which is the final price shown on the Client’s account statement. Lancaster does not charge any additional fee for these trades. Custodians usually assess a flat ticket fee for each transaction, though the amount can vary based on account size and trading activity. In some cases, a custodian may instead apply an asset-based fee. Factors in Selecting Broker-Dealers: Because municipal bonds trade in a fragmented market, Lancaster works with many broker/dealers over the course of a year.
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Different broker/dealers may provide better liquidity or pricing depending on market conditions and the characteristics of a security. Importantly, the broker/dealer offering the lowest cost is not always the one providing best execution. In seeking the most favorable results for Clients, Lancaster considers multiple factors, including:
Availability of suitable securities The type of security being traded and overall market activity Desired timing of the transaction Prevailing bid/ask spreads and market levels of comparable securities The financial stability, execution quality, and settlement capabilities of the broker/dealer The broker/dealer’s responsiveness and reliability
Our goal is to ensure that the total cost of each transaction is favorable to clients, balancing price, broker/dealer capabilities, execution quality, and market conditions. Directed Brokerage: We typically do not accept Client-directed transactions. If a Client requires directed transactions, the Client should understand that:
The account may pay higher transaction costs. The account may receive less favorable execution prices.
Aggregation and Allocation of Orders: When buying or selling the same security for multiple accounts, Lancaster may - but is not obligated to - aggregate orders. Aggregation may impact pricing and execution efficiency. If an aggregated order is only partially filled, securities may be allocated pro rata across participating accounts or allocated in another manner at Lancaster’s discretion. Allocation decisions consider portfolio characteristics such as duration relative to target levels, representation in Lancaster strategies, existing holdings of the same obligor, and state or
sector exposures, among other metrics. Over time, our objective is to provide fair and consistent treatment across accounts. When selling bonds held across several accounts, participation in the sale is determined by each account’s portfolio target levels, composition, and realized turnover. Lancaster does not swap bonds between unrelated accounts. In addition, Lancaster may sequence or rotate trades among accounts under our systematic allocation policies. These policies are designed to ensure fairness over time while allowing us to adjust order submission aggressiveness based on account-specific factors. As a result, execution prices may differ between accounts. Exceptions to Aggregation: In some situations, we may not aggregate orders. In these cases, Clients may not benefit from potential pricing or cost advantages that aggregation could otherwise provide. Soft Dollar Benefits: Lancaster does not receive proprietary research, soft dollar benefits, or other products or services from broker-dealers in exchange for Client trades. From time to time, we may receive general market commentary or research that broker-dealers provide broadly to market participants. These materials are not tied to Client transactions. Brokerage for Client Referrals: Lancaster does not select or recommend broker-dealers in exchange for Client referrals.
Item 13. Review of accounts
Individuals from Lancaster’s Leadership and Portfolio Management teams review Client accounts on a regular basis. Reviews are conducted either by individual portfolio managers or by the team as a group, depending on account needs and market conditions. The review process is systematic in nature and occurs continuously throughout the day using advanced analytics. Potential events triggering a review include securities transactions as well as changes in cash reserves of an account. During these reviews, we consider:
investment objectives account performance current security positions and new investment opportunities portfolio guidelines and liquidity needs, if applicable
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Compliance with investment guidelines is generally assessed at the time securities or other investments are purchased, but may also be assessed on an ad-hoc basis. Factors That Trigger Additional Reviews: In addition to ongoing continuous reviews, we may review an account when specific circumstances arise. Examples may include significant changes in market conditions, changes in the securities held in the account, or updates to a Client’s investment objectives, policies, or restrictions. Client Reports: Clients with separately managed accounts may receive written reports regarding their account from Lancaster on a monthly or quarterly basis, or as otherwise agreed with the Client.
Item 14. Client referrals and other compensation
Lancaster may compensate persons for Client referrals. If referral fees are paid to a third party, these referral fees are paid by Lancaster and not the Client.
Item 15. Custody
We do not take possession of Client funds or securities. All Client assets are held with a qualified custodian, such as a broker/dealer or bank, selected by the Client. While we may have existing relationships with certain custodians, the choice of custodian is ultimately made by the Client. When we buy or sell securities, we instruct the broker/dealer to deliver the securities directly to the custodian of the Client’s account for settlement. Our advisory fees are usually deducted directly from Client accounts. We submit requests for advisory fee payments to the custodian, who will then process payment. These arrangements are documented in the advisory agreement signed by both the Client and our Firm.
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Clients receive account statements at least quarterly from their custodian or wrap program sponsor. These statements list transactions, holdings, and account values. In some cases, we may also provide Clients with our own reports summarizing exposures and performance. Important Note: If Clients receive a report from us, they should carefully compare it with the official statements they receive from their custodian. The custodian’s statement is the official record of the Client’s account.
Item 16. Investment discretion
Clients grant us discretionary authority to manage their accounts. When authorized, we may, without prior consultation:
select securities to buy or sell; and/or determine trade amounts; and/or select brokers or dealers to be used for security purchases or sales; and/or determine the prices, commissions, and/or mark-ups/mark-downs to be paid to a broker or dealer for a securities transaction
Discretionary authority is granted through execution of a discretionary portfolio management or sub-advisory agreement with Lancaster. Clients may limit our discretionary authority in certain instances by providing us with written instructions with respect to certain security restrictions. These restrictions may be amended by the Client at any time by providing us with additional written instructions.
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All proposed guidelines and/or restrictions are reviewed prior to account acceptance and opening for new accounts as well as for new restrictions or restriction amendments for existing accounts. Approved restrictions are recorded in our systems. We may decline restrictions we deem unduly limiting or inconsistent with our investment philosophy and processes. Accounts subject to restrictions may experience investment results that differ, potentially materially, from other accounts managed in the same strategy which do not have restrictions. Clients should understand that investment restrictions may limit our ability to implement investment strategies effectively and may increase risks, reduce diversification, or adversely affect performance.
Item 17. Voting client securities
The securities we purchase for Clients, such as municipal bonds, do not involve proxy voting. As a result, we generally do not vote proxies and we ask Clients to vote directly on their own behalf.
Item 18. Financial information
Lancaster does not require or solicit pre-payment of more than $1,200 in fees per Client, six months or more in advance. Lancaster has never filed for bankruptcy and is not aware of any financial condition that is expected to impact meeting its contractual commitments to its Clients.
Other brochures on file
- Lancaster Labs ADV Part 2B - March 2026, Jul 20, 2026
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.