CADENT CAPITAL ADVISORS, LLC

Cadent Capital Advisors, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Cadent Capital Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (918) 935-3450 or by email at: brett@cadcapital.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Cadent Capital Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Cadent Capital Advisors, LLC’s CRD number is: 169704. 4525 East 91st Street Tulsa, OK 74137 (918) 935-3450 www.cadcaptial.com brett@cadcapital.com Registration does not imply a certain level of skill or training. Version Date: 07/07/2025  Item 2: Material Changes There following are material changes in this brochure from the last annual updating amendment of Cadent Capital Advisors, LLC on 01/31/2024. Material changes relate to Cadent Capital Advisors, LLC’s policies, practices or conflicts of interests only. Item 4B: Added Divorce Financial Planning Service Item 5A: Added additional details on how Portfolio Management fees are calculated Item 5A: Added Divorce Financial Planning Service Fee ii  Item 3: Table of Contents Contents Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................7 A. Description of the Advisory Firm ................................................................................................................7 B. Types of Advisory Services ...........................................................................................................................7 Portfolio Management Services .....................................................................................................................7 Selection of Other Advisers ............................................................................................................................8 Subadviser Services .........................................................................................................................................8 Retirement Plan Consulting Services ............................................................................................................8 Advisory Services to Brokerage Customers ................................................................................................8 Financial Planning ...........................................................................................................................................8 Services Limited to Specific Types of Investments .....................................................................................9 Written Acknowledgement of Fiduciary Status ..........................................................................................9 C. Client Tailored Services and Client Imposed Restrictions ......................................................................10 D. Wrap Fee Programs ......................................................................................................................................10 E. Assets Under Management ..........................................................................................................................10 Item 5: Fees and Compensation ...........................................................................................................................10 A. Fee Schedule ............................................................................................................................................10 Portfolio Management Services Fees ..........................................................................................................10 Selection of Other Advisers Fees .................................................................................................................11 Subadviser Services Fees ..............................................................................................................................11 Pension Consulting Services Fees ...............................................................................................................11 Advisory Services to Brokerage Customers Service Fees ........................................................................12 Financial Planning Fees ................................................................................................................................12 B. Payment of Fees .............................................................................................................................................12 Payment of Portfolio Management Fees ....................................................................................................12 Payment of Selection of Other Advisers Fees ............................................................................................12 Payment of Pension Consulting Services Fees ..........................................................................................13 iii  Payment of Financial Planning Fees ...........................................................................................................13 C. Client Responsibility for Third Party Fees ................................................................................................13 D. Prepayment of Fees ......................................................................................................................................13 E. Outside Compensation For the Sale of Securities or Other Investment Products to Clients .............13 1. This is a Conflict of Interest ...............................................................................................................13 Clients Have the Option to Purchase Recommended Products From Other Brokers or 2. Insurance Agents ...........................................................................................................................................14 3. Commissions are not the Primary Source of Income for CCA .....................................................14 4. Advisory Fees in Addition to Commissions or Markups ..............................................................14 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................14 Item 7: Types of Clients ........................................................................................................................................14 Minimum Account Size ................................................................................................................................14 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .....................................15 A. Methods of Analysis and Investment Strategies ................................................................................15 Methods of Analysis ......................................................................................................................................15 Charting analysis ...........................................................................................................................................15 Fundamental analysis ...................................................................................................................................15 Technical analysis ..........................................................................................................................................15 Investment Strategies ....................................................................................................................................15 B. Material Risks Involved .........................................................................................................................15 Methods of Analysis ......................................................................................................................................15 Fundamental analysis ...................................................................................................................................15 Technical analysis ..........................................................................................................................................16 Investment Strategies ....................................................................................................................................16 C. Risks of Specific Securities Utilized ......................................................................................................17 Item 9: Disciplinary Information .........................................................................................................................19 A. Criminal or Civil Actions .......................................................................................................................19 B. Administrative Proceedings ..................................................................................................................19 C. Self-regulatory Organization (SRO) Proceedings ...............................................................................19 Item 10: Other Financial Industry Activities and Affiliations .........................................................................19 A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................................19 iv  Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ................................................................................................................................................19 C. Related CPA .............................................................................................................................................19 D. Advisory Services to Brokerage Customers ........................................................................................20 Registration Relationships Material to this Advisory Business and Possible Conflicts of E. Interests ...............................................................................................................................................................20 F. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................................................................................................................................21 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............21 A. Code of Ethics ..........................................................................................................................................21 B. Recommendations Involving Material Financial Interests ...............................................................21 C. Investing Personal Money in the Same Securities as Clients ............................................................22 D. Trading Securities At/Around the Same Time as Clients’ Securities .............................................22 Item 12: Brokerage Practices ................................................................................................................................22 A. Factors Used to Select Custodians and/or Broker/Dealers..............................................................22 1. Research and Other Soft-Dollar Benefits ..........................................................................................22 2. Brokerage for Client Referrals ...........................................................................................................23 3. Clients Directing Which Broker/Dealer/Custodian to Use ..........................................................23 B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................23 Item 13: Reviews of Accounts ..............................................................................................................................24 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..............................24 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................24 C. Content and Frequency of Regular Reports Provided to Clients .....................................................24 Item 14: Client Referrals and Other Compensation ..........................................................................................25 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ...................................................................................................................................25 B. Compensation to Non – Advisory Personnel for Client Referrals ...................................................25 Item 15: Custody ....................................................................................................................................................25 Item 16: Investment Discretion ............................................................................................................................25 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................26 Item 18: Financial Information .............................................................................................................................26 A. Balance Sheet ...........................................................................................................................................26 v  B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................................................................................................................................................................26 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................26 vi  Item 4: Advisory Business A. Description of the Advisory Firm Cadent Capital Advisors, LLC (hereinafter “CCA”) is a Limited Liability Company organized in the State of Oklahoma. The firm was formed in January 2012, and the principal owners are Philip Andrew Mooberry, Ann Dagg, Todd Taylor, and Curtis Rice. B. Types of Advisory Services CCA offers the following services to advisory clients: Portfolio Management Services CCA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring CCA evaluates the current investments of each client and then will reallocate in accordance to their risk tolerance levels and time horizon. CCA will provide a review of the client’s investments at least annually. Risk tolerance levels are documented in the Investment Policy Statement, which is reviewed as needed with clients. The client should notify CCA regarding any changes in your situation that may affect your financial condition, investment objective or risk tolerance. CCA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCA’s economic, investment or other financial interests. To meet its fiduciary obligations, CCA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, CCA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CCA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 7  Selection of Other Advisers CCA may direct clients to third-party investment advisers. Before selecting other advisers for clients, CCA will always ensure those other advisers are properly licensed or registered as investment adviser. Subadviser Services CCA may also act as a subadviser to advisers unaffiliated with CCA. These third-party advisers would outsource portfolio management services to CCA. This relationship will be memorialized in each contract between CCA and the third-party advisor. Retirement Plan Consulting Services CCA offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting include, but is not limited to: o Liaison to Service Provider and TPA o Education Services to Plan Committee o Development of Investment Policy Statement o Participant Enrollment and Education o Benchmarking Services o Monitoring of Plan Fees o Creation and Implementation of Fund List o Ongoing analysis and recommendation of Investment Funds o Annual Review with Plan Committee These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Advisory Services to Brokerage Customers CCA provides investment advisory services to certain broker-dealers’ customers (“Brokerage Customers”) who provide written consent requesting to receive the firm’s advisory services. Brokerage Customers have entered into a written advisory agreement with CCA. Financial Planning Individual Financial Planning Services Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Financial Planning may be provided at no cost as part of the investment management process. 8  Divorce Financial Planning Services Divorce Financial Planning may include but is not limited to: Gathering financial details relevant to Client’s divorce, analysis of income and expenses. Financial budget planning and modeling, analysis and illustration of potential settlement scenarios, work with personal tax professionals to evaluate tax consequences of various settlement proposals, examining retirement and insurance issues, preparing inventories and financial settlement scenarios, and evaluating sources of income for alimony or spousal support. Services Limited to Specific Types of Investments CCA generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), commodities, hedge funds, private equity, private placement and insurance products including annuities. CCA may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about conflicts of interest. • • There are conflicts of interest that CCA and its investment adviser representative have in making an IRA or 401k plan rollover recommendations. The conflict CCA has in making any IRA or 401k plan rollover recommendation is CCA will earn a new (or increase its current) advisory fee if you do rollover to an IRA or 401k plan advised by CCA. The CCA investment advisor representative making an IRA rollover or 401k plan recommendation has the same conflict as CCA. As they will earn a new (or increase its current) advisory fee as a result. 9  C. Client Tailored Services and Client Imposed Restrictions CCA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCA from properly servicing the client account, or if the restrictions would require CCA to deviate from its standard suite of services, CCA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. CCA does not participate in any wrap fee programs. E. Assets Under Management CCA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $563,592,354 $87,415,790 December 2024 CCA also has $742,069,518.02 in assets under advisement. Assets under management include securities portfolios for which CCA provide continuous and regular supervisory or management services. While assets under advisement refer to assets on which CCA provides advice or consultation but for which CCA does either not have discretionary authority or does not arrange or effectuate the transaction. Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Services Fees CCA charges an annual investment advisory fee of up to 2% of assets under management. This rate can be negotiated between Client and Advisor. The annual fee for portfolio management services is billed monthly in advance based on the market value of the assets on the last day of the preceding month as reported by the 10  custodian. The monthly billed amount for each account is rounded to the nearest dollar. Amounts ending in $0.01 and $0.49 are rounded down, while amounts from $0.50 to $0.99 are rounded up. The specific advisory fees are set forth in your Investment Advisory Contract. Fees are assessed on all assets under management, including securities, cash and money market balances. Fees will be adjusted for all cash and securities inflows and outflows in the following month. Clients may terminate the agreement without penalty, for full refund of CCA’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract with thirty days’ written notice. After the five-day period, the client will be responsible for charges incurred for portfolio management services rendered to the point of termination. Selection of Other Advisers Fees CCA may direct clients to third-party investment advisers. CCA will be compensated by charging its own fee separately from the third-party investment adviser to which it directs those clients. This relationship will be memorialized in each contract between CCA and each third-party adviser. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. The annual fee schedule is as follows: Total Assets Under Advisement All Assets CCA’s Fee Up to 2.00% Third Party’s Fee Up to 0.50% Total Fee Up to 2.50% These fees are negotiable. Subadviser Services Fees CCA may also act as a subadviser to unaffiliated third-party advisers and CCA would receive a share of the fees collected from the third-party adviser’s client. The fees charged are negotiable and will not exceed any limit imposed by any regulatory agency. This relationship will be memorialized in each contract between CCA and the third-party adviser. Pension Consulting Services Fees The rate for pension consulting services is up to 2% of the plan assets for which CCA is providing such consulting services or can be a fixed fee. These fees are negotiable. 11  Advisory Services to Brokerage Customers Service Fees CCA receives an advisory fee based on the Assets Under Management from Brokerage Customers who have provided written consent to a broker-dealer to receive the investment advisory service from CCA and have entered into a written advisory contract with CCA. The advisory fee is calculated in advance based on the value of the Assets Under Management from Brokerage Customers as of the end of the previous quarter. The maximum advisory fee will not exceed 1% annually. This advisory fee is paid by the broker-dealer and is not charged to the client separately. Financial Planning Fees Hourly Fees These fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement.  Individual Financial Planning Services - The hourly Fee for these services is $250 per hour.  Divorce Financial Planning Services – The hourly fee for these services is $350 per hour. Clients may terminate the agreement without penalty, for full refund of CCA’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement with upon written notice. After the five- day period, the client will be responsible for charges incurred for Financial Planning services rendered to the point of termination and such fees will be due and payable by the Client. B. Payment of Fees Payment of Portfolio Management Fees Portfolio management fees are withdrawn directly from the client’s accounts by CCA with client’s written authorization. The annual fee for portfolio management services is billed monthly in advance based on the market value of the assets on the last day of the preceding month as reported by the custodian. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected and will be disclosed to the client prior to entering into a relationship with the third-party advisor. Currently, fees are 12  withdrawn directly from the client’s accounts by the platform provider with client’s written authorization. Fees are paid quarterly in advance. Payment of Pension Consulting Services Fees Pension consulting fees may be invoiced and billed directly to the client and clients may select the method in which they are billed. Fees are paid quarterly in arrears or on a monthly basis depending on the contact in place. Payment of Financial Planning Fees Hourly Financial Planning fees are billed in arrears, and invoiced and paid via check or withdrawn directly from the client’s accounts by CCA with client’s written authorization. Clients may choose the method they are billed. C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CCA. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees CCA collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days to the client via check or return deposit back into the client’s account. For all asset based fees paid in advance, the fee refunded will be the balance of the fees collected in advance minus the daily rate* times the number of days in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee by 365.) E. Outside Compensation For the Sale of Securities or Other Investment Products to Clients Todd Eugene Taylor, Logan Wehling and Deanna Stranglen are licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation. 1. This is a Conflict of Interest The supervised persons will accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds to its clients. This presents a conflict of interest and gives the 13  supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, they will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers or Insurance Agents Clients always have the option to purchase CCA recommended products through other brokers or insurance agents that are not affiliated with CCA. 3. Commissions are not the Primary Source of Income for CCA Commissions are not CCA’s primary source of compensation. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management CCA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients CCA generally provides advisory services to the following types of clients:  Individuals  High-Net-Worth Individuals  Charitable Organizations  Small Businesses  Trusts and Estates  Foundations  Pension/Retirement plans  Broker-Dealer Minimum Account Size There is no account minimum. 14  Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CCA’s methods of analysis include charting analysis, fundamental analysis, technical analysis, quantitative analysis and modern portfolio theory. Charting analysis involves the use of patterns in performance charts. CCA uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Investment Strategies CCA uses long term trading, short term trading, short sales, margin transactions, and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in 15  stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. Quantitative Model Risk. Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies CCA’s use of short-term trading, short sales, margin transactions, and options trading generally holds greater risk and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that 16  an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized CCA’s use of short sales, margin transactions, and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary and include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best- known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest, and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. 17  Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Hedge Funds: A private investment pool of money from investors that invest in securities or other types of investments. Hedge funds typically have more flexible investment strategies than, for example mutual funds which may increase the risk of investment losses. Some additional risks associated with hedge funds are lack of regulation, costs/fees, limitations of redemption and valuation risk. Clients should consult hedge fund’s offering documents explaining such risks prior to investing. Private Equity Funds: A pooled investment vehicle where the private equity firm pools together the money invested in the fund by all the investors and uses that money to make investments on behalf of the fund. Unlike mutual funds or Hedge funds, however, private equity firms often focus on long-term investment opportunities in assets that take time to sell with an investment time horizon typically of 10 or more years. Some risks associated with private equity funds are lack of regulation, public disclosure requirements, illiquidity, costs/fees, and conflicts of interest. Clients should consult investment offering documents explaining such risks prior to investing. Private placements: An offering of unregistered securities to a limited pool of investors. In a private placement, a company sells shares of stock in the company or other interests in the company. Some risks associated with Hedge Funds are lack of regulation, 18  costs/fees, illiquidity, and valuation risk. Clients should consult investment offering documents explaining such risks prior to investing. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings On September 17, 2013, William Hale Mildren violated Section 1-411 of the Oklahoma Securities Act of 2004, in that he failed to reasonably supervise a Registered representative under his charge while at Sanders Morris Harris. Civil and Administrative penalties occurred. More information is available at https://adviserinfo.sec.gov/ C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. \ Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CCA nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CCA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Related CPA One supervised Person of the Advisor, Brett C. Hobbs, is a certified public accountant. Mr. Hobbs does not provide tax advice to Clients for compensation but may help review tax form filings and other tax documents for Clients for no additional compensation. 19  D. Advisory Services to Brokerage Customers CCA has agreement with broker-dealer to provide investment advisory services to Brokerage Customers. Broker-dealers pay compensation to CCA for providing investment advisory services to Customers. Brokerage Customers will execute a written advisory agreement directly with CCA. This relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers consenting to receive investment advisory services from CCA; by CCA not accepting or billing for additional compensation on broker-dealers’ Assets Under Management beyond the advisory fees disclosed in Item 5; and by CCA not engaging as, or holding itself out to the public as, a securities broker-dealer. CCA is not affiliated with any broker-dealer. E. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Todd Eugene Taylor and Deanna Stranglen are licensed insurance agents. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. CCA always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of CCA in such individual’s outside capacities. Mr. Mooberry is also a registered agent and common member of Terramoo, LLC and a common member of JKJ Stonehaven Square, LLC. These entities actively pursue purchases of land in and around the Tulsa area with the intended goal of both new constructions and leasing/managing existing buildings on property owned. A client of Cadent Capital Advisors, LLC is a member of Terramoo, LLC. David Michael Foley is a member of Grace Investment Holdings, LLC which holds real estate investments. Todd Eugene Taylor is the owner of a second home considered a rental home property in Hilton Head, SC. He receives occasional rental income from this property. Brett Collin Hobbs is a Board Member at Oklahoma Employees Insurance and benefits Board. 20  Deanna Faye Stranglen is currently a member of Stranglen Properties, LLC, and Manager of DRL Properties, LLC which each hold real estate rental investments. Additionally, Deanna is a sales representative for Mary Kay, Inc. F. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CCA may direct clients to third-party investment advisers. CCA will be compensated by charging its own fee separately from the advisers to which it directs those clients. This relationship will be memorialized in each contract between CCA and each third-party adviser. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CCA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests CCA does not recommend that clients buy or sell any security in which a related person to CCA or CCA has a material financial interest. However, CCA personnel may arrange cross trades for client accounts. A cross trade is generally defined as a transaction between clients of the investment adviser where one client purchases and the other client sells the same security using a third-party broker (neither the investment adviser nor any person under common control acts as the broker). CCA will obtain verbal or written consent from the client prior to performing cross trades and, if granted, such consent will be binding. When arranging cross trades, CCA will act in accordance with its fiduciary duties to clients and will strive to avoid systematically advantaging or disadvantaging certain clients. 21  C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of CCA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CCA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. CCA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of CCA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CCA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, CCA will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Client transactions take place before employee transactions unless employees participate in a block transaction alongside clients. Employees will receive no advantage in block transactions. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on CCA’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a Client on terms that are the most favorable to the Client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and CCA may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of CCA. CCA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. CCA recommends Fidelity Institutional Wealth Services 1. Research and Other Soft-Dollar Benefits While CCA has no formal soft dollars program in which soft dollars are used to pay for third party services, CCA may receive research, products, or other services from its broker/dealer in connection with client securities transactions (“soft dollar 22  benefits”) consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and may consider these benefits in recommending brokers. There can be no assurance that any particular client will benefit from any particular soft dollar research or other benefits. CCA benefits by not having to produce or pay for the research, products or services, and CCA will have an incentive to recommend a broker dealer based on receiving research or services. Clients should be aware that CCA’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Additionally, Fidelity Institutional Wealth Services has and will possibly reimburse client transfer and/or termination fees on behalf of CCA, and Fidelity Institutional Wealth Services has and will possibly fund partial software usage/contract fees on behalf of CCA. 2. Brokerage for Client Referrals CCA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use CCA will require clients to use a specific broker-dealer to execute transactions. B. Aggregating (Block) Trading for Multiple Client Accounts If CCA buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple Clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, CCA would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. CCA would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with the Adviser’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). 23  Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client portfolio management accounts are reviewed at least annually by Brett Collin Hobbs, Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. Formal reviews with CCA are generally conducted annually or more or less frequently by the assigned investment adviser representative depending on the needs of the client. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Brett Collin Hobbs, Chief Compliance Officer or the assigned investment adviser representative. There is only one level of review for financial plans, and that is the total review conducted to create the financial plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Portfolio management reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, CCA’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each portfolio management client will receive brokerage statements no less than quarterly from the custodian. These brokerage statements are sent directly from the custodian to the client. The client may also establish electronic access to the custodian’s website to view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the client’s account(s). The Advisor may also provide clients with periodic reports regarding their holdings, allocations and performance. Each financial planning client will receive the financial plan upon completion. 24  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) As reference in Item 12 above, CCA may receive an indirect economic benefit from custodians/broker-dealers. CCA, without cost (and/or at a discount) may receive support services and/or products from custodians/broker-dealers. CCA receives an economic benefit from custodians/broker-dealers in the form of the support products and services it makes available to the firm and other independent investment advisors whose clients maintain their accounts at custodians/broker-dealers. The availability to CCA of custodians/broker-dealers products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. B. Compensation to Non – Advisory Personnel for Client Referrals CCA does not compensate non-advisory personnel as solicitors. Item 15: Custody When it deducts fees directly from client accounts at a selected custodian, CCA will be deemed to have limited custody of client’s assets and must have written authorization from the client to do so. Custody is also disclosed in Form ADV because CCA has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, CCA will follow the safeguards specified by the SEC rather than undergo an annual audit. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion CCA provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, CCA generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. In some instances, CCA’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to CCA. 25  Item 17: Voting Client Securities (Proxy Voting) CCA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security except as may be directed by Client to CCA for assistance. Item 18: Financial Information A. Balance Sheet CCA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither CCA nor its management has any financial condition that is likely to reasonably impair CCA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years CCA has not been the subject of a bankruptcy petition in the last ten years. 26