Overview
- Headquarters
- Salt Lake City, UT
- Total Firm Assets
- $386 million
- Average High-Net-Worth Client Portfolio Size
- $3.6 million
- Stated Minimum Account Size
- $500,000
Fee Disclosure
CANNON AMENDED PART 2A BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.70% |
| $10,000,001 | and above | 0.60% |
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $49,500 | 0.99% |
| $10 million | $84,500 | 0.84% |
| $50 million | $324,500 | 0.65% |
| $100 million | $624,500 | 0.62% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 53.59%
- Number of High-Net-Worth Clients
- 57
- Total Client Accounts
- 243
- Discretionary Accounts
- 243
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 144247
Additional Brochure: CANNON AMENDED PART 2A BROCHURE (2026-08-20)
View Document Text
Cannon Capital Management, Inc.
Disclosure Brochure
August 20, 2026
6768 South 1300 East
Salt Lake City, Utah 84121
(801) 566-3190
www.cannoncap.com
This brochure provides information about the qualifications and business practices
of Cannon Capital Management, Inc. (“CCM” or “the Firm”). If you have any
questions about the contents of this brochure, please contact us at (801) 566- 3190.
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 Cannon Capital Management, Inc. is available on the
SEC’s website at www.adviserinfo.sec.gov. CRD number is 144247.
Please note that registration as an investment adviser does not imply a certain level
of skill or training.
Disclosure Brochure – August 20, 2026
Page 1
Cannon Capital Management, Inc.
Item 2. Material Changes
This section is to identify and discuss material changes at Cannon Capital Management, Inc. (CCM).
The last annual filing of our Disclosure Brochure was dated March 24, 2026. We have made the
following changes:
•
Items 4, 10 and 14 – Cannon Capital Management, Inc. (“CCM”) has become affiliated
through common ownership with Cannon Capital Tax, LLC (“CCT”), a separate Utah limited
liability company that provides tax preparation, tax planning and strategy, bookkeeping,
payroll, and related services. CCM may refer clients to CCT, and clients of both firms may
authorize the firms to coordinate their respective services. This affiliation and referral
relationship creates potential conflicts of interest, as described in Items 4, 10 and 14 below.
Additionally, we have made other changes, some of which may clarify or enhance existing disclosures, but
we do not consider these other changes to be material.
Disclosure Brochure – August 20, 2026
Page 2
Cannon Capital Management, Inc.
Item 3. Table of Contents
Item 1. Cover Page ............................................................................................................. 1
Item 2. Material Changes ................................................................................................... 2
Item 3. Table of Contents ................................................................................................... 3
Item 4. Advisory Business ................................................................................................... 4
Item 5. Fees and Compensation ......................................................................................... 8
Item 6. Performance –Based Fees and Side –By-Side Management. ................................ 9
Item 7. Types of Clients Served by CCM .......................................................................... 10
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .............................. 10
Item 9. Disciplinary Information ........................................................................................ 12
Item 10. Other Financial Industry Activities and Affiliations ............................................... 12
Item 11. Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading .......................................................................................................... 13
Item 12. Brokerage Practices .............................................................................................. 13
Item 13. Review of Accounts ............................................................................................. 14
Item 14. Client Referrals and Other Compensation ............................................................ 14
Item 15. Custody ................................................................................................................ 15
Item 16. Investment Discretion ......................................................................................... 15
Item 17. Voting Client Securities ........................................................................................ 15
Item 18. Financial Information ........................................................................................... 15
Disclosure Brochure – August 20, 2026
Page 3
Cannon Capital Management, Inc.
Item 4. Advisory Business
Cannon Capital Management, Inc. (“CCM” or “the Firm”) is a fee-based investment advisor that
offers two types of advisory services: 1) Investment Management and Financial Planning and 2)
Pension Consulting and Advisory Services.
CCM has been in business since January of 2008 and is owned by Clinton C. Cannon and Chace
T. Cannon. The experience, education and background of Clinton C. Cannon and the investment
advisor representatives of CCM can be found in the accompanying Brochure Supplement
document.
Investment Management and Financial Planning
CCM will provide the Client free initial consultation. Among the purposes served by the initial
consultation is to:
□ Introduce the Client to CCM’s firm, its services and staff;
□ Gather applicable information about the Client’s investment objectives, financial
condition and risk tolerance that CCM will use in establishing the parameters around
which CCM will develop the Client’s investment portfolio and financial plan; and
□ Reach an agreement on the terms of service and compensation for CCM’s services.
If the Client elects to use CCM’s portfolio management services, the Client will sign CCM’s
Investment Advisory Agreement. The Client will also sign any custodial agreements necessary
to establish a custodial account with a brokerage firm and authorize CCM to execute trades in
the account for the Client. Clients will be notified of all transactions by trade confirmations from
their broker-dealer/custodian and through communication with CCM.
CCM will also request—through the investment Advisory Agreement—that the Client provide
written authorization to allow CCM to automatically deduct its advisory fee from the Client’s
account (please refer to the “Fees and Compensation” section on pages 7-8 of this Firm
Brochure). CCM will not have the authority to make any other withdrawals from the Client’s
account(s) under management.
Client accounts are managed on a discretionary basis, meaning CCM will buy or sell securities in
the Client’s account without obtaining prior approval of trades from the client. Clients may
impose restrictions on investing in certain securities or types of securities. CCM monitors Client
accounts on a daily basis so that it may make any necessary transactions to keep the Client’s
account in line with its investment objectives.
CCM and the Client will establish a formal review schedule to discuss the Client’s investment
portfolio, their financial plan, and to review the investment returns generated in the portfolio
Disclosure Brochure – August 20, 2026
Page 4
Cannon Capital Management, Inc.
and make any changes to the parameters around which the portfolio is managed.
While CCM will have discretionary authority to execute buy and sell orders in the Client’s
account, Clients should always review their brokerage account statements to verify the trading
activity and withdrawals that occur in their account(s).
CCM uses a wide variety of investment mechanisms to create portfolios for its clients. Included
in the suite of investment choices are the following:
□ Equity or stock investments – publicly traded and exchange-listed securities, securities
that are traded over-the-counter and foreign listed issuers of stock that are American
Depository Receipts (ADR) and therefore listed on the U.S. exchanges
□ Mutual funds and Exchange Traded Funds (ETFs)
□ Corporate debt securities
□ Commercial paper
□ Certificates of deposit (CD’S)
□ Tax free debt securities often referred to as municipal debt
□ Debt issued by the U.S. Government or it’s agencies
□ Mutual funds and ETFs that invest in similar debt instruments as those listed above
□ Private Credit funds
□ Alternative Investments such as Private Equity and Real Estate Investment Trusts (REIT)
There are risks associated with each type of investment vehicle used by CCM in the creation of
a portfolio. Each investment vehicle could face the possibility of bankruptcy and the value of the
underlying security, be it equity or debt, could fall to zero and result in a complete investment
loss. CCM believes that the creation of a diversified portfolio severely limits the possibility of a
complete portfolio loss; but, in an extreme environment such a possibility exists. However, CCM
does not utilize any strategies or invest in any securities in which the loss could be greater than
the investment cost of the security. CCM does not participate in any wrap fee programs.
When we provide investment advice to clients regarding their 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 interests ahead of yours. Under this special rule's provisions, we must:
Disclosure Brochure – August 20, 2026
Page 5
Cannon Capital Management, Inc.
• Meet a professional standard of care when making investment recommendations;
• Never put our financial interests ahead of yours when making recommendations;
• 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.
For more information about our conflicts of interest, please review Items 5, 10, 11 and 14 or
reach out to us using the contact information on the cover page of this brochure.
As of December 31, 2025, CCM had total Assets Under Management of $386,073,298, of which
are Discretionary.
Coordination with Affiliated Tax Services
CCM is affiliated through common ownership with Cannon Capital Tax, LLC (“CCT”), a separate
legal entity that provides tax preparation, tax planning and strategy, bookkeeping, payroll, and
related services. CCM may recommend or refer clients to CCT when CCM believes tax services
may be appropriate for the client. Clients are under no obligation to engage CCT and may obtain
tax services from any provider of their choosing.
CCT's services are provided pursuant to a separate engagement agreement directly between
the client and CCT. CCT's tax services are not investment advisory services provided by CCM,
and fees paid to CCT are separate from the investment advisory fees paid to CCM.
When a client engages both CCM and CCT, the firms may coordinate investment, financial
planning, and tax matters when authorized by the client. Tax return information will not be
shared between CCT and CCM except in pursuant to the client's separate written authorization
and as otherwise permitted by applicable law.
Pension Consulting and Advisory Services
CCM serves as an ERISA 3(21) investment co-fiduciary with the Plan Sponsor, a 3(38) investment
- fiduciary or a Plan Consultant for Qualified Retirement Plans at the Plan Sponsor’s direction.
CCM’s compensation is entirely fee based and includes no compensation or revenue sharing
from securities used by the Plan. CCM’s services in this area refer to 401(k) Plans.
Disclosure Brochure – August 20, 2026
Page 6
Cannon Capital Management, Inc.
CCM’s Pension Consulting and Advisory Services include the following:
□ Developing an Investment Policy Statement (IPS) for the Plan
□ Selecting and monitoring Plan investment options for the Plan consistent with the
Plan’s IPS
□ Scheduling and developing Trustee agendas for the Plan
□ Attending, conducting and documenting Trustee meetings
□ Participant investment education – through group and one on one meetings
□ Coordinating Plan administration with the respective Plan service providers
□ Consulting with Plan trustees regarding administration and Plan compliance with
rules and regulations
CCM advocates its Pension Clients use an open architecture investment platform which allows
greater flexibility and control of the investment options used by the Plan Sponsor. When an
open architecture platform is used by the Client, CCM will create “pre-made” risk- based or
Target Date investment portfolio models for the Plan Participants to select from using the Plan
investment options. The pre-made risk-based or Target Date investment portfolios are in
addition to the individual fund options from which a Plan Participant may choose to use as their
investment tools in creating their own investment portfolio. CCM will offer direct advice when
asked but does not have the authority to direct the individual Plan Participants’ investment
choices.
As such, CCM does not have discretionary control over individual Plan Participants investment
decisions. CCM’s compensation is not conditional upon the use of the pre-made risk- based or
Target Date portfolio models by the Plan Participant – please refer to the “Fees and
Compensation” section on pages 7 - 8 of this Firm Brochure.
The investment Securities used in the Pension Consulting and Advisory Services by CCM include:
□ Publicly traded Mutual Funds and Exchange Traded Funds
□ Sub-advised funds with relationships through insurance firms such as John Hancock,
Principal Financial, etc.
Funds used by Clients may consist of both actively managed and passive or indexed funds.
CCM does not offer investment advice or use other investment vehicles other than those listed
above in its Pension Consulting and Advisory Services.
Disclosure Brochure – August 20, 2026
Page 7
Cannon Capital Management, Inc.
There are risks associated with each type of investment vehicle recommended by CCM in the
Pension Consulting and Advisory Services. Each investment vehicle could face the possibility of
bankruptcy and the underlying funds, be it equity or debt, could fall to zero and result in a
complete investment loss. CCM believes that the creation of a diversified portfolio severely
limits the possibility of a complete portfolio loss; but, in an extreme environment such a
possibility exists. However, CCM does not recommend or provide any strategies or funds in
which the loss could be greater than the investment cost of the security.
CCM does not participate in any wrap fee programs.
Item 5: Fees and Compensation
Investment Management
its fees for services by directly submitting a bill to the
CCM prefers to deduct
brokerage/custodian firm servicing the Client’s account. Clients grant permission for this direct
billing in CCM’s Investment Advisor Agreement. However, if a Client would prefer that billing for
services be made to them, a fee notice will be sent to the Client with payment expected within
30 days of the fee notice.
CCM’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees,
and other related costs and expenses which are incurred by the client. CCM does not receive
any portion of these commissions, fees, and costs. The fee schedule for Cannon Capital
Management, Inc. Investment Management Services is as follows:
All Equity & Mixed Equity and Fixed Income Portfolios:
1.25% on assets up to $1,000,000.00
1.00% on assets from $1,000,001.00 to $3,000,000.00
.85% on assets from $3,000,001.00 to $5,000,000.00
.70% on assets from $5,000,001.00 to $10.000,000.00
.60% on assets > $10,000,000.00
Fees are quoted on an annual basis. Fees are assessed at the beginning of each calendar quarter
using the account's fair market value as of the last business day of the calendar quarter.
Investment advisory services may be terminated by either party with a two- day written notice.
Should investment advisory services be terminated by either party, fees assessed at the
beginning of the quarter will be refunded on a prorated basis. CCM does not negotiate its
management fee; however, CCM does offer discounts to select friends, employees and family
of the Firm.
Disclosure Brochure – August 20, 2026
Page 8
Cannon Capital Management, Inc.
Pension Consulting and Advisory Services
CCM will bill for its services based on the Plan Sponsor’s direction – some Plan Sponsors prefer
to have Plan Participants pay for CCM’s services, in which case a fee for service is submitted to
the Plan Record keeper for payment. If a Plan Sponsor desires to pay for CCM’s services
themselves, a fee for service is submitted directly to the Plan Sponsor; payment is expected
within 30 days of fee for service notification.
The fee schedule for Cannon Capital Management, Inc. Pension Consultant and Advisory
Services is as follows:
.50% $0 - $500,000.00
.45% $500,001 - $1,000,000
.41% $1,000,001 - $2,000,000
.38% $2,000,001-$3,000,000
.36% $3,000,001-$4,000,000
.34% $4,000,001-$5,000,000
.32% $5,000,001-$6,000,000
.29% $6,000,001-$7,000,000
.27% $7,000,001-$8,000,000
.25% $8,000,001-$10,000,000
.23% $10,000,001-$13,000,000
.20% $13,000,001-$20,000,000
Negotiated > $20,000,000
Fees are quoted on an annual basis. Fees are assessed at the beginning of each calendar quarter
using the account's fair market value as of the last business day of the calendar quarter. Pension
consulting services may be terminated at any time by either party with written notice.
Clients may be charged certain fees and expenses imposed by third party broker-dealers,
insurance companies, investment companies and/or custodians such as custodial fees, charges
imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-
lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. Such charges, fees and commissions are
exclusive of and in addition to CCM’s fee. CCM does not receive any additional compensation
from any third-party fees or commissions.
Item 6. Performance-Based Fees and Side-By-Side Management
Disclosure Brochure – August 20, 2026
Page 9
Cannon Capital Management, Inc.
CCM does not provide any services for performance-based (fees based on a share of capital gains
on or capital appreciation of the assets of a client).
Item 7. Types of Clients Served by CCM
CCM serves a wide variety of clients including individuals, pension and profit-sharing plans
including 401(k) Plan Sponsors, trusts, Estates, charitable and non-profit entities as well as for
profit corporations, LLC and partnerships and other business entities.
The minimum account size for Portfolio Management Services is $500,000.00 or as negotiated
with a representative of CCM. The minimum account size for Pension Consulting and Advisory
Services is $1,000,000.00 or as negotiated with a representative of CCM.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Portfolio Management
The investment advisory services are based on the following philosophies and investment
disciplines for the equity (stock) and fixed income (bond) markets.
Equity Investment Philosophy and Discipline:
Our equity investment philosophy is founded on a belief in diversification, minimal costs, and a
desire and willingness to invest in sectors or companies that have demonstrated an ability to
deliver higher returns relative to other sectors of the equity market over an extended period of
time. We design our investment allocations around these opportunities.
Our investment discipline incorporates our philosophy and adds to it the structure of a consistent
and disciplined valuation review of investment sectors including Large Cap Stocks, Medium Cap
Stocks, Small Cap Stocks, Foreign Developed Stocks, Emerging Market Stocks, Alternative
Investments and Natural Resources. Based on this review we will from time to time adjust our
allocations to take advantage of sectors that are inordinately cheap or unusually expensive.
We use a variety of Exchange Traded Funds (ETFs) or other similar investment vehicles to
strategically allocate funds in a portfolio designated for equity exposure. The ETFs we use will
generally be index funds of a broad asset class such as Large Cap, Mid Cap, Emerging
International Markets, etc. or narrower sector funds such as in healthcare, finance, energy or
technology. Our use of ETF funds is to create an effective means to allocate assets in a strategic
manner. We feel that by using a combination of mutual funds and ETF’s we can create an equity
investment portfolio that will be more efficient from a volatility or risk standpoint and yet
provide a diversified portfolio with significant opportunity to grow over an investor’s time
horizon.
Typically, equity portfolios will be comprised of ETFs, individual stocks and alternative
investments.
Risks in our analysis and implementation of investment strategies include the following:
□ Faulty information released by the companies in which we have made an investment
□ Incorrect analysis of information regarding an investment
Disclosure Brochure – August 20, 2026
Page 10
Cannon Capital Management, Inc.
□ Undisciplined implementation of our strategies
Despite the analysis performed by CCM of the investments it makes for its clients, any
investment carries market risk, and investors may lose their principal investment. While CCM
does not engage in frequent trading strategies, all trades may carry a cost of execution, called a
brokerage fee, and excessive trading can result in increased costs to the Client without an
equivalent increase in return. Individual stocks will generally carry a greater amount of risk than
ETF security as ETF will have a greater number of stocks within its holdings and thereby reduce
the risk of the overall portfolio. Individual stocks and ETF securities can be leveraged, which in
turn increases the risk of greater loss and return. CCM does not leverage individual stocks or use
leveraged ETF securities.
Fixed Income Philosophy and Discipline
We believe in using fixed income mutual funds, exchange traded funds and private market funds
to generate the highest level of income relative to the prevailing credit and maturity conditions
existing in the market and as set by our client’s preferences. We incorporate a discipline that
involves creating a diversified portfolio of fixed income securities to meet our client's specific
needs and circumstances.
We use Exchange Traded Funds (ETFs), private market funds and, in some cases mutual funds,
to strategically provide income to our client portfolios. The use of fixed income ETFs allows us
to quickly create a diversified portfolio of fixed income instruments from a maturity, type and
credit quality standpoint. Generally, the fixed income ETFs we use will be passive and based
upon an index with a specific maturity, type of issuer and credit rating that allows us the
opportunity to create a more efficient fixed income portfolio by incorporating individual fixed
income securities with those in a fixed income ETF.
Risks in our analysis and implementation of investment strategies include the following:
□ Faulty information released by the companies in which we have made an investment
□ Inability of the issuer of debt to pay back their commitment
□ Undisciplined implementation of our strategies
Despite the analysis performed by CCM of the investments it makes for its clients, any
investment carries market risk and investors may lose their principal investment. While CCM
does not engage in frequent trading strategies, all trades may carry a cost of execution, called a
brokerage fee, and excessive trading can result in increased costs to the Client without an
equivalent increase in return. ETF securities can be leveraged which in turn increases the risk of
greater loss and return. CCM does not leverage ETF securities.
Disclosure Brochure – August 20, 2026
Page 11
Cannon Capital Management, Inc.
Item 9. Disciplinary Information
Neither CCM nor any of its Representatives have had any legal or disciplinary events in their
past, nor are they aware of any such pending events. Clients and prospective Clients may view
the CRD records (registration records) for CCM or any of its representatives through the SEC’s
Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov The CRD number for
CCM is 144247. The CRD numbers of the management of CCM and its representatives are listed
alongside their biographical information in the accompanying Brochure Supplement document.
Item 10. Other Financial Industry Activities and Affiliations
As described in Item 4, CCM is affiliated through common ownership with CCT, a Utah limited
liability company that provides tax preparation, tax planning and strategy, bookkeeping, payroll,
and related services. Certain owners and/or supervised persons of CCM also have ownership
interests in, and may perform services for, CCT.
CCM and CCT are separate legal entities. CCT is independently responsible for the tax and
accounting-related services it provides, and clients engaging CCT enter into a separate written
engagement directly with CCT. CCM does not provide tax return preparation, bookkeeping, or
payroll services through its investment advisory engagement.
CCM may refer advisory clients to CCT when tax-related services may be appropriate. Clients
are not required to use CCT and may select any tax professional or other service provider they
choose. A client's decision whether to engage CCT will not affect the availability or terms of
CCM's investment advisory services.
The common ownership of CCM and CCT creates a conflict of interest because CCM and its
owners have an economic interest in the financial success of CCT. Accordingly, CCM and its
representatives have an incentive to recommend CCT rather than an unaffiliated tax provider.
CCM addresses this conflict by disclosing the affiliation to clients, not requiring clients to engage
CCT, and requiring advisory recommendations to be made in the client's best interest.
CCM and CCT may coordinate their respective services for clients who engage both firms. Each
entity maintains separate client engagements, records, and responsibilities. CCT will disclose tax
return information to CCM only pursuant to the client's separate written consent or as
otherwise permitted by applicable law.
Neither CCM nor any of our management persons are registered as a broker-dealer or a
registered representative of a broker-dealer or have an application pending to register as a
futures commission merchant, commodity pool operator, commodity trading adviser or as an
associated person (or registered representative) of the foregoing entities.
Other than what is described above, neither CCM nor any of our management persons have
relationship or any arrangement that is material to our advisory business or to our clients that
CCM or any of our management persons have with any related person that is, under common
Disclosure Brochure – August 20, 2026
Page 12
Cannon Capital Management, Inc.
control and ownership.
In addition, CCM does not recommend or select other investment advisers for clients and does
not receive compensation from other advisers.
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Pursuant to SEC Rule 204A-1, CCM has a Code of Ethics that promotes the fiduciary duty of CCM
and its Representatives. The Code of Ethics articulates the importance of trust as a foundation
to the relationship between an investment advisor and its clients and establishes policies and
procedures to ensure that CCM and its Representatives place the interests of the Clients first.
The confidential information, fiduciary standard of care, personal trading on the part of the CCM
and its Representatives, outside business activities of Representatives, and the disclosure of
conflicts of interest.
A copy of CCM’s Code of Ethics is available upon request for any Client or prospective Client.
Participation or Interest in Client Transactions and Personal Trading
CCM or its owners and Representatives may buy or sell securities which the firm has
recommended to its clients. Individual transactions initiated by owners and associates of CCM
as well as by CCM itself must first be cleared by the Chief Compliance Officer of the firm and are
not allowed to front run any of the trades done on behalf of Cannon Capital Management's
clients.
Allowing CCM, its ownership or associates to buy or sell securities which the firm is
recommending to its clients could create a conflict of interest between CCM and its clients. CCM
recognizes this potential conflict of interest and adheres to a strict code of ethics which has as
its central point the principal of Duty of Loyalty to our clients. Duty of Loyalty means that all
actions taken by anyone associated with CCM will be done within the scope of the laws and
regulations of our industry, with complete integrity and placing the benefits of our clients first
and foremost. Neither CCM nor any of its Representatives recommend securities to its clients in
which it has a material financial interest.
Item 12. Brokerage Practices
CCM does suggest the use of certain custodians to its clients. The suggestions CCM makes are
based on the ability of the respective custodian(s) to execute orders in a timely and efficient
manner while minimizing the cost of the transaction. CCM does not engage in the practice of
using "soft dollar" commissions from the brokerage fees generated by its clients to purchase
products or services from third party vendors. CCM does not recommend a particular broker-
dealer based on obtaining referrals from the broker-dealer. CCM does not receive any
compensation, either direct or indirect, from any brokerage charged to Client accounts.
Disclosure Brochure – August 20, 2026
Page 13
Cannon Capital Management, Inc.
Trades executed for clients whose assets are held in custody for them by Charles Schwab will be
charged a commission rate based on the schedule established by Charles Schwab. Clients whose
assets are not held in custody at Charles Schwab will have their trades executed by brokers with
whom CCM will, in conjunction with the broker, determine the commission rate paid for the
respective trades. CCM will seek to minimize the cost of the trades on behalf of the client. CCM
will aggregate the purchase or sale of securities for various Client accounts. The aggregation of
trade orders creates efficiency in price execution and prohibits any one client from receiving a
favorable treatment of a trade.
Item 13. Review of Accounts
Client investment advisory portfolios are reviewed on a daily or weekly basis. Reviews are
triggered by systematic monitoring of the portfolios, investment actions taken by the Portfolio
manager and through formal reviews with the respective clients. All reviews are conducted by
a member of the Firm’s investment committee consisting of: Clinton C. Cannon, CFA and
Managing Director, Chace T. Cannon, CFP and Managing Director.
Every client receives a quarterly report which depicts the cost basis and market value of each
security and the portfolio as a whole. Included in the report is a listing of all securities that have
been bought or sold within the most recent calendar quarter. Along with the quarterly reports
of their individual portfolio, a quarterly update of the capital markets is included. Between
quarterly reports, clients may receive notifications regarding events that may affect the capital
markets or specific investments held in their respective portfolios.
Item 14. Client Referrals and Other Compensation
CCM’s related persons receive discounted fees at certain resorts that a private fund we
recommend invests in. In addition, from time to time, custodians, mutual fund/ETF companies,
private fund managers, or other third parties will pay for client luncheons, or other events, that
CCM hosts. These arrangements give rise to conflicts of interest, or perceived conflicts of
interest in that the CCM has an incentive to invest (or recommend) client assets with these
entities that provide such benefits to CCM or its supervised persons. CCM’s commitment to its
clients and the policies and procedures it has adopted that require the review of such
arrangements by the CCO are designed to limit any interference with the Firm’s independent
decision making when choosing the best investments for our clients. We address this conflict of
interest by adhering to a written compliance manual that includes the monitoring of such
recommendations to ensure they are in the client’s best interest. As part of its duties to its
clients, CCM always endeavors to put the interests of its clients first.
Referrals to Cannon Capital Tax, LLC
CCM may refer clients to its affiliated tax-services firm, CCT. CCM does not receive a referral fee
from CCT solely for referring a client to CCT. However, because CCT and CCM are under common
ownership and certain CCM personnel have ownership interests in CCT, CCM and its associated
persons have an economic interest in the financial success of CCT. This creates an incentive for
CCM to recommend CCT over unaffiliated tax service providers. CCM addresses this conflict by
Disclosure Brochure – August 20, 2026
Page 14
Cannon Capital Management, Inc.
disclosing the affiliation to clients, not requiring clients to engage CCT, and requiring advisory
recommendations to be made in the client's best interest.
Clients are under no obligation to engage CCT and are free to obtain tax services from any
provider they choose. A client's decision whether to engage CCT does not affect the advisory
services provided by CCM or the advisory fees charged by CCM.
Item 15. Custody
Clients will engage an independent broker-dealer/custodian to maintain their accounts and so
CCM will not have physical custody of Clients’ assets, monies or securities. CCM may withdraw
advisory fees directly from Clients’ accounts (please see Item 5 “Fees and Compensation”). CCM
is deemed to have custody solely due to the direct withdrawal of fees but does not entail all of
the same legal and regulatory requirements as an investment adviser with physical custody of
Clients’ assets, monies or securities. Clients will receive account statements from their broker-
dealer/custodian on a monthly basis and on a quarterly basis from CCM. CCM urges Clients to
compare the account statements they receive from the broker-dealer/custodian with those sent
by CCM.
Item 16. Investment Discretion
CCM has investment discretion for Clients who choose to employ CCM’s Portfolio Management
Services. Investment discretion is granted to CCM as part of the investment advisory agreement
the Client signs with CCM.
Pension Consulting and Advisory Services Clients do not grant investment discretion to CCM and
for those Clients, CCM performs its services in a non-discretionary manner.
Item 17. Voting Client Securities
Cannon Capital does not have and will not accept authority to vote client securities. Issuer and
issuer related communications are generally delivered by the custodian directly to the client. By
signing the custodian application, the client acknowledges that Cannon Capital will not accept
voting rights on securities.
Item 18. Financial Information
CCM does not require the prepayment of fees from its clients six months or more in advance and
is not required to disclose additional financial information with this document. CCM has not
been the subject of a bankruptcy petition at any time during the last 10 years.
Disclosure Brochure – August 20, 2026
Page 15