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Capasso Planning Partners LLC
Form ADV Part 2A
Disclosure Brochure
October 15, 2025
This brochure provides information about the qualifications and business practices of Capasso
Planning Partners LLC. If you have any questions about the contents of this brochure, please contact
us at (843) 608-8487 or by email at charlie@capassoplanningpartners.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 Capasso Planning
CRD number
Partners LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.
: 294673
Capasso Planning Partners LLC │635 East Bay Street, Suite C, Charleston, SC 29403
Telephone: (843) 608-8487
www.capassoplanningpartners.com
Material changes relate to Capasso Planning Partners LLC’s policies, practices or conflicts of interests.
Item 2: Material Changes
Capasso Planning Partners LLC has the following material changes to report.
This brochure includes the following change since our last brochure dated June 24, 2025:
- We have updated Item 5 of our ADV 2A to clarify that the maximum annual fee for investment
advisory services is 1.25%, and that any fees for additional services such as financial planning are
separate and in addition to that fee. Please see Item 5 of our ADV 2A for more details.
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Item 3: Table of Contents
Item 2: Material Changes .............................................................................................................................. 2
Item 3: Table of Contents .............................................................................................................................. 3
Item 4: Advisory Business .............................................................................................................................. 4
Item 5: Fees and Compensation .................................................................................................................... 6
Item 6: Performance-Based Fees and Side-By-Side Management ................................................................ 8
Item 7: Types of Clients ................................................................................................................................. 8
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................................. 8
Item 9: Disciplinary Information .................................................................................................................. 11
Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 12
Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ................. 12
Item 12: Brokerage Practices ...................................................................................................................... 13
Item 13: Review of Accounts ....................................................................................................................... 14
Item 14: Client Referrals and Other Compensation .................................................................................... 15
Item 15: Custody ......................................................................................................................................... 16
Item 16: Investment Discretion ................................................................................................................... 16
Item 17: Voting Client Securities ................................................................................................................. 16
Item 18: Financial Information .................................................................................................................... 16
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Item 4: Advisory Business
Capasso Planning Partners LLC (hereinafter “CPP LLC”) is a Limited Liability Company organized in the
Description of Advisory Firm
State of South Carolina. The firm was formed in January 2018 and has been in business since April 2018.
The principal owner is Charles Dustin Capasso.
Types of Advisory Services
CPP LLC offers ongoing portfolio management services based on the individual goals, objectives, time
Portfolio Management Services
horizon, and risk tolerance of each client. CPP LLC creates an Investment Policy Statement for each client
and then constructs a plan to aid in the selection of a portfolio that matches each client's specific
situation.
CPP LLC evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. CPP LLC will request discretionary authority from clients in order to select securities and
execute transactions without permission from the client prior to each transaction. However, CPP LLC take
each client through an investment education process along with the planning process so each client
understands the strategy from the onset of the relationship.
Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.
CPP LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties
owed to its accounts and without consideration of CPP LLC’s economic, investment or other financial
interests. To meet its fiduciary obligations, CPP LLC attempts to avoid, among other things, investment or
trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly,
CPP LLC’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 CPP LLC’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair
and equitable basis over time.
Financial plans and financial planning may include but are not limited to investment planning, insurance
Financial Planning Services
planning, tax planning, estate planning, retirement planning, education planning, employee benefits
planning, charitable gift panning, credit planning, debt strategies, income, spending, budgeting, savings,
and credit card reward analysis.
These services may include the following three steps:
1.
Initial Consultation: Assess current financial situation and discuss the financial planning process
and services.
2. Detailed Meeting: Review financial situation in depth to understand client’s financial goals and
concerns.
3. Client Recommendation Meeting: Deliver and client walkthrough of financial plan, including
current net worth (Balance Sheet), goals, and action items.
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Ongoing Financial Planning Services
If providing ongoing financial planning services, CPP LLC will provide the following:
• Quarterly check-ins with clients to assess financial plan, implementation of the plan, limitations,
adjustments needed, and assess new variables in a client’s financial picture.
• End of Year meeting to discuss financial plan.
• A live copy of the plan through CPP LLCs financial planning tools. Client may or may not receive a
written financial plan, depending on their particular needs and requests.
CPP LLC may direct clients to third-party investment advisers. Before selecting other advisers for clients,
Selection of Other Advisers
CPP LLC will verify that all recommended advisers are properly licensed, notice filed, or exempt in the
states where CPP LLC is recommending the adviser to clients. Clients will pay these fees to these third-
party investment advisers either directly, or through CPP LLC, as discussed in Item 5 of this brochure.
CPP LLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds
Services Limited to Specific Types of Investments
(including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and
precious metal sectors), commodities, non-U.S. securities, venture capital funds and private placements,
although CPP LLC primarily recommends mutual funds, and private equity funds.
CPP LLC may use other securities as well to help diversify a portfolio when applicable.
CPP LLC utilizes Pontera, a third-party platform, to facilitate management of held away assets such as
Pontera
defined contribution plan participant accounts, with discretion. The platform allows CPP LLC to avoid
being considered to have custody of Client funds since the Firm does not have direct access to client log-
in credentials to affect trades. CPP LLC is not affiliated with the Pontera platform in any way and receives
no compensation from them for using their platform. In order for CPP, LLC to manage held away assets
(assets not held at Fidelity or Schwab) a link will be provided to the client allowing them to connect an
account(s) to the platform. Once client account(s) is connected to the platform, CPP LLC will review the
current account allocations. When deemed necessary, CPP LLC will rebalance the account considering
client investment goals and risk tolerance, and any change in allocations will consider current economic
and market trends. The goal is to improve account performance over time, minimize loss during difficult
markets, and manage internal fees that harm account performance.
CPP LLC will tailor a program for each individual client. This will include an interview session to get to
Client-Tailored Services and Client-Imposed Restrictions
know the client’s specific needs and requirements as well as a plan that will be executed by CPP LLC on
behalf of the client. 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 CPP LLC from properly
servicing the client account, or if the restrictions would require CPP LLC to deviate from its standard suite
of services, CPP LLC reserves the right to end the relationship.
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A wrap fee program is an investment program wherein the investor pays one stated fee that includes
Wrap Fee Programs
management fees, transaction costs, fund expenses, and any other administrative fees. CPP LLC does not
participate in any wrap fee programs.
As of December 31, 2024, CPP LLC has approximately the following assets under management:
Assets under Management
• Discretionary: $322,521,858
• Non-Discretionary: $5,175,639
• Total Regulatory Assets Under Management: $327,697,497
Annual Fee
Item 5: Fees and Compensation
Total Assets under Management
Portfolio Management Fees
$1 - $1,000,000
1.00%
$1,000,001 - $3,000,000
0.80%
$3,000,001 - $4,500,000
0.70%
$4,500,001 - $6,000,000
0.60%
$6,000,001 and up
0.50%
CPP LCC may charge a minimum management fee, which, if applicable, will be disclosed fully in the
client’s Investment Advisory Contract. The advisory fee is calculated using the value of the assets in the
Account on the last business day of the prior billing period. Fees vary and are negotiable. The maximum
annual fee for investment advisory services is 1.25%. If clients are provided additional services such as
financial planning, those fees are separate and in addition to this fee, and can be paid through the client’s
brokerage accounts. If billed using the tiered fee schedule (not the annual flat rate), clients will pay a
different rate for different portions of their assets under management, depending on the applicable tier.
As the client’s assets grow, the rates for each tier will apply to the corresponding portion of the total
portfolio. The fee rate for each tier is applied only to the portion of assets within that tier.
The final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the
agreement without penalty for a full refund of CPP LLC's fees within five business days of signing the
Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's
written authorization on a monthly or quarterly basis or may be invoiced and billed directly to the client
on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in advance.
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Financial planning fees are paid either via check, wire, online processing system, or withdrawn directly
Financial Planning Fees
from the client’s custodial account with the client’s written authorization. There is a minimum fee of
$2,400 for all financial planning services.
The negotiated fixed rate for creating client financial plans is between $1,500 and $100,000. Fixed
Fixed Fees
financial planning fees are paid quarterly or semi-annually in advance, but never more than six months in
advance.
The hourly fee for ongoing financial planning services ranges from $250- $350. The fees are negotiable,
Hourly Fees
and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Hourly
financial planning fees are paid quarterly in arrears.
Clients may terminate the agreement without penalty, for full refund of CPP LLC’s fees, within five
business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the
Financial Planning Agreement generally upon written notice.
The notice of termination requirement and payment of fees for third-party investment advisers will
Selection of Other Advisers Fees
depend on the specific third-party adviser selected.
CPP LLC may direct clients to third-party investment advisers at its discretion. For certain third-party
investment advisers, CPP LLC receives the fee paid by the client and compensates the third-party
investment adviser separately. For other third-party investment advisers, the client pays the third-party
fee directly to the third-party investment adviser, pursuant to an agreement that the client executes with
the third-party investment adviser that discloses this fee.
Clients are responsible for the payment of all third-party fees (i.e., custodian fees, commissions,
Client Responsibility for Other Fees
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the
fees and expenses charged by CPP LLC. Please see Item 12 of this brochure regarding broker-dealers and
custodians.
CCP LLC manages assets not held at the primary custodian, including but not limited to 401K plans, 529
Billing on Held Away Assets
plans and private investments. CCP LLC will charge portfolio management fees as describe above for
providing services on these assets. The fee is deducted from an account under CCP LLC primary custodian
or paid directly by the client on a quarterly basis. The fees are based on the assets provided by the third-
party custodian at the close of the quarter.
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CPP LLC collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on
Prepayment of Fees
a prorated basis and 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 equal to the balance of the fees
collected in advance minus the daily rate* times the number of days elapsed in the billing period up to
and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee
rate by 365.)
Fixed fees that are collected in advance will be refunded based on the prorated amount of work
completed at the point of termination.
Certain representatives of CPP LLC are licensed insurance agents and, from time to time, will offer clients
Outside Compensation for the Sale of Securities to Clients
advice or insurance products from this activity. Clients should be aware that these services, in certain
instances, pay a commission or other compensation and this presents a conflict of interest, as these
commissionable insurance products conflict with the fiduciary duties of a registered investment adviser.
To mitigate this conflict, representatives of CPP LLC will act in the client’s best interest. CPP LLC’s
representatives, not CPP LLC, receives the commissions for these insurance products. CPP LLC does not
charge a management fee on these insurance products, and clients are not required to use these
products.
CPP LLC does not accept performance-based fees or other fees based on a share of capital gains on or
Item 6: Performance-Based Fees and Side-By-Side Management
capital appreciation of the assets of a client.
CPP LLC generally provides advisory services to the following types of clients:
Item 7: Types of Clients
Individuals
•
• High-Net-Worth Individuals
• Charitable Organizations
• Corporations or other businesses
There is no account minimum for any of CPP LLC’s services.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
CPP LLC’s methods of analysis include:
Methods of Analysis
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Fundamental Analysis involves the analysis of financial statements, the general financial health of
companies, and the analysis of management or competitive advantages.
Modern Portfolio Theory is a theory of investment that attempts to maximize portfolio expected return
for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return,
each by carefully choosing the proportions of various assets.
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, and historical projections of sales.
CPP LLC does not offer specific investment strategies or model portfolio. Clients are invested in a variety
Investment Strategies
of securities based on their unique circumstances, including equities, corporate bonds, municipal bonds,
mutual funds, and ETFs. The firm may recommend additional securities to diversify a portfolio when
applicable.
We may use one or more of the following investment strategies when advising a client on investments:
•
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. Using a
long-term purchase strategy generally assumes the financial markets will go up in the long-term
which may not be the case. There is also the risk that the segment of the market that you are
invested in or perhaps just your particular investment will go down over time even if the overall
financial markets advance. Purchasing investments long-term may create an opportunity cost -
"locking-up" assets that may be better utilized in the short-term in other investments.
• Short Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities'
short-term price fluctuations. Using a short-term purchase strategy generally assumes that we
can predict how financial markets will perform in the short-term which may be very difficult and
will incur a disproportionately higher amount of transaction costs compared to long-term trading.
There are many factors that can affect financial market performance in the short-term (such as
short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller
impact over longer periods of times.
• Option Writing – an option is the right either to buy or sell a specified amount or value of a
particular underlying investment instrument at a fixed price (i.e. the “exercise price”) by
exercising the option before its specified expiration date. Options giving you the right to buy are
called “call” options. Options giving you the right to sell are called “put” options. When trading
options on behalf of a client, we generally use covered options. Covered options involve options
trading when you own the underlying instrument on which the option is based. Investments in
options contracts have the risk of losing value in a relatively short period of time. Option
contracts are leveraged instruments that allow the holder of a single contract to control many
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shares of an underlying stock. This leverage can compound gains or losses.
Material Risks Involved
Investing in securities involves risk of permanent loss of capital that clients should be prepared to bear.
Risks of Investing
The value of an investment may be affected by one or more of the following risks, any of which could
cause the portfolio’s return or yield to fluctuate:
Availability of Information: Certain issuers, including municipalities, private companies, and foreign
issuers may not be subject to the same disclosure, accounting, auditing, and financial reporting standards
and practices as publicly listed companies in U.S. stock markets. As such, there may be less information
publicly available about these issuers and their current financial condition.
Credit Risk: An issuer of debt securities may fail to make interest payments and repay principal when due,
in whole or in part. Changes in an issuer’s financial strength or in a security’s credit rating may affect a
security’s value.
Inflation Risk: Inflation may erode the buying power of your investment portfolio, even if the dollar value
of your investments remains the same.
Interest Rate Risk: Changes in interest rates may affect the value of a portfolio’s investments. For
example, when interest rates rise, the value of investments in fixed income securities tends to fall below
par value or the principal investment and when interest rates fall, the value of the investments in fixed
income securities tends to rise. In general, fixed income securities with longer maturities are more
sensitive to these price changes.
Market Risk: The value of an investment may decline based on market conditions, regardless of the
issuer’s operational success or its financial condition. As such, the value of a portfolio’s assets may
fluctuate as the stock or bond market fluctuates.
Prepayment or Call Risk: Many fixed income securities contain a provision that allows the issuer to “call”,
or redeem, all or part of the issue prior to the maturity date of the security. There is no guarantee that
investors will be able to reinvest the proceeds in a security of equivalent quality or yield characteristics.
Style Risk: The value of a portfolio may fluctuate based on the investment style employed in the
management of the portfolio. The risk of value investing includes that the price of a security may not
approach its anticipated value or may decline in value. The risk of growth investing includes that the
anticipated underlying earnings or operational growth may not occur, or the market price of the security
may decline in value.
Trading Practices: Brokerage commissions and other fees may be higher in certain markets or for foreign
securities due to lack of established government supervision and regulation of foreign securities markets,
currency markets, trading systems, and brokerage practices. Procedures and rules governing foreign
transactions and custody also may involve delays in payment, delivery, or recovery of money or
investments.
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Corporate Bonds: Corporate bonds may incur greater risk than government bonds, as corporate bonds
Risks of Specific Securities Used
are generally financed by a business or corporation and may be subject to loss of part or total value in the
event of an issuer’s bankruptcy or restructuring.
Equity Securities: While equity securities outperform other types of investments at certain times,
individual stock prices may go up and down more dramatically. A slower-growth or recessionary
economic environment could have an adverse effect on the price of all stocks.
Exchange Traded Funds: Investing in an exchange traded fund (“ETF”) often involves the same risks as
investing in the underlying securities the ETF is tracking. ETF prices may vary significantly from the Net
Asset Value due to market conditions. Certain exchange traded funds, such as inverse funds, may not
track underlying benchmarks as expected.
Municipal/Government bonds: Debt securities issued by a municipality or other government entity are
susceptible to events relating directly to the issuer or security, including economic, legal, or political
policy changes, tax base erosion, state constitutional limits on tax increases, budget deficits and other
financial difficulties, and changes in the credit rating assigned to municipal issues.
Mutual Funds: Investments in mutual funds generally involve the same risks as investing in underlying
equity or fixed income securities. Additionally, as a pooled investment vehicle, mutual funds subject
investors to other investors’ investment decisions and capital gains are spread evenly among all investors.
Mutual fund prices may vary significantly from the Net Asset Value due to market conditions.
Private Equity: Investments in private equity have specific risks given the inherent illiquid nature of the
investment and the need to lock-up capital for several years. Investors are not able to redeem their
investments at any given time. Additionally, investors may not be able to meet future capital
commitments causing investor default risk forcing investors to sell illiquid assets to meet their
commitments.
Investing in Options: Transactions in options carry a high degree of risk. A relatively small market
movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective
because market conditions may make it impossible to execute such orders. Selling ("writing" or
"granting") an option generally entails considerably greater risk than purchasing options. Although the
premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The
seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obliged
either to settle the option in cash or to acquire or deliver the underlying investment. If the option is
"covered" by the seller holding a corresponding position in the underlying investment or a future on
another option, the risk may be reduced.
There is no disciplinary activity to report.
Item 9: Disciplinary Information
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Neither CPP LLC nor its representatives are registered as, or have pending applications to become a:
Item 10: Other Financial Industry Activities and Affiliations
• Broker-dealer or representative of a broker-dealer;
• Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an
associated person of the foregoing entities.
CPP LLC may direct clients to third-party investment advisers. CPP LLC will always act in the best interests
of the client, including when determining which third party investment adviser to recommend to clients.
CPP LLC will verify that all recommended advisers are properly licensed, notice filed, or exempt in the
states where CPP LLC is recommending the adviser to clients.
Representatives of CPP LLC are licensed insurance agents and, from time to time, will offer clients advice
or insurance products from this activity. Clients should be aware that these services, in certain instances,
pay a commission or other compensation and this presents a conflict of interest, as these commissionable
insurance products conflict with the fiduciary duties of a registered investment adviser. To mitigate this
conflict, representatives of CPP LLC will act in the client’s best interest. CPP LLC’s representatives, not
CPP LLC, receives the commissions for these insurance products. Clients are not required to use these
insurance products, and CPP LLC does not charge a management fee on them.
CPP’s principal owner, Charles Capasso, is also an owner of Capasso Tax and Accounting Services LLC,
which provides tax and accounting services to clients. These services will be offered to clients of CPP, and
fees paid to CPP are separate from fees paid to Capasso Tax and Accounting Services LLC.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions, and Personal Trading
CPP LLC has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales,
Code of Ethics
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. CPP LLC's Code of Ethics is available free upon request to any client or
prospective client.
CPP LLC does not recommend that clients buy or sell any security in which a related person to CPP LLC or
Recommendations Involving Material Financial Interests
CPP LLC has a material financial interest.
From time to time, representatives of CPP LLC may buy or sell securities for themselves that they also
Investing Personal Money in the Same Securities as Clients
recommend to clients. This may provide an opportunity for representatives of CPP LLC 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
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interest. CPP LLC 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.
From time to time, representatives of CPP LLC may buy or sell securities for themselves at or around the
Trading Securities At/Around the Same Time as Clients’ Securities
same time as clients. This may provide an opportunity for representatives of CPP LLC 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,
CPP LLC will never engage in trading that operates to the client’s disadvantage if representatives of CPP
LLC buy or sell securities at or around the same time as clients.
Item 12: Brokerage Practices
Broker-dealers will be recommended based on CPP LLC’s duty to seek “best execution,” which is the
Broker Selection and Best Execution
obligation to seek execution of securities transactions for a client on the most favorable terms for the
client under the circumstances. Clients will not necessarily pay the lowest commission or commission
equivalent, and CPP LLC may also consider the market expertise and research access provided by the
broker- dealer, including but not limited to access to written research, oral communication with analysts,
admittance to research conferences and other resources provided by the brokers that may aid in CPP
LLC's research efforts. CPP LLC will never charge a premium or commission on transactions, beyond the
actual cost imposed by the broker-dealer.
CPP LLC will require clients to custody their account with Fidelity Brokerage Services LLC, or Schwab
Institutional, a division of Charles Schwab & Co., Inc.
While CPP LLC has no formal soft dollar program in which soft dollars are used to pay for third party
Research and Other Soft Dollar Benefits
services, CPP LLC may receive research, products, or other services from custodians and broker-dealers in
connection with client securities transactions (“soft dollar benefits”). CPP LLC may enter soft dollar
arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the
Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will
benefit from soft dollar research, whether or not the client’s transactions paid for it, and CPP LLC does
not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the
accounts. CPP LLC benefits by not having to produce or pay for the research, products or services, and
CPP LLC will have an incentive to recommend a broker-dealer based on receiving research or services.
Clients should be aware that CPP LLC’s acceptance of soft dollar benefits may result in higher
commissions charged to the client.
CPP LLC receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer
Brokerage for Client Referrals
or third party.
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CPP LLC does not allow its clients to direct brokerage. CPP LLC recommends one or more custodians or
Directed Brokerage
broker-dealers to effect securities transactions for its clients. The custodians or broker-dealers were
chosen based on CPP LLC’s fiduciary responsibilities to provide best execution.
If CPP LLC buys or sells the same securities on behalf of more than one client, then it may (but would be
Aggregated Trades
under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in
order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such
case, CPP LLC 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. CPP LLC would determine the
appropriate number of shares and select the appropriate brokers consistent with its duty to seek best
execution, except for those accounts with specific brokerage direction (if any).
If we have to place more than one order to fill all orders in an aggregated transaction, each client in the
aggregated transaction receives the average price for all orders placed for clients in the same aggregated
transaction in the same security for that day. If we are unable to complete a trade, the securities are
allocated to clients on a pro-rata basis.
Item 13: Review of Accounts
All client accounts for CPP LLC's advisory services are reviewed at least quarterly by a Partner of the Firm.
Advisory Clients
Each client of CPP LLC's advisory services provided on an ongoing basis will receive a monthly report
detailing the client’s account, including assets held, asset value, and calculation of fees. This statement
will come from the custodian.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by the
Financial Planning Clients
respective Partner with the client relationship. Generally, financial planning clients are provided a one-
time financial plan concerning their financial situation. After the presentation of the plan, there are no
further reports. However, clients may request additional plans or reports on an ongoing basis, for
additional fees on either a fixed or hourly rate, as disclosed in Item 5 of this brochure. Details of these
ongoing services can be found in Item 4 of this brochure.
Factors That May Trigger a Non-Periodic Review of Client Accounts
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).
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Item 14: Client Referrals and Other Compensation
With respect to Schwab, CPP LLC receives access to Schwab’s institutional trading and custody services,
Additional Benefits Received
which are typically not available to Schwab retail investors. These services generally are available to
independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at
least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services.
Schwab’s services include brokerage services that are related to the execution of securities transactions,
custody, research, including that in the form of advice, analyses and reports, and access to mutual funds
and other investments that are otherwise generally available only to institutional investors or would
require a significantly higher minimum initial investment. For CPP LLC client accounts maintained in its
custody, Schwab generally does not charge separately for custody services but is compensated by
account holders through commissions or other transaction-related or asset-based fees for securities
trades that are executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to CPP LLC other products and services that benefit CPP LLC but may not
benefit its clients’ accounts. These benefits may include national, regional or CPP LLC specific educational
events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include
occasional business entertainment of personnel of CPP LLC by Schwab Advisor Services personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms of
entertainment, some of which may accompany educational opportunities. Other of these products and
services assist CPP LLC in managing and administering clients’ accounts. These include software and other
technology (and related technological training) that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of aggregated trade
orders for multiple client accounts, if applicable), provide research, pricing information and other market
data, facilitate payment of CPP LLC’s fees from its clients’ accounts (if applicable), and assist with back-
office training and support functions, recordkeeping and client reporting. Many of these services
generally may be used to service all or some substantial number of CPP LLC’s accounts. Schwab Advisor
Services also makes available to CPP LLC other services intended to help CPP LLC manage and further
develop its business enterprise. These services may include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology, business
succession, regulatory compliance, employee benefits providers, human capital consultants, insurance
and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of
services rendered to CPP LLC by independent third parties. Schwab Advisor Services may discount or
waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-
party providing these services to CPP LLC. CPP LLC is independently owned and operated and not
affiliated with Schwab.
CPP LLC engages third parties to solicit clients for a fee. Pursuant to Rule 206(4)-1 under the Advisers Act,
Cash Solicitation Arrangements
CPP LLC is required to have a written agreement with such parties with respect to the solicitation
activities and referral fees. Clients referred pursuant to these arrangements must receive a separate
disclosure document that details the services and compensation. CPP LLC compensates such parties for
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Form ADV Part 2A: October 15, 2025
referrals out of the management fees paid by the referred clients. This does not increase the
management fee incurred by the client.
When advisory fees are deducted directly from client accounts at client's custodian, CPP LLC will be
Item 15: Custody
deemed to have limited custody of client's assets and must have written authorization from the client to
do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction,
and they should carefully review those statements for accuracy.
In certain instances, CPP LLC may be deemed to have custody due to the Firm’s authority to transfer
money from a client's account to a third party through a written standing letter of authorization (“SLOA”).
For these accounts, CPP LLC would follow guidance provided by the SEC to eliminate the requirement of
an annual surprise custody exam.
CPP LLC provides discretionary and non-discretionary investment advisory services to clients. The advisory
Item 16: Investment Discretion
contract established with each client sets forth the discretionary authority for trading. Where investment
discretion has been granted, CPP LLC generally manages the client’s account and makes investment
decisions without consultation with the client as to when the securities are to be bought or sold for the
account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price
per share. In some instances, CPP LLC’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 CPP LLC.
CPP LLC will not ask for, nor accept voting authority for client securities. Clients will receive proxies
Item 17: Voting Client Securities
directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the
issuer of the security.
CPP LLC neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or
Item 18: Financial Information
more in advance, and therefore is not required to include a balance sheet with this brochure.
Neither CPP LLC nor its management has any financial condition that is likely to reasonably impair CPP
LLC’s ability to meet contractual commitments to clients.
CPP LLC has not been the subject of a bankruptcy petition in the last ten years.
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Form ADV Part 2A: October 15, 2025