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Item 1: Cover Page
Form ADV Part 2A Appendix I
Capital Analysts, LLC
Wrap Fee Program Brochure
As of August 8, 2025
Principal Office:
601 Office Center Drive, Suite 300
Fort Washington, PA 19034
You may also visit us on the web at www.capitalanalysts.com.
This Wrap Fee Program Brochure provides information about the qualifications and business practices of Capital
Analysts, LLC, a registered investment adviser with the U.S. Securities and Exchange Commission (SEC). If you
have any questions about the contents of this brochure, please contact us at (800) 242-1421. The information in this
brochure has not been approved or verified by the SEC or by any state securities authority. Furthermore, registration
with the SEC does not imply a certain level of skill or training.
Additional information about Capital Analysts, LLC is also available on the SEC's website at
www.adviserinfo.sec.gov.
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Item 2: Material Changes
No material changes have occurred to Capital Analysts’ Form ADV Part 2A Appendix I since the firm’s annual
amendment in March 2025.
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Item 3: Table of Contents
Item 1: Cover Page ................................................................................................................................................................................................................. 1
Item 2: Material Changes ……………………………………………………………………………………………………………………….………. 2
Item 3: Table of Contents ………………………………………………………………………………………………………………………...…….. 3
Item 4: Services, Fees and Compensation ………………………………………………………………………………………...…...…....... 4
Item 5: Account Requirements and Types of Clients ………………………………………………………………………...…............ ..36
Item 6: Portfolio Manager Selection and Evaluation ………………………………………………………………………………….36
Item 7: Client Information Provided to Portfolio Managers …………………………………………………………..………… 41
Item 8: Client Contact with Portfolio Managers ……………………………………………………………………………...…….……… 41
Item 9: Additional Information ……………………………………………………………………………………………………………..…...… 41
Brochure Supplement(s) included:
•
•
Form ADV Part 2A
Investment Management & Research Team Brochure Supplement (Form ADV Part 2B)
Capital Analysts Form ADV Part 2A, Items 1-Item 17, is included and to be delivered together with
this Capital Analysts Form ADV Part 2A – Appendix I Brochure
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Item 4: Services, Fees and Compensation
This section will describe the wrap fee programs sponsored by Capital Analysts, LLC (Capital Analysts), how we
tailor these programs to your individual needs, which of our wrap fee programs allows you to impose investment
restrictions and which of our wrap fee programs are closed to new accounts. This section also provides a
description of our wrap fees, how and when these wrap fees are collected, and if refunds are available. Other types
of fees and expenses that you may incur are described below in the section titled, "Other Costs That You May
Incur." Details regarding other compensation received by Capital Analysts, its affiliates and/or your Advisor and
associated conflicts of interest are described below in the section titled, "Other Compensation to Lincoln
Investment, Capital Analysts and Our Conflicts of Interest."
Notification of Capital Analysts Advisory Programs Closed to New Accounts
Effective October 18, 2024, the following Capital Analysts advisory programs were closed to all new non-ERISA
accounts; however, new account paperwork signed and dated prior to November 15, 2024 continued to be
processed:
•
•
•
•
•
•
•
•
CAAMS/CAAMS Plus (account prefix: JKH)
CAAMS AssetBuilder (account prefix: PL8)
CAAMS Complete (account prefix: PL5)
CAAMS ETF (account prefix: PL2)
CAAMS Select Managers (account prefix: PL6)
CAAMS Stock (account prefix: PL3)
CAAMS Strategist (account prefix: XPL)
CAAMS UMA (account prefix: PL1)
Our Fiduciary Role…Capital Analysts and your Advisor assume a fiduciary duty to invest or provide to you
investment recommendations that are in your best interest. This fiduciary duty extends to all advisory accounts you
open with us, but such fiduciary duty does not extend to brokerage or other non-advisory accounts or investments.
The level of monitoring in your advisory account will depend on the advisory program you select, your advisory
agreement with us and your Advisor. If Capital Analysts or your Advisor have been granted full discretionary
trading authority over your advisory account, Capital Analysts or your Advisor will provide ongoing monitoring and
will make changes in your account as deemed necessary. If your Advisor has been granted limited discretionary
trading authority over your advisory account, your Advisor will provide ongoing monitoring. For all other non-
discretionary advisory accounts, you and your Advisor will review your advisory account’s objectives, investments
and performance relative to your objectives and financial situation at least annually to allow your Advisor the
opportunity to recommend changing or maintaining the objectives or investments in your account. See your
investment advisory agreement for the level of discretion granted to your Advisor or Capital Analysts.
Investment Advice Provided to Certain Retirement and Tax-Advantaged Accounts
When we and/or your Advisor provides investment advice to you regarding your Covered Retirement Plans, Capital
Analysts and your Advisor are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (“IRC”), 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 and your Advisor to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we and your Advisor must: meet a professional standard of care
when making investment recommendations (give prudent advice); not place 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 reasonably 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. Covered Retirement Plans include the following account types: Individual Retirement Account (“IRA”);
Individual Retirement Annuity; Roth IRA, Beneficiary IRA, Beneficiary Roth IRA; SEP-IRA, SARSEP, SIMPLE
IRA; One-Participant 401(k); Health Savings Account; Archer Medical Savings Account; Coverdell Education
Savings Account; Accounts held by ERISA Title I Plan participants/beneficiaries with authority to direct the
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distribution of assets from their account. When we provide investment advice to your Covered Retirement Plan as
described in this paragraph, we will disclose to you the types of services to be provided and material facts relating to
conflicts of interest that are associated with the recommendations made to you. These disclosures are provided to
you in various documents, including The Lincoln Investment Companies Investor Agreement and Disclosure
Handbook, Capital Analysts’ Form CRS, and its affiliated broker-dealer and investment adviser, Lincoln
Investment’s Form CRS, your Advisor’s BIO Brochure (Form ADV Part 2B), account applications, prospectuses,
and specific platform disclosure documents, and this Capital Analysts Investment Advisory Disclosure Brochure
(Form ADV Part 2A and Wrap Fee Program Brochure).
General Information Regarding Wrap Fee Programs
A Wrap Fee Program is an investment advisory program in which you pay one bundled fee to compensate Capital
Analysts and your Advisor for their services and to pay the transaction and clearing costs associated with
transactions in your advisory account. Capital Analysts also offers unbundled fee (non-Wrap fee) programs, where
you would pay a fee to compensate Capital Analysts and your Advisor for their services, but you would pay
separately the transaction and clearing costs associated with the trading in your account. These services are
described in Capital Analysts’ Form ADV Part 2A Brochure.
Capital Analysts’ Wrap Fee Programs are offered on brokerage platforms where securities such as mutual funds,
stocks, bonds, exchange traded funds (“ETFs”), exchange traded notes (“ETNs”) and options, all of which typically
have trading costs associated with them, are offered. The Wrap Fee is not based directly upon the actual transaction
or execution costs of the transactions in your account.
Depending on the underlying investments and amount of transactions you expect to trade in your account, a Wrap
Fee account may cost you more than if you chose to pay separately for all of your transaction costs (e.g., pay the
advisory fee plus all ticket charges).
Pershing and Schwab offer many mutual funds and ETFs with no transaction fees. In lieu of transaction fees,
Lincoln Investment, Capital Analysts’ introducing broker-dealer for Pershing accounts, pays an asset-based fee to
Pershing to cover the trade execution and clearing costs for equity securities, ETFs, fixed income, and options on the
Pershing platform. For mutual funds, Lincoln Investment is assessed a surcharge for transactions in certain mutual
funds, but otherwise is not assessed a transaction fee for mutual fund trades on the Pershing platform. Due to this
arrangement with Pershing, Capital Analysts has financial incentive to recommend to you no-surcharge mutual fund
only portfolios in your Wrap Accounts on Pershing in order to minimize its expenses. Where Lincoln Investment is
assessed transaction costs, Capital Analysts has a financial incentive to minimize the costs that will be assumed by
the firm on your behalf by not placing transaction orders in those accounts as doing so would increase Lincoln
Investment’s transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement.
Your Advisor will review your investment objectives with you to determine the best offering for you.
If the pricing structure of a Wrap Fee Program is suited to your needs, your Advisor will work with you to
recommend one or more specific Wrap Fee Program(s) based on your confidential investor profile, in which you
provide to Capital Analysts and your Advisor personal and financial information including, but not limited to, your
investment goals, income requirements, time horizon, and tolerance for risk in order to tailor his or her
recommendations to your needs and objectives.
You may have the opportunity to place reasonable restrictions on the types of investments that are purchased in
certain Wrap Fee Programs. Please contact your Advisor to discuss any allowable investment restrictions in the
Wrap Fee Program(s) you have selected. Further details regarding your specific Wrap Fee Program can be found in
your investment advisory agreement.
The services and costs covered by the Wrap Fee are:
• Financial and life planning consultation by your Advisor, as needed or requested by you;
•
•
Investment advice provided by Capital Analysts and your Advisor;
Investment management provided by your Advisor or Capital Analysts;
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•
•
Clearing and trading costs associated with transactions and/or positions in the account, such as ticket
charges, surcharge fees for certain no load and load waived funds and confirmation fees (for accounts
custodied at Pershing LLC only);
Short-term trading costs imposed by mutual funds and/or Pershing for trades occurring within Capital
Analysts Managed Programs or Advisor Managed Model Portfolios and Client Custom Portfolios;
Charges imposed if certain investment minimums are not met;
•
• Monitoring of your advisory account(s).
However, your Wrap Fee will not cover standard account administrative fees such as statement fees, electronic fund
and wire transfer charges, annual retirement account fees, termination fees, and fees for trades executed away from
the custodian.
You could purchase services similar to those available in Capital Analysts’ Wrap Fee Programs separately from
unaffiliated financial services providers. Wrap Fee Programs may cost you more or less than purchasing the services
from another investment adviser. Some cost factors to consider, other than the Wrap Fee itself, when considering an
advisory program include:
Commissions or ticket charges to be charged in lieu of a Wrap Fee
• Account custody fees
• Account maintenance and special handling fees, such as wire funds fees
• Volume of trading activity anticipated in your account
•
• Account termination fees
• Account statement and confirmations fees
You should review the costs for each of the management services separately, as well as consider the internal costs of
mutual funds in your account, when analyzing the total cost to you. Please contact your Advisor for a schedule of
fees and costs associated with our Wrap Fee Program(s).
The Financial Advisor Fee. Your Advisor receives a portion of the Wrap Fee you pay, which compensates your
Advisor for his or her services (“Financial Advisor Fee”). This fee is an annual fee that continues as long as you
maintain your account with us. Unless otherwise stated, your Advisor’s fee is negotiable at the Advisor’s sole
discretion and to a maximum fee that is established by Capital Analysts. The maximum annual Financial Advisor
Fee that your Advisor can charge for his/her services is 1.25% of the assets being advised or managed. The amount
of this compensation may be more than what your Advisor would receive from other advisory services offered by
Capital Analysts, or more than if you paid separately for investment advice, brokerage, and other services. Advisor
managed services and fees typically differ by Advisor, and the Financial Advisor Fee can vary based on advisory
services offered. Your Advisor will share in all or a portion of the Financial Advisor Fee based on their payout
schedule with Capital Analysts. This fee provides access to your Advisor for financial and life planning
consultation, as requested by you, as well as investment advice services which include assisting you in the
determination of the appropriate investment advisory investments and advisory programs for you, conversing with
you on an as-needed or as requested basis, but, at minimum, annually, to ensure that the investments and programs
continue to meet your stated objectives and needs. It is important therefore that you make the time to speak with
your Advisor at least annually or whenever there is a material life event that could affect or change your investment
objectives or financial needs.
In addition to the Financial Advisor Fee described above, Capital Analysts or its affiliates makes certain payments to
your Advisor upon meeting certain requirements, including, but not limited to, attaining or maintaining asset or new
account enrollment thresholds. For additional details regarding these payments including the criteria for selection
and associated conflicts of interest, see Other Compensation to Lincoln Investment, Capital Analysts and Our
Conflicts of Interest.
Description of Wrap Fee Programs and Fees
Capital Analysts sponsors the following Wrap Fee Programs:
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I.
Capital Analysts Managed Programs
CAAMS Complete (including Alternative, Yield and Custom Income Strategies)
CAAMS AssetBuilder
CAAMS ETF (including Environmental, Social and Governance (ESG) Portfolios and
Managed Volatility Portfolios)
CAAMS Stock
CAAMS UMA
CAAMS Strategist
II.
Your Financial Advisor’s Services: Advisor Consulting, Advisor Managed Model Portfolios and
Client Custom Portfolios
III.
Third-Party Managed Model and Third-Party Custom Portfolios
CAAMS Select Manager
I. Capital Analysts Managed Programs (Closed to New Accounts*)
*Capital Analysts makes available to ERISA plans certain CAAMS Complete, AssetBuilder, ETF, Stock,
UMA and Strategist Program model portfolios, with the exception of CAAMS ESG ETF model portfolios
(“CAAMS ERISA Managed Programs”). Other than the CAAMS ERISA Managed Programs, Capital
Analysts Managed Programs are closed to new accounts.
Capital Analysts Managed Programs are managed on a discretionary basis by Capital Analysts through its
Investment Management & Research (“IM&R”) team. The IM&R Team’s background is described in more detail in
the ADV 2B Brochure Supplement to this brochure.
When you select a Capital Analysts Managed Program, you must authorize, in writing, full discretionary trading
authority to the IM&R Team. “Full discretion” means your Capital Analysts has the authority to decide on the
securities to purchase, sell or trade in your account without prior consultation with you. For CAAMS Strategist
accounts, you are giving Capital Analysts full discretionary authority to manage and/or effect securities transactions
in your account based on the model portfolios provided by third-party portfolio managers. Custody and clearing
services are performed by Pershing LLC (“Pershing”). Charles Schwab & Co. is also an available custodian for
certain of the programs, as noted below.
The table below provides a comparison of Capital Analysts Managed Programs. Please refer to the specific Capital
Analysts Managed Program heading below for further information regarding the management and costs of the
program you are considering.
The Wrap Fee amounts provided below represent the maximum annual fee that may be charged.
Capital Analysts Managed Program Offerings
Custodians
Investment
Types
Capital Analysts
Managed
Program
Name
Minimum
Investment
(may be
waived)
Max.
Annual
Financial
Advisor
Fee¹
Minimum
Account Size
to Avoid $250
or $150
Annual
Management
Fee
Max.
Annual
Capital
Analysts
Program
Sponsor &
Management
Fee
Max.
Annual
Total
Wrap
Fee
(Sum of
columns
to left) ²
1.25%
1.64%
$50,000
$64,102
CAAMS
Complete
Mutual funds
and ETFs
Pershing LLC;
Charles
Schwab & Co.
0.39% or
$250,
whichever is
greater
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August 2025
Capital Analysts Managed Program Offerings
Custodians
Investment
Types
Capital Analysts
Managed
Program
Name
Minimum
Investment
(may be
waived)
Max.
Annual
Financial
Advisor
Fee¹
Minimum
Account Size
to Avoid $250
or $150
Annual
Management
Fee
Max.
Annual
Capital
Analysts
Program
Sponsor &
Management
Fee
Max.
Annual
Total
Wrap
Fee
(Sum of
columns
to left) ²
1.25%
1.64%
$50,000
$64,102
CAAMS
Alternative
Mutual funds
and ETFs
Pershing LLC;
Charles
Schwab & Co.
0.39% or
$250,
whichever is
greater
s
e
v
e
e
l
S
1.25%
1.64%
$50,000
$64,102
CAAMS
Yield
Mutual funds
and ETFs
Pershing LLC;
Charles
Schwab & Co.
0.39% or
$250,
whichever is
greater
e
t
e
l
p
m
o
C
S
M
A
A
C
1.25%
1.50%
$250,000
$100,000
Pershing LLC;
Charles
Schwab & Co.
CAAMS
Custom
Income
Strategies
0.25% or
$250,
whichever is
greater
Customizable
to include
corporate,
municipal, &
government
debt, ETFs,
options, CDs
& stocks
Mutual funds
1.25%
1.85%
$15,000
$25,000
Pershing LLC
CAAMS
AssetBuilder
0.60% or
$150,
whichever is
greater
CAAMS ETF
ETFs
1.25%
1.55%
$50,000
$83,333
Pershing LLC;
Charles
Schwab & Co.
0.30% or
$250,
whichever is
greater
CAAMS Stock
1.25%
1.70%
$50,000
$55,555
Stocks and
ETFs
Pershing LLC;
Charles
Schwab & Co.
0.45% or
$250,
whichever is
greater
1.25%
1.70%
$50,000
$55,555
Pershing LLC
CAAMS Unified
Management
Account (UMA)
0.45% or
$250,
whichever is
greater
Mutual funds,
stocks, bonds,
ETFs and
individual
money
managers
1.25%
1.85%
$50,000
$41,666
Pershing LLC
Mutual funds
and ETFs
Clark Capital
Management
Group
(CCMG)
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
DoubleLine
Tactical
Volatility
t
s
i
g
e
t
a
r
t
S
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
ICON
Advisers, Inc.
S
M
A
A
C
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
J.P. Morgan
Global Multi-
Asset
0.60% or
$250,
whichever is
greater
0.60% or
$250,
whichever is
greater
0.60% or
$250,
whichever is
greater
0.60% or
$250,
whichever is
greater
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August 2025
Capital Analysts Managed Program Offerings
Custodians
Investment
Types
Capital Analysts
Managed
Program
Name
Minimum
Investment
(may be
waived)
Max.
Annual
Financial
Advisor
Fee¹
Minimum
Account Size
to Avoid $250
or $150
Annual
Management
Fee
Max.
Annual
Total
Wrap
Fee
(Sum of
columns
to left) ²
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
Meeder
Advisory
Services, Inc.
Max.
Annual
Capital
Analysts
Program
Sponsor &
Management
Fee
0.60% or
$250,
whichever is
greater
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
0.60% or
$250,
whichever is
greater
Pacific
Investment
Management
Company
(PIMCO)3
Mutual funds
1.25%
1.85%
$50,000
$41,666
Pershing LLC
Russell
Investment
Company
0.60% or
$250,
whichever is
greater
1 Financial Advisor Fee is negotiable. Capital Analysts may also waive or negotiate Program Sponsor and Management Fees at our sole
discretion.
2 Important Note: Clients could pay higher than the percentage fee quoted as the Maximum Annual Total Wrap Fee due to the $250 and
$150 annual minimum for Capital Analysts Program Sponsor & Management Fees. See Program Sponsor & Management Fees under
each program description below for additional information regarding the impact of the minimum Capital Analysts Annual Program
Sponsor & Management Fees on client accounts.
3 PIMCO model portfolios are available only to residents of the United States.
You are responsible to notify your Advisor of any changes in your financial situation or investment objectives or to
give any investment restrictions that you wish to impose so that your Advisor can suggest the appropriate advisory
service for you. If you wish to impose investment restrictions, Capital Analysts’ Managed Programs may not be the
appropriate advisory service for you as they may not be able to accommodate your investment restrictions.
The Capital Analysts Program Sponsor & Management Fee. The Capital Analysts Program Sponsor &
Management Fee is the portion of your Wrap Fee paid to Capital Analysts for the administration and asset
management of the Capital Analysts Managed Program selected by you. The Capital Analysts Program Sponsor &
Management Fee varies depending on the Capital Analysts Managed Program selected. See the table above, as well
as the descriptions below, for the Capital Analysts Managed Programs.
All Capital Analysts Managed Programs, except the CAAMS Custom Income Portfolios, are managed as Model
Portfolios, which means the portfolio is managed to the stated objectives of the portfolio, not to your personal needs
or objectives.
Capital Analysts refunds any 12b-1 fees paid to its affiliated broker-dealer, Lincoln Investment, for Capital Analysts
advisory accounts. The refunded amounts are identified on your Pershing statement as a line item transaction labeled
“12b-1 Fee Credit”. Other custodians do not share 12b-1 fees with Lincoln Investment.
Details regarding each Capital Analysts Managed Program are below.
CAAMS Complete (Closed to New Accounts)
CAAMS Complete is comprised of model portfolios offering you a choice of portfolios primarily comprised of
mutual funds and ETFs with automatic rebalancing. Funds are selected for the CAAMS Complete portfolios
using a screening and rating methodology called Capital Analysts Performance Statistics Leaders (“CAPSL”).
The objective of CAPSL is to identify mutual funds that consistently outperform their peers and the market for
consideration of inclusion in diversified investment portfolios. While the CAPSL list represents funds that have
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August 2025
exhibited strong characteristics over full market cycles, it is by no means a buy list. On a quarterly basis, the
IM&R Team screens the vast landscape of all U.S. open-ended funds for inclusion on the CAPSL list.
Morningstar Direct is used to quantitatively screen thousands of funds. Initial screens typically include funds with
a five-year track record and those that have at least $100 million in AUM. Qualifying mutual funds are sorted by
Morningstar category and undergo a multi-factor quantitative analysis. Finalists are further subjected to style
analysis and a qualitative analysis. The final CAPSL list of approximately 125 funds represents less than 1% of
the mutual fund universe. This CAPSL list, together with occasional selected ETFs, forms the basis for CAAMS
Complete and CAAMS AssetBuilder portfolios. With the exception of CAAMS Custom Income Strategies,
Capital Analysts Wrap Programs are managed as Model Portfolios where the portfolio is managed to the stated
objectives of the portfolio, not to you or your account. The CAAMS Custom Income Strategies portfolios are
constructed on a client-by-client basis, generally utilizing a corporate, government and/or municipal bond
laddering strategy.
Seven portfolios are managed by the IM&R Team to different risk levels or objectives, each available with
standard and tax-aware options:
Focused Income
•
Conservative
•
Income & Growth
•
Balanced
•
•
Capital Growth
• Aggressive Growth
• High Equity
In addition to the seven portfolios above, CAAMS Complete offers specialized “sleeves” to be used in
conjunction with other more broadly diversified portfolios:
•
CAAMS Alternative
CAAMS Alternative model portfolio uses alternative mutual funds and ETFs to gain exposure to
alternative investments in order to complement a larger diversified portfolio.
•
CAAMS Yield
The CAAMS Yield model portfolio is focused on generating income. The portfolio typically allocates to
income producing mutual funds and ETFs to gain exposure to both high-dividend equities and yield-bearing
bonds.
•
CAAMS Custom Income Strategies
Capital Analysts offers the CAAMS Custom Income Strategies program. Custom management means your
account is constructed and managed to meet your specific objectives, on a discretionary basis. You and your
Advisor will work together to determine your specific risk tolerance and potential income needs. Your
portfolio will be structured accordingly by the IM&R Team using a laddered bond strategy which may use
corporate, municipal, and government debt, as well as other investments such as ETFs, preferred and
common stocks, and closed-end funds, covered options, and CDs to help increase yield. These portfolios
have a higher minimum investment size than other CAAMS Complete programs.
Program Sponsor & Management Fee (CAAMS Complete, excluding CAAMS Custom Income Strategies
sleeve)
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.34%
0.29%
0.24%
Assets Under Management
(minimum account $50,000)
Capital Analysts Program Sponsor
& Management Fee*
First
$500,000
0.39% or $250,
whichever is greater
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August 2025
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $64,102, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.39%,
which could make the total annual fee paid by clients exceed 1.64%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
Program Sponsor & Management Fee (Custom Income Strategies sleeve)
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.20%
0.15%
0.10%
Assets Under Management
(minimum account $250,000)
Capital Analysts Program Sponsor
& Management Fee*
First
$500,000
0.25% or $250,
whichever is greater
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $100,000, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.25%,
which could make the total annual fee paid by clients exceed 1.50%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
CAAMS AssetBuilder (Closed to New Accounts)
CAAMS AssetBuilder is comprised of model portfolios utilizing open end mutual funds only. This Program
offers you a choice of three risk levels – Moderate Conservative, Balanced, and Aggressive – with automatic
rebalancing. CAAMS AssetBuilder utilizes the same selection discipline as used for CAAMS Complete - the
Capital Analysts Performance Statistics Leaders (“CAPSL”) proprietary mutual fund research tool. See the
description of the CAAMS Complete program above for more information on mutual fund selection in CAAMS
AssetBuilder portfolios.
Program Sponsor & Management Fee
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.55%
0.50%
0.45%
First
$500,000
0.60% or $150,
whichever is greater
Assets Under Management
(minimum account $15,000)
Capital Analysts Program Sponsor
& Management Fee*
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $150.00 per year, assessed at $12.50 per month.
For account sizes less than $25,000, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.60%,
which could make the total annual fee paid by clients exceed 1.85%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
CAAMS ETF (Closed to New Accounts)
CAAMS ETF is comprised of model portfolios that invest primarily in exchange-traded funds (“ETFs”) and
certain mutual funds across asset classes and styles. Eight portfolios are managed by the IM&R Team to different
risk levels or objectives, each available with standard and tax-aware options:
Focused Income
•
Conservative
•
Income & Growth
•
Balanced
•
•
Capital Growth
• Aggressive Growth
• High Equity
• Yield
CAAMS ETF implements asset allocation models substantially the same as those used in CAAMS Complete
using selected ETFs to create portfolios that correlate closely to industry benchmarks. Use of ETFs can reduce the
internal expenses of a portfolio. The IM&R Team analyzes hundreds of ETFs representing multiple asset classes
11
August 2025
to determine those ETFs that are best suited to the asset allocation model and constructs the portfolios typically
utilizing 10-15 ETFs. The ETF screening and selection process is accompanied by strategic asset allocation
analysis. Portfolios are rebalanced and reallocated as necessary.
CAAMS ETF Managed Volatility Model Portfolios. Capital Analysts also offers a Managed Volatility option.
Designed to reduce fluctuations of the portfolio over a market cycle, particularly during periods of heightened
volatility, these portfolios are based on the same asset allocation models as other CAAMS ETF portfolios but are
constructed using ETFs that are overweight low-volatility securities within a given asset class. The Managed
Volatility portfolios may sacrifice some potential gains in exchange for the possibility of avoiding large losses.
Because of the effect of managed volatility ETFs on the overall risk-return profile of a portfolio, the Managed
Volatility option is available for each of the following portfolios only:
Income & Growth
Capital Growth
•
•
• High Equity
CAAMS ESG ETF Model Portfolios. Capital Analysts Environmental, Social, and Governance (“ESG”) ETF
strategies are globally diversified portfolios that employ an actively managed investment approach with asset
allocation, using exchange traded funds (“ETFs”) representing multiple asset classes and styles. These portfolios
focus on ESG ETFs that invest in securities issues by companies and governments performing well in areas of
environmental, social and governance issues. The ETFs offer the potential for long-term growth or income while
seeking to mitigate risk exposures from ESG-related issues. See Item 6: Portfolio Manager Selection and
Evaluation for more information on Environmental, Social and Governance (“ESG”) investing and our CAAMS
ESG ETF model portfolios. The ESG ETF portfolios are available for each of the following portfolios:
Focused Income
•
Conservative
•
Income & Growth
•
Balanced
•
•
Capital Growth
• Aggressive Growth
• High Equity
CAAMS ESG ETF portfolios are not available to ERISA plans.
CAAMS ETF BlackRock Target Allocation ETF Models. The BlackRock Target Allocation models are a
dynamically managed model portfolio series that uses BlackRock ETFs. The models start by setting a strategic
asset allocation for each of the ten risk levels and then will make tactical allocations based on the macroeconomic
and investment environment. The models will keep equity allocations within 5% of the target, while duration will
be managed in the fixed income portion based of the forecasted path of interest rates. While the models are
tactical, they tend to make smaller, less frequent moves, trading just four to six times per year on average. Each
BlackRock Target Allocation ETF Model is also available as a Target Allocation ESG ETF Model. The Target
Allocation ESG ETF Models are not available to ERISA plans. Available model portfolios are indicated below:
•
•
•
•
•
•
•
•
•
•
•
Target Allocation 0% Equity / 100% Fixed Income
Target Allocation 10% Equity / 90% Fixed Income
Target Allocation 20% Equity / 80% Fixed Income
Target Allocation 30% Equity / 70% Fixed Income
Target Allocation 40% Equity / 60% Fixed Income
Target Allocation 50% Equity / 50% Fixed Income
Target Allocation 60% Equity / 40% Fixed Income
Target Allocation 70% Equity / 30% Fixed Income
Target Allocation 80% Equity / 20% Fixed Income
Target Allocation 90% Equity / 10% Fixed Income
Target Allocation 100% Equity / 0% Fixed Income
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August 2025
Program Sponsor & Management Fee
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.25%
0.20%
0.15%
First
$500,000
0.30% or $250,
whichever is greater
Assets Under Management
(minimum account $50,000)
Capital Analysts Program Sponsor
& Management Fee*
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $83,333, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.30%,
which could make the total annual fee paid by clients exceed 1.55%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
CAAMS Stock (Closed to New Accounts)
CAAMS Stock is composed of model portfolios offering core multi-cap, multi-style equity portfolios diversified
by individual stocks across industry groups and sectors. Where applicable, the IM&R Team will also work with
you and your Advisor to identify tax loss harvesting opportunities in your CAAMS Stock account.
CAAMS Stock portfolios represent select groups of stocks chosen primarily from the industry groups and
economic sectors in the S&P Composite 1500. ETF that track components of the S&P Composite 1500 or other
broad-based indexes, as well as ETFs that track international or dividend stock indexes, may be used for some
portfolios.
Six portfolios are managed by the IM&R Team to different objectives:
Core Equity
Core Equity Plus
•
•
• Global Equity
Capital Appreciation
•
•
Equity Income
• Dividend Growth
Program Sponsor & Management Fee
Assets Under Management
(minimum account $50,000)
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.35%
0.25%
0.20%
First
$500,000
0.45% or $250,
whichever is greater
Capital Analysts Program Sponsor
& Management Fee*
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $55,555, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.45%,
which could make the total annual fee paid by clients exceed 1.70%. This minimum annual fee would have a greater relative impact
on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
CAAMS Unified Management Account (UMA) (Closed to New Accounts)
CAAMS UMA portfolios use both active and passive investment approaches in a single account that combines
individual securities from the CAAMS Stock portfolios, ETFs, and mutual funds. These portfolios are appropriate
for investors who are interested in a professionally managed account providing the tax efficiency of individual
securities and ETFs, and who want their holdings diversified across asset classes and industry groups.
Five portfolios are managed by the IM&R Team to different risk levels or objectives:
Income & Growth
Balanced
•
•
• Growth
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August 2025
• Aggressive Growth
• High Equity
Custom portfolios managed by the IM&R Team may also be available in the CAAMS UMA Wrap Fee Program.
Program Sponsor & Management Fee
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.35%
0.25%
0.20%
First
$500,000
0.45% or $250,
whichever is greater
Assets Under Management
(Minimum account $50,000)
Capital Analysts Program Sponsor
& Management Fee*
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $55,555, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.45%,
which could make the total annual fee paid by clients exceed 1.70%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
CAAMS Strategist (Closed to New Accounts)
CAAMS Strategist provides access to mutual fund and ETF model portfolios developed and managed by certain
third-party money managers (“Strategists”) selected by Capital Analysts and the IM&R Team. Strategists are
registered investment advisers unaffiliated with Capital Analysts, but have entered into agreement(s) to provide
the model portfolios, as well as certain research and marketing services.
The current Strategists are Clark Capital Management Group, DoubleLine Capital LP, ICON Advisers, Inc., J.P.
Morgan Investment Management Inc., Meeder Advisory Services, Inc., Pacific Investment Management
Company, and Russell Investment Company each offering the respective portfolios described below.
Clark Capital Management Group
Clark Capital Management Group (“CCMG”) model portfolios are composed of mutual funds and exchange-
traded funds (“ETFs”) from multiple fund families, as well as affiliated funds (Navigator Funds). CCMG
utilizes their proprietary quantitative model to tactically position the portfolios in a "risk-on" or "risk-off"
allocation. The Navigator® Global Risk Management strategies seek to provide investors the potential for
higher returns in the global equity markets with the ability to shift to safer U.S. fixed income sectors.
Developed and managed by CCMG’s Investment Team, the strategies are available in three risk allocation
profiles: conservative, moderate and growth. CCMG’s tactical approach seeks to identify and adapt to
changing market themes in an effort to manage volatility in the portfolios over a full market cycle and deliver
successful outcomes to investors.
• Global Risk Managed Conservative
• Global Risk Managed Moderate
• Global Risk Managed Growth
•
Tactical Investment Grade Bond
DoubleLine Capital LP – Minimum Volatility
DoubleLine Capital LP (“DoubleLine”) model portfolios are composed solely of their affiliated funds
(“DoubleLine Funds”). Developed and managed by DoubleLine, they offer total return fixed income minimum
volatility model portfolios. DoubleLine employs active management of asset class exposure, sector allocations,
and security selection to manage volatility in the portfolios over a full market cycle. Tactical allocations may
be made as opportunities arise. The portfolios exclusively use mutual funds managed by DoubleLine to
implement this strategy.
Conservative
•
• Moderate Conservative
• Moderate
• Moderate Aggressive
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August 2025
ICON Advisers, Inc.
ICON Advisers, Inc. (“ICON”) model portfolios are composed solely of their affiliated funds (“ICON Funds”).
ICON brings an analytical logic to the world of investing that aims to reduce subjective decision-making. It
enables ICON to challenge conventional wisdom based on disciplined, objective, non-emotional methodology.
Led by co-founder and Chief Investment Officer Dr. Craig Callahan, ICON applies the Science of Investing to
attempt to identify industries that are underpriced. Dr. Callahan has created a valuation model that advanced
the methodology, originally developed by Benjamin Graham, by adapting it to today’s ever-changing market
conditions.
•
ICON US Income
J.P. Morgan Investment Management, Inc. – Global Multi-Asset
J.P. Morgan Investment Management, Inc. (“J.P. Morgan”) model portfolios are composed solely of their
affiliated funds (J.P. Morgan Funds). Developed and managed by J.P. Morgan, the Global Multi-Asset strategy
provides five (5) risk-based model portfolios. J.P. Morgan uses both strategic and tactical asset allocation
driven by both quantitative and qualitative analysis across widely diversified asset classes. The portfolios
exclusively use mutual funds managed by J.P. Morgan to implement this strategy.
Conservative
•
• Moderate Conservative
• Moderate
• Moderate Growth
• Growth
Meeder Advisory Services, Inc.
Meeder Advisory Services, Inc. (“Meeder”) model portfolios are composed solely of their affiliated funds
(Meeder Funds). Developed and managed by Meeder, Meeder offers six (6) risk-based Tactical Allocations
Master model portfolios. Meeder uses tactical asset allocation to adjust among asset and sub-asset classes
based on short- to intermediate-term market forecasts, with the objective of exploiting inefficiencies or
temporary imbalances among them. The portfolios exclusively use mutual funds managed by Meeder to
implement this strategy.
Flexible Income
Conservative
Balanced
•
•
• Moderate Conservative
•
• Moderate Growth
• Growth
Pacific Investment Management Company
Pacific Investment Management Company (“PIMCO”) model portfolios are composed solely of their affiliated
funds (“PIMCO Funds”). Developed and managed by PIMCO, they offer model portfolios geared toward
producing income. PIMCO employs active management of asset class exposure, sector allocations, and
security selection to manage risk and generate current income over a full market cycle. The portfolios
exclusively use mutual funds managed by PIMCO to implement this strategy. Each portfolio is available as a
taxable model or tax-aware model.
•
•
•
Capital Preservation
Enhanced Core
Income Focus
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August 2025
Russell Investment Company
Russell Investment Company portfolios are composed solely of their affiliated funds (“Russell Funds”). This is
a strategic asset allocation strategy that uses a long-term approach to investing that mixes fundamental asset
classes into a target portfolio. Because the Russell portfolios are constructed for long-term investors, short and
intermediate term conditions are not a dominant factor in determining the allocations. The Russell portfolios are
rebalanced on a semi-annual basis (typically March and September) to maintain the original balance.
The Russell investment philosophy is rooted in the belief that financial markets reward knowledgeable,
disciplined investors. Based on a philosophy that over a long period of time active managers can add value,
Russell selects teams of money managers to help meet clients’ investment goals. Russell aims to reduce risk and
attempts to provide benchmark-beating returns both collectively and over time.
•
•
•
•
•
Tax Managed Conservative
Tax Managed Moderate
Tax Managed Balanced
Tax Managed Growth
Tax Managed Equity Growth
Program Sponsor & Management Fee
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.55%
0.50%
0.45%
First
$500,000
0.60% or $250,
whichever is greater
Assets Under Management
(minimum account $50,000)
Capital Analysts Program Sponsor
& Management Fee*
* The minimum annual Capital Analysts Program Sponsor & Management Fee is $250.00 per year, assessed at $20.83 per month.
For account sizes less than $41,666, the client is paying a Program Sponsor & Management Fee in excess of the stated 0.60%,
which could make the total annual fee paid by clients exceed 1.85%. This minimum annual fee would have a greater relative
impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a percentage on smaller accounts.
Capital Analysts Managed Programs – ERISA
Capital Analysts also makes available to ERISA plans certain CAAMS Complete, AssetBuilder, ETF, Stock,
UMA and Strategist Program model portfolios, with the exception of CAAMS ESG ETF model portfolios
(“CAAMS ERISA Managed Programs”). The Program Sponsor & Management Fee for Capital Analysts
CAAMS ERISA Managed Programs offered to ERISA plans is shown below:
Program Sponsor & Management Fee
Assets Under Management
(minimum account $50,000) ¹
First
$500,000
Next
$500,000
Next
$1,000,000
Over
$2,000,000
0.34%
0.29%
0.24%
0.39% or $250,
whichever is greater
Capital Analysts Program Sponsor
& Management Fee²
¹ Minimum account size for CAAMS AssetBuilder is $15,000. Minimum account size for CAAMS Stock and CAAMS UMA is
$50,000.
² With the exception of the CAAMS AssetBuilder program, the minimum annual Capital Analysts Program Sponsor &
Management Fee is $250.00 per year, assessed at $20.83 per month. For account sizes less than $64,102, the client is paying a
Program Sponsor & Management Fee in excess of the stated 0.39%, which could make the total annual fee paid by clients exceed
1.64%. For CAAMS AssetBuilder, the minimum annual Capital Analysts Program Sponsor & Management Fee is $150.00 per
year, assessed at $12.50 per month. For account sizes less than $25,000, the client is paying a Program Sponsor & Management
Fee in excess of the stated 0.60%, which could make the total annual fee paid by clients exceed 1.85%. These minimum annual
fees would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a
percentage on smaller accounts.
16
August 2025
II. Your Financial Advisor’s Services: Advisor Consulting, Advisor Managed Model Portfolios and Client
Custom Portfolios
Unless otherwise stated, your Advisor’s fee is negotiable at the Advisor’s sole discretion and to a maximum fee
that is established by Capital Analysts. Advisor managed services and fees typically differ by Advisor, and the
Financial Advisor Fee can vary based on advisory services offered. Your Advisor will share in all or a portion of
the Financial Advisor Fee based on their payout schedule with Capital Analysts. The maximum annual fee that
your Advisor can charge (“Advisor Fee”) for his/her services is 1.25% of the assets being advised or managed.
In addition to the Financial Advisor Fee described above, Capital Analysts or its affiliates makes certain
payments to your Advisor upon meeting certain requirements, including, but not limited to, attaining or
maintaining asset or new account enrollment thresholds. For additional details regarding these payments
including the criteria for selection and associated conflicts of interest, see Other Compensation to Lincoln
Investment, Capital Analysts and Our Conflicts of Interest.
For Accounts Custodied at Pershing
Advisor Managed Model Portfolios and Client Custom Portfolios accounts opened on Pershing are offered as
Wrap Fee Programs, meaning you pay one bundled fee to compensate Capital Analysts and your Advisor for
their services and to pay the transaction and clearing costs associated with transactions in your advisory account.
The Wrap Fee will cover: (1) the advice provided to you by your Financial Advisor and Capital Analysts, (2)
trading and clearing costs associated with transactions and/or positions in the Account, such as ticket charges and
surcharge fees for certain no-load and load-waived funds, (3) short-term trading costs imposed by mutual funds
and/or Pershing, (4) charges imposed if certain investment minimums are not met, and (5) trade confirmation
fees. The Fee you pay will not cover other standard account administrative fees such as statement fees, electronic
fund and wire transfer charges, annual IRA custodial and termination fees.
An annual Capital Analysts Administrative Fee will be assessed in addition to your Advisor’s Fee. The
Administrative Fee is assessed on a monthly basis. The Capital Analysts Administrative Fee for Advisor
Managed Model Portfolios and Client Custom Portfolios is shown below:
Administrative Fee (Closed to New Accounts Other than Advisor Managed Model Portfolios and Client
Custom Portfolios ERISA Accounts)
Assets Under Management
Next
$500,000
Next
$1,000,000
Over
$2,000,000
Capital Analysts Administrative Fee¹ ²
0.12%
0.10%
0.08%
First
$500,000
0.15% or $200,
whichever is greater
¹ The minimum annual Capital Analysts Administrative Fee is $200.00 per year, assessed at $16.67 per month. For account
sizes less than $133,333, the client is paying an Administrative Fee in excess of the stated 0.15%. This minimum annual fee
would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a
percentage on smaller accounts.
² The Administrative Fee schedule shown above also applies to Capital Analysts Advisor Managed Model Portfolios and Client
Custom Portfolios offered to ERISA plans.
Your Advisor’s role is to earn and maintain a relationship with you to provide you financial and life planning
and consultation, as requested by you, as well as investment advice services which includes assisting you in the
determination of the appropriate investment advisory investments and advisory programs for you, conversing
with you on an as-needed or as requested basis, to ensure that the investments and programs continue to meet
your stated objectives and needs. Some advisors may also provide supplemental reports on a periodic basis to
assist you in evaluating the effectiveness of the investments and advisory program(s). Capital Analysts Advisors
may provide periodic non-discretionary investment advice to their clients, or certain Advisors provide ongoing
discretionary management to their clients. The Advisor has the responsibility to select securities or make
recommendations based on your needs and objectives, but if the advisor does not have written discretionary
authority over your account, he/she cannot purchase or sell securities without first obtaining your approval. All
advice is geared to meet the client’s risk tolerance, income, any investment restrictions, and tax management
17
August 2025
objectives, if applicable. Advisor Managed Portfolios generally allocate to securities including, but not limited
to, mutual funds, ETFs, ETNs, stocks, bonds and options.
For those Advisors who have been granted the authority to manage accounts on an ongoing discretionary basis,
discretionary authority may be exercised using Model Portfolios, where your account is managed to the stated
objectives of the portfolio, or custom managed, where your account is constructed and managed to meet your
specific objectives (“Client Custom Portfolios”). Discretionary authority granted to Advisors may be limited or
full. “Full discretion” means your Advisor has the authority to decide on the securities to purchase, sell or trade
in your account without prior consultation with you. “Limited discretion” means that your Advisor has limited
authority to select the time and/or price of the security to be purchased or sold, and/or if applicable to rebalance
your account back to a pre-stated asset allocation of pre-selected securities. Limited Discretion, which has been
granted to all advisors with respect to Advisor Managed Model Portfolios and Client Custom Portfolios held at
Pershing, allows them, when necessary, to liquidate shares in one or more securities for the sole purpose of using
proceeds to satisfy a shortfall in funds available for the deduction of the monthly investment advisory fee. An
Advisor with limited discretion does not have the authority to select new securities to be purchased in your
account. The final decision regarding any new security, whether to buy or sell, remains with the client in a
Limited Discretion account. Your written investment advisory agreement will identify whether, and to what
degree, you have granted your Advisor discretionary authority on your account.
Each Capital Analysts Advisor may follow a different investment discipline and may or may not establish a
minimum investment amount. The fees charged by Advisors on Advisor Managed Model and Client Custom
Portfolios will vary depending on the platform utilized and the individual Advisor. Most Capital Analysts
Advisors manage or advise portfolios containing securities such as, but not limited to, mutual funds, ETFs,
ETNs, stocks, bonds and options. Consult with your Advisor to learn more about the advisory services and fees
he or she offers. Your Advisor’s education, licenses and professional designations are described in Form ADV
Part 2B Brochure Supplement, a copy of which your Advisor will provide to you.
Advisor Managed Model Portfolio and Client Custom Portfolio Offerings
Advisory Offering
Investment Types
Custodian of Assets
Minimum
Investment
Mutual funds
Pershing LLC
Depends on
platform and
individual Advisor
Advisor Consulting with
Advisor Managed Model
Portfolios and/or Client
Custom Portfolios
Pershing LLC
Depends on
platform and
individual Advisor
Advisor Consulting with
Advisor Managed Model
Portfolios and/or Client
Custom Portfolios
General Securities such
as, but not limited to,
mutual funds, stocks,
bonds, ETFs, ETNs,
options
III. Third-Party Managed Model and Third-Party Custom Portfolios
CAAMS Select Manager (Closed to New Accounts Other than Third-Party Managed Model and Third-
Party Custom Portfolios ERISA Accounts)
For the CAAMS Select Program, Capital Analysts has entered into agreements with the Select Managers
establishing the maximum Select Manager Fees that may be charged. The maximum annual advisory fee
shown in the table below compensates the Select Manager, Capital Analysts, and your Advisor. The Select
Manager Fee will generally range between 0.40% and 0.65% for equity accounts and between 0.25% and
0.50% for fixed income accounts. The Select Manager Fee will be identified in your investment advisory
agreement, which you should carefully review prior to signing. An annual Capital Analysts Administrative Fee
18
August 2025
will be assessed in addition to your Advisor’s Fee and the Select Manager Fee. The Capital Analysts
Administrative Fee for the CAAMS Select Manager Program is shown below:
Administrative Fee
First
$500,000
Next
$500,000
Next
$1,000,000
Over
$2,000,000
Assets Under Management
(minimum account size varies by
manager)
Capital Analysts Administrative Fee1 2
0.12%
0.10%
0.08%
0.15% or $200,
whichever is greater
¹ The minimum annual Capital Analysts Administrative Fee is $200.00 per year, assessed at $16.67 per month. For account
sizes less than $133,333, the client is paying an administrative fee in excess of the stated 0.15%. This minimum annual fee
would have a greater relative impact on the total fee paid by smaller accounts; fees can exceed the stated maximums as a
percentage on smaller accounts.
² The Administrative Fee schedule shown above also applies to ERISA plans in the CAAMS Select Manager program.
In the CAAMS Select Program, the IM&R Team will work with you and your Advisor to assist in the selection
of one or more third-party portfolio managers, called Select Managers, based on your investment objectives
and risk tolerance. Capital Analysts relies on the expertise and management disciplines of these Select
Managers when they are engaged to manage your assets to their stated discipline and risk level. Capital
Analysts, however, retains the authority to terminate a Select Manager at any time. If a Select Manager is
removed from Capital Analysts’ offerings, Capital Analysts will notify you in writing and allow you the
opportunity to change Select Managers.
You will enter into an agreement with Capital Analysts and, depending upon the Select Manager, a separate
agreement with that Select Manager that you choose to provide asset management services. The Select
Manager exercises discretionary authority to determine the securities to be purchased and sold in your
CAAMS Select account. Clearing and custody services are provided by Pershing. Select Managers have
account minimum requirements that will vary. A list of Select Managers is shown below. A complete
description of each Select Manager’s services, fee schedules, and account minimums will be disclosed in the
Select Manager’s respective Forms ADV 2A, Wrap Brochures, or similar disclosure brochures provided to you
at or before the time your Capital Analysts agreement is executed and the account is established.
CAAMS Select Managers
Select Manager
Investment Discipline(s)
Minimum
Investment
Max. Annual
Fee to Client
$250,000
1.70%
Intermediate Taxable Fixed Income,
Municipal Fixed Income
$100,000
1.80%
Large-Cap Value
$100,000
1.90%
Multi-Cap Value
Davidson Investment
Advisors, Inc.
First Fiduciary
Investment Counsel
Fiduciary Trust
Company International
of Pennsylvania
$1,000,000
2.00%
Fort Washington
Investment Advisors,
Inc.
$250,000
1.90%
Active Corporate¹, Core Fixed¹,
Intermediate Fixed¹, Municipal Bond,
Small Company Fund, International
Equity, Focused Equity, Large Cap
Focused Equity, Full Discretion Fixed
Income (LLC)
Quality Growth, Dividend and Yield,
Growth and Income
$500,000
2.05%
Global Balanced
$250,000
1.70%
Domestic Fixed Income
The Haverford Trust
Company
One Capital
Management, LLC
RNC Genter Capital
Management
19
August 2025
CAAMS Select Managers
Select Manager
Investment Discipline(s)
Minimum
Investment
Max. Annual
Fee to Client
$100,000
1.90%
$1,000,000
1.90%
$100,000
1.90%
$500,000
1.90%
Thornburg Investment
Management, Inc.
Todd Asset Management
Uniplan Investment
Counsel, Inc.
Wright Investors’
Service, Inc.
Core Value Equity, Municipal Fixed
Income²
Large-Cap Intrinsic Value
Real Estate Investment Trusts
(“REITs”)
Large Cap Core Equity, Dividend
Income
Each Select Manager sets its own investment management fee, which generally ranges between 0.40% - 0.65% for equity accounts
and 0.25% - 0.50% for fixed income accounts, although some Select Managers may assess fees that are higher or lower. Each
Select Manager’s current fees are listed in its Form ADV 2A and/or Form ADV 2A & Appendix I, which your Advisor should
provide you.
¹ Active Corporate has a minimum investment of $3,000,000. Core Fixed and Intermediate Fixed have minimum investments of
$5,000,000.
² Municipal Fixed Income has a minimum investment of $1,000,000.
Additional Information Regarding Wrap Program Fees
The Wrap Fee Programs described above may cost more or less than if you were to purchase such services
separately. Certain factors, such as trading frequency, can impact the cost effectiveness of such Wrap Fee Programs.
Generally, in an account where there is infrequent trading, a regular brokerage account incurring transaction fees
along with the separate purchase of such investment advice for a fee may be less expensive. Your Advisor shares in
the portion of the Wrap Fee that is identified as the Advisor Fee.
The Wrap Fee may cover various services rendered and costs incurred under the selected program including client-
advisor consultations, transaction costs, investment management, and performance reporting. However, securities
transactions executed in your program account(s) may also include mark-ups, markdowns or dealer spreads paid to
market makers or other principals from whom securities were obtained. These mark-ups, markdowns or dealer
spreads will be retained by the market maker or other principal and will not be credited or reimbursed to your
account, Capital Analysts, or its affiliate, Lincoln Investment. Capital Analysts offers fee schedules that vary by
platform, program and the size of the assets in your advisory account. Your fee schedule will be reflected in your
Capital Analysts investment advisory agreement.
For the majority of CAAMS Wrap Fee Programs offered by Capital Analysts, your Wrap Fee will be assessed on a
monthly basis in advance of services rendered and will be based on the account value on the last business day of the
prior month. For some clients, fees are assessed monthly in arrears, as indicated in your agreement with Capital
Analysts; this is no longer offered to new clients. The specific manner in which advisory fees are calculated and
charged is established in your written investment advisory agreement with Capital Analysts. In your investment
advisory agreement, you must also authorize Capital Analysts to directly debit advisory fees from your account.
Fees may be deducted from cash holdings or by liquidating assets held in the account at the discretion of Capital
Analysts or your Advisor. Fees for the first month in which services are provided will be assessed based on the
assets deposited into the account, and prorated for the number of days for which advisory services are provided in
that month for those assets. Capital Analysts will not assess fees for any subsequent deposits or refund fees for
withdrawals occurring within the month, other than the initial deposit. For advisory services terminated during the
month, any prepaid, unearned fees will be refunded on a pro-rata basis, and any earned, unpaid fees will be due and
payable on a pro-rata basis. See your investment advisory agreement for pro-rata fee assessments and refunds
thresholds as these vary by platform and program. Capital Analysts can waive or negotiate advisory fees at our sole
discretion.
In general, a client may terminate Capital Analysts advisory services at any time upon written notice to us. The
death of a client also constitutes termination of any agreement with Capital Analysts, though an executor or other
authorized representative may choose to continue services under a new or modified agreement. Clients remain
responsible to pay fees for services performed but not yet billed.
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For assets held on platforms other than Pershing, see your investment advisory agreement for billing details,
including the frequency of fees assessment, whether your fee is assessed in advance or arrears of services rendered,
and any applicable thresholds for inception billing, termination billing, and initial and interim billing on deposits and
withdrawals as these can vary by platform and program.
You could purchase products or services similar to those offered by Capital Analysts separately from our affiliated
investment adviser, Lincoln Investment Planning, LLC or from any financial services provider. Capital Analysts may
offer employees, it’s Advisors, and family members a discount or waiver of Wrap Fee Program fees.
Other Fees in Wrap Fee Accounts
The Wrap Fee will cover the advice provided to you and all trading and clearing costs associated with transactions in
the account, including clearing and trading costs associated with transactions and/or positions in the account, such as
ticket charges, surcharge fees for certain no-load and load-waived funds, and confirmation fees. You will, however,
be responsible for other account service fees that may be imposed by Pershing, such as: IRA Custody/annual
retirement account fees, termination fees, fees for trades executed away from the custodian, wire transfer and
electronic fund fees, statement delivery charges and any expenses of the underlying investments in your account.
For information on the fees applicable to accounts held at Pershing, please refer to
www.lincolninvestment.com/Disclosures for the Lincoln Investment Trading Fees, Account Service Fees and
Disclosures - Accounts Held on Pershing Platform or ask your Advisor.
Other Costs That You May Incur
Total advisory fees paid and other costs associated with your portfolio impact the overall performance of your
portfolio. It is important to review these costs when making your advisory and investment decisions. Costs may
include the following:
1. Mutual Fund 12b-1 Distribution Fees. An expense within some mutual fund share class offerings is a Mutual
Fund Distribution Fee, also called a 12b-1 fee, which is paid to your broker-dealer. For all Capital Analysts
advisory accounts on Pershing’s platform, when Lincoln Investment is the introducing broker-dealer on your
advisory account and where the 12b-1 fee is paid to Lincoln Investment, we have instructed Pershing to directly
refund this fee to your account. You may still incur a 12b-1 fee expense for any portion of the 12b-1 fee
expense that the fund does not share with Pershing or that Pershing does not share with Lincoln Investment.
This fee-offset or crediting of 12b-1 fees will alleviate the conflict of interest associated with Lincoln
Investment receiving this third-party compensation and will also reduce the expense to you associated with
purchasing a mutual fund share class which includes a 12b-1 fee expense. Whether you receive and the manner
in which you receive this credit depends on the platform where your advisory assets are held.
2.
Internal Expenses. Internal management fees, other fund charges or other expenses charged by the mutual fund
or sub-account of a variable annuity (also known as the internal expense). All mutual funds and annuity
companies charge a fee for the management and operations of their offerings. Higher internal expenses can
adversely affect the long-term performance of your portfolio when compared to share classes of the same fund
that assess lower internal expenses. For more complete information regarding the internal expenses of an
investment and how they impact your costs and performance, you should read “Understanding Share Classes
within your Investment Advisory Accounts” below.
3. Platform Fees. Capital Analysts offers its advisory services on various broker-dealer platforms. Each platform
assesses different account fees, such as platform fees, ticket charges, commissions, wire fees, trade-away fees,
statement and confirmation fees, retirement plan recordkeeping or custodial fees, and low balance or account
termination fees. Depending on the platform/custodian selected, some fees can be avoided or reduced. For
instance, applicable fees will be different for an account opened on Pershing versus accounts opened on another
third-party platform/custodian. For a description of trading and administrative fees associated with where your
account will be held, view the specific platform disclosure document for your account found at
www.lincolninvestment.com/Disclosures.
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4. Mutual Fund Surcharge Fees. Some custodians and platforms assess a surcharge fee for transactions in certain
mutual fund share classes, typically to offset the costs of providing services when the mutual fund does not pay
the custodian or platform directly.
5. Mutual Fund Short-term Trading Redemption Fees. Some mutual funds impose short-term trading
redemption fees of up to 2% for active trading or exchanging in and out of their funds. Ticket charges may also
be imposed if certain fund minimums are not met. This could affect you or your investment adviser’s ability to
properly manage your portfolio as these costs will impact the performance of your portfolio or may be an
incentive not to trade. Capital Analysts’ decision to reallocate your account assets may result in you incurring a
redemption fee imposed by one or more mutual funds held in your account.
6. Variable Annuity Rider and Contract Costs. These costs may include, but are not limited to, annual base
annuity contract charges, optional benefit riders, underlying sub-account expenses, and potential surrender fees.
7. Retirement Plan Rollovers. If you decide to roll assets out of a retirement plan, such as a 401(k) plan, into an
individual retirement account ("IRA"), we have a financial incentive to recommend that you invest those assets
with us because we will be paid an advisory fee on those assets, and other compensation. You should be aware
that such fees would likely be higher than those you would pay through the plan, and there can be additional
costs and expenses, such as custodial fees and account fees. As securities held in a retirement plan are generally
not transferred to an IRA, commissions and sales charges may be charged when liquidating such securities prior
to the transfer, in addition to commissions and sales charges previously paid on transactions in the plan. For
more information about rollovers, see The Lincoln Investment Companies Investor Agreement and Disclosure
Handbook.
You may incur additional charges imposed by custodians, broker-dealers, investment and insurance companies and
other third parties, such as transfer taxes, wire transfer and electronic fund fees and other fees and taxes on
brokerage accounts and securities transactions. Such charges and fees are exclusive of and in addition to Capital
Analysts’ fee. You shall be responsible for payment of any and all taxes that may be due as a result of any
transactions in your account.
Other Compensation to Lincoln Investment, Capital Analysts and Our Conflicts of Interest
Capital Analysts recognizes its fiduciary responsibility to place your interests above ours and that other
compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked
upon by you as an incentive for us to recommend investment products or advisory services based on compensation
rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the
conduct of our business that we believe could be material. With many of these conflicts, we have taken steps to
mitigate or reduce the conflict.
Understanding Share Classes in Capital Analysts Advisory Accounts
Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests
the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These
internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that
manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the
fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and
expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns.
A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or
portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different
returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or
servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees
and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes
that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other
words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on
the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers
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on particular share classes, such as transaction fees at the time of buying or selling the fund shares and are in
addition to the investment advisory fee you will pay.
The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual
operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual
fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can
vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase
may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may
become available with different expense ratios.
Capital Analysts looks at the “Prospectus Net Expense Ratio” as provided by Morningstar, a third-party data
provider, for each mutual fund share class to determine the least expensive eligible share class. The Prospectus Net
Expense Ratio is a fund’s stated total annual operating expense percentage after any contractual fee waivers or other
expense reimbursements to the fund.
Capital Analysts’ Share Class Selection Policy for Advisory Accounts
This share class selection policy applies to your advisory assets that are custodied at Pershing and for which Capital
Analysts and/or your financial professional initiate the trade and is described below.
Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund
that can impact the performance of your investment over time. Regardless of whether you have selected a
discretionary asset management program or a non-discretionary advisory program, share class selection for your
mutual fund purchases within your advisory account will be determined by Capital Analysts. Share class expenses
can vary across different share classes of the same fund. In furtherance of its fiduciary duty to advisory clients,
Capital Analysts will seek to select the least expensive share class available at Pershing for the selected mutual fund
for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the
Sweep Program are treated differently, as described below). For purposes of this policy, the least expensive share
class is defined as the share class of a mutual fund that has the lowest prospectus net expense ratio as published by
Morningstar, subject to the share classes’ investment minimums being appropriate for all of our retail advisory
investors, obtaining investment minimum waivers where they are available, and selecting a share class that is
available to all investors regardless of account tax type. Capital Analysts will also consider various other factors
when considering share class conversions in your advisory accounts, including but not limited to, whether the fund
will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in the
expense ratio between the existing share class and the new, proposed share class. The fund share class used in an
IM&R discretionary managed Model Portfolio can be different than for other Capital Analysts non-discretionary
advised accounts, as a fund minimum waiver may be available for discretionary IM&R Managed Model Portfolios
but not for non-discretionary advisory accounts. Most mutual funds offer varying share classes but all custodians
may not make all share classes of a mutual fund available; therefore, the designated share class selected by Capital
Analysts will likely vary across custodial platforms.
If the fund and share class selected includes a 12b-1 fee, Pershing continues to be instructed on our behalf to credit
back to your advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets held at
Pershing to eliminate the conflict of interest associated with the receipt of such revenue.
Capital Analysts will review available mutual fund share classes on a quarterly basis to identify those mutual funds
where there has been a prospectus update or a new share class has been made available by the fund in the prior
quarter. If it is determined that a lower cost share class is available and meets our policy criteria as described above,
Capital Analysts will initiate a share class conversion for all mutual fund investments in a higher expense share class
to that lower expense share class (except that money market mutual funds within the Sweep Program are treated
differently, as described below). Share class conversions will appear on your account statements. The ability and
length of time to effect a share class conversion will vary and is subject to prospectus requirements and custodial
platform approval. If you transfer-in shares of a mutual fund into a non-discretionary advisory account that are in a
share class that is less expensive than the share class available to our advisory accounts, Capital Analysts will not
convert your mutual fund position held in a lower expense share class of the same fund to a more expensive share
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class of the same fund. However, Capital Analysts may restrict additional purchases of that share class. Capital
Analysts can also convert the grandfathered share class during a subsequent periodic review.
Until all mutual funds have been converted to the least expensive share class, you should not assume that you are or
will be invested in the least expensive share class available, and the share class of a mutual fund offered by Capital
Analysts can have higher expenses, and therefore lower returns during the conversion transition period.
Additionally, Capital Analysts has selected a higher-cost share class with respect to the Dreyfus Government Cash
Management Fund – Service Shares Sweep Product, which is the designated sweep product for non-ERISA 403(b)7
and 457(b) plans and participant accounts and the designated secondary sweep product for excess balances in the
Dreyfus Insured Deposits L Sweep Product. There are less expensive share classes of the same money market
mutual fund available that would not provide revenue sharing with the firm or would provide lesser amounts of
revenue sharing with the firm.
Information about the mutual funds and share classes that are available through your account, including their
investment policies, restrictions, charges, and expenses, is contained in the mutual funds’ prospectuses. You should
read these prospectuses carefully.
Third-Party Payments and Revenue Sharing from Pershing LLC
Pershing provides credits, payments and benefits, including but not limited to fee and expense reductions, to Capital
Analysts’ affiliate, Lincoln Investment, in its role as introducing broker-dealer for assets held at Pershing LLC
(“Pershing”), that incentivize us to recommend and continue to use Pershing as clearing firm and custodian and
achieve agreed upon asset levels in The Bank of New York Mellon Corporation (“BNY”)’s affiliated products and
services. Pershing and BNY Mellon Advisors, Inc. (“BNYMA”) are affiliates of BNY.
Pershing Revenue Sharing and Expense Credit with Lincoln Investment. For accounts held on Pershing’s
platform, Pershing provides a credit against expenses to Capital Analysts’ affiliate, Lincoln Investment, as
introducing broker-dealer, based on the total asset value of all accounts and the total number of investor accounts
custodied at Pershing, calculated at the time that assets were converted from Lincoln Investment’s Solutions self-
clearing platform to Pershing (“Pre-Conversion Custody Balance”), pursuant to a written agreement with
Pershing. This Pre-Conversion Custody Balance included both brokerage and advisory assets and accounts with
Lincoln Investment and advisory assets and accounts with Lincoln Investment’s affiliate, Capital Analysts. This
revenue does not vary with respect to the investment choices/recommendations made in your Pershing account.
Lincoln Investment does not refund or offset this third-party payment against advisory fees paid by clients whose
advisory assets are on Pershing. Overall, the expense credits received by Lincoln Investment from Pershing for
2024 represented less than one percent of Lincoln Investment’s total advisory revenue, approximately one
percent of Capital Analysts’ revenue and less than one percent of Lincoln Investment’s broker-dealer revenue.
The receipt of these expense credits creates a conflict of interest to Lincoln Investment and its affiliate, Capital
Analysts, to use Pershing as a custodian over other custodians that do not share these fees, do not provide
expense credits to us or that would share lesser amounts with us. We mitigate this conflict by disclosing it to you
and by not sharing it with your Advisor.
Contract Extension Credits and Conversion Support Payments. Pershing provides certain credits and
payments to Capital Analysts’ affiliate, Lincoln Investment, pursuant to a written agreement in consideration of
the extension of Lincoln Investment’s agreement with Pershing and the attainment of certain milestones,
including conversion-related milestones, execution of new contracts and transfer of accounts to Pershing. Capital
Analysts does not refund or offset these credits/payments against fees paid by clients. The receipt of these credits
and payments creates a conflict of interest to Capital Analysts to recommend and/or use Pershing as a custodian
over other custodians that do not share these fees, do not provide expense credits/payments to us or that would
share lesser amounts with us. This revenue is not shared with your Advisor. Additionally, under Lincoln
Investment’s agreement with Pershing, there is a termination fee schedule with amounts that decrease over time.
Therefore, Capital Analysts has an incentive to maintain the relationship with Pershing for a longer period of
time.
Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Capital
Analysts’ affiliate, Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to
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a written agreement with Pershing resulting in a higher margin interest rate to you. This mark-up will not exceed
2.25% above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to
Capital Analysts to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or
limit the amount. Capital Analysts mitigates this conflict by disclosing it to you and by not sharing it with your
Advisor.
Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform,
Capital Analysts’ affiliate, Lincoln Investment, as introducing broker-dealer, marks up the base interest rate
pursuant to a written agreement with Pershing, resulting in a higher non-purpose loan interest rate to you. This
mark-up will not exceed 0.75% above the base interest rate. The receipt of revenue sharing with Pershing creates
a conflict of interest to Capital Analysts to use Pershing as custodian over other custodians that do not permit us
to mark-up the fees or limit the amount. Capital Analysts mitigates this conflict by disclosing it to you and by not
sharing it with your Advisor.
Trading and Account Service Fees. Capital Analysts’ affiliated broker-dealer, Lincoln Investment, establishes
brokerage commission schedules for advisory and brokerage accounts. For Capital Analysts’ advisory accounts
held on Pershing’s platform for which Lincoln Investment is introducing broker-dealer (i) Pershing charges
trading and account service fees for which Lincoln Investment, as introducing broker-dealer, has added a mark-
up that ranges from 0% to 420%; (ii) For certain trading and account services for which Pershing does not assess
a fee to Lincoln investment, Pershing permits Lincoln Investment, as introducing broker-dealer, to impose its
own fee which is charged to you. The receipt of these fees creates a conflict of interest for Lincoln Investment
since it creates an incentive for Lincoln Investment and Capital Analysts to continue to use Pershing as custodian
over other custodians that do not permit us to mark-up the trading and account service fees or would limit the
amount, or that would not permit us to set our own fee. We mitigate these conflicts by disclosing them to you
and by not sharing the mark-ups and Lincoln Investment fees with your Advisor. Your Advisor is permitted to
pay certain fees on your behalf in their sole discretion.
Growth Incentive Credits/Payments. For accounts opened and/or assets moved to Pershing by Capital
Analysts or its affiliate, Lincoln Investment, Pershing provides a credit/payment to Lincoln Investment as
introducing broker-dealer based on the total asset value of such accounts when the accounts are opened on
Pershing, or accounts/assets are moved to Pershing or retained by Pershing, pursuant to a written agreement with
Pershing. The receipt of these credits/payments creates a conflict of interest to Lincoln Investment and its
affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian over other custodians that do not
share these fees, do not provide credits/payments to us or that would share lesser amounts with us. This revenue
is not shared with your Advisor.
Acquisition Financial Support Credits/Payments. For accounts acquired from other firms by Capital Analysts
or its affiliate, Lincoln Investment, Pershing provides credits/payments to Lincoln Investment based on the total
asset value of such accounts when they will be moved to Pershing or retained by Pershing, pursuant to a written
agreement with Pershing. The credit/payment to Lincoln Investment is greater for acquired accounts that will be
moved to Pershing compared to the credit for acquired accounts that will be retained by Pershing (accounts
already existing on Pershing’s platform). The receipt of these credits/payments creates a conflict of interest to
Capital Analysts and its affiliate, Lincoln Investment, to recommend and/or use Pershing as a custodian over
other custodians that do not share these credits/payments, do not provide payments to us or that would share
lesser amounts with us. This revenue is not shared with your Advisor.
The Lincoln Investment Companies Sweep Program. The Lincoln Investment Companies offer a sweep
program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that
are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s)
(“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to
$2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of
interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”)
member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNY”) and
BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in
the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts
at various Program Banks. The Bank Deposit Sweep Products and Money Fund Sweep Products are supported
and operated through a private labelling arrangement with Dreyfus, a division of Mellon Investments
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Corporation (“MIC”) and are available only to clients of broker-dealers who clear through Pershing, such as
Capital Analysts. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or
“Administrator”), BNY Mellon Securities Corporation (“BNYSC”) and Dreyfus to provide certain services with
respect to the operation of the Deposit Accounts. MIC is a registered investment adviser and BNYSC is a broker-
dealer. BNY Mellon Investment Adviser, Inc. (“BNYIA” or “Adviser”) acts as investment adviser for the
Dreyfus Money Fund Sweep Products. Affiliates of BNY include but are not limited to, Pershing, BNYSC, MIC,
BNYIA, BNY and BNY Mellon, N.A. BNY Mellon is the corporate brand for The Bank of New York Mellon
Corporation. For the most up-to-date information, see the applicable product-specific disclosure for a list of
BNY Mellon affiliates and their role in the operation of the Sweep Products.
Depending upon your account type, Capital Analysts will designate a Sweep Product for use in your account.
Capital Analysts offers two Bank Deposit Sweep Products, the Dreyfus Insured Deposits L (“Tiered Rate Sweep
Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund Sweep
Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker symbol
DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker symbol
DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund Investor
Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over $2,490,000 in the
Level Fee Sweep Product, create financial benefits and conflicts for us as described below. Capital Analysts has
designated the Dreyfus Government Cash Management Fund Service Shares for non-ERISA 403(b)7 and 457(b)
plans and participant accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the
Tiered Rate Sweep Product. Capital Analysts has designated the Tiered Rate Sweep Product for use in
commission-based individual retirement accounts (IRAs) and most non-retirement brokerage and advisory
accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs.
Lincoln Investment, Capital Analysts’ affiliated broker-dealer, receives a portion of the fee paid to Pershing by
the Program Banks in connection with the Bank Deposit Sweep Products and receives distribution assistance
payments from Pershing in connection with the Dreyfus Government Cash Management Fund Service Shares
Sweep Product. Accordingly, Capital Analysts has a conflict of interest in that we have a financial incentive to
designate the Tiered Rate Sweep Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash
Management Fund Service Shares Sweep Product as the Sweep Product(s) for your account and, for
discretionary advisory programs managed by Capital Analysts, Capital Analysts can allocate a portion of assets
to the Sweep Product, each of which generates additional revenue to us and our affiliate, Lincoln Investment.
This compensation is a significant source of revenue for Lincoln Investment, Pershing, and provides economic
benefits to Capital Analysts as Lincoln Investment’s affiliate. Pershing, other financial services firms and third
parties could offer the same or similar money market mutual fund sweep products and/or bank deposit sweep
products, at a lower overall cost and higher return to the investor than is available through the Sweep Program,
whether directly through the provider or through a sweep program offered by a different financial services firm.
This receipt of revenue sharing from Pershing creates a conflict of interest to Lincoln Investment and its affiliate,
Capital Analysts, to use Pershing as a custodian over other custodians that do not share these fees, do not share
these payments or that would share lesser amounts or that would not permit us to set our own fee, to offer the
Sweep Products, and to recommend that you utilize and maintain a higher balance in the Sweep Products.
Capital Analysts and Lincoln Investment receive a greater financial benefit when cash is swept into the above
Bank Deposit Sweep Products and Money Fund Sweep Product than it otherwise would if your cash balance is
held elsewhere, and any compensation that our affiliate Lincoln Investment receives reduces the interest and/or
dividend you receive, and your overall investment return. This compensation is retained by Lincoln Investment
and is not shared with you. We and our affiliate Lincoln Investment receive greater compensation as assets
and/or accounts utilizing the Sweep Products increase, as more fully described below. The Sweep Product fees
that Lincoln Investment receives are in addition to any investment advisory fees that you pay to Capital Analysts
and your Advisor. This means that Capital Analysts and its affiliate Lincoln Investment earn two layers of fees
on the same Sweep Product balances in your account, which can result in you experiencing a negative overall
investment return. We also receive different fees based on the Sweep Product designated for your account.
Therefore, we have an incentive for you to use (and invest your assets in) the sweep products that increase our
compensation. If you desire to maintain a cash balance in your account for an extended period of time awaiting
investment and/or seek the highest yields currently available in the market for your cash balance, please contact
your Advisor or Capital Analysts for options outside of the Sweep Products. In order to mitigate these conflicts,
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Capital Analysts does not share this revenue with your Advisor. Your Advisor has the ability to waive the
advisory fee on all Sweep Products, should you request it.
Capital Analysts has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most
non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in
advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln
Investment and its affiliate, Capital Analysts, Pershing, and Pershing’s affiliated Program Banks that participate
in the Sweep Program. For additional information regarding Pershing’s and their affiliates’ conflicts of interest,
please see the link to our Disclosures web page, included below. Lincoln Investment receives a portion of the fee
paid to Pershing by the Program Banks, which it can allocate to its affiliate, Capital Analysts. Lincoln
Investment sets the amount of the fee it receives from Pershing on your Bank Deposit Sweep Product accounts
and/or assets. This is a conflict of interest as it permits Lincoln Investment and its affiliate, Capital Analysts, to
assess a higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no
remuneration or less remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The
portion of the fee received by Lincoln Investment on the Bank Deposit Sweep Products is greater than the yield
that you will receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest
rate paid on your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to our
affiliate, Lincoln Investment, the lower the interest paid to you; the lower the compensation paid to
Lincoln Investment, the higher the interest paid to you. You should understand that this can result in you
experiencing a negative overall investment return with respect to your balance in the Bank Deposit Sweep
Product. Additionally, bank deposit sweep products typically yield lower returns than money market mutual
funds. However, because Lincoln Investment earns a higher fee when you invest in Bank Deposit Sweep
Products than if you invest in other money market products such as money market mutual funds, within or
outside of the Sweep Program, Capital Analysts is incentivized to designate Bank Deposit Sweep Products for
your account(s). Lincoln Investment receives greater compensation related to Bank Deposit Sweep Products as
the amount of assets and/or accounts utilizing the Sweep Products increase and can take up to 6.00% of the
interest rate paid on the balances of your Deposit Accounts. For additional information on Lincoln Investment’s
current fees and compensation earned in relation to the Sweep Program, see the link to our Disclosures web
page, included below. Accordingly, these arrangements present a conflict of interest to Capital Analysts because
they provide an incentive for us to offer the Bank Deposit Sweep Products as our default sweep products, to
maintain balances in the Bank Deposit Sweep Products over other investment options, including money market
mutual funds, and for us and your Advisor to recommend that you enroll in and utilize the Bank Deposit Sweep
Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Capital Analysts has designated a
secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the secondary Money Market
Sweep Product is Dreyfus Government Cash Management Fund Service Shares (Ticker symbol DGUXX). If
your excess balance is swept into Dreyfus Government Cash Management Fund Service Shares, Capital Analysts
will earn fees on that balance, as further discussed below. For the Level Fee Sweep Product, the secondary
Money Market Sweep Product is Dreyfus Government Cash Management Fund Investor Shares (Ticker symbol
DGVXX). For additional information regarding these secondary Sweep Products, please see the link to our
Disclosures web page, included below. Program Banks do not have a duty to offer the highest rates available or
rates that are comparable to money market mutual funds or those offered by other depository institutions or
deposits held at Program Banks outside of the Sweep Program. The receipt of revenue sharing from Pershing and
the ability for Capital Analysts to set its fee for the Sweep Products creates a conflict of interest for Lincoln
Investment and its affiliate, Capital Analysts, to use Pershing as a custodian and to offer the Bank Deposit Sweep
Products we make available to you over other custodians or sweep products that do not pay a portion of their
fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set the fee
it will assess for the Sweep Products.
Capital Analysts has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund
Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess
of $2,490,000 in the Level Fee Sweep Product.
A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes
this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund
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Service Shares Sweep Product, Capital Analysts utilizes a share class that provides remuneration to us
(distribution assistance) which reduces the dividend you receive, even though other share classes are available to
Capital Analysts that would pay Capital Analysts’ affiliate, Lincoln Investment less and you more. Capital
Analysts’ affiliate, Lincoln Investment receives distribution assistance from Pershing in the form of annual
compensation of up to 0.55% for assets in the Dreyfus Government Cash Management Fund Service Shares
Sweep Product. This is not the least expensive share class of the Dreyfus Government Cash Management Fund
available or the least expensive share class available through Pershing. Capital Analysts utilizes a higher expense
share class over other less expensive share classes that would otherwise be available and of lower cost to you.
There are less expensive share classes of the same money market mutual fund available that would not provide
revenue sharing with Lincoln Investment or would provide lesser amounts of revenue sharing. Share classes with
higher expenses can lower your returns over time. This receipt of revenue sharing from Pershing creates a
conflict of interest to Capital Analysts to use Pershing as a custodian and share classes offered by Pershing that
provide remuneration over other custodians and share classes that do not share these fees or payments, or that
would share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a
greater balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less
remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to
Dreyfus Government Cash Management Fund Services Shares is BNYIA. BNYIA has engaged its affiliate,
Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus
Government Cash Management Fund Services Shares. Capital Analysts has an incentive to offer/recommend
Dreyfus Government Cash Management Fund Services Shares due to the agreement between Lincoln Investment
and Pershing which incentivizes us to offer Pershing or its affiliates’ products so that we and our affiliate can
share in a portion of the revenue.
The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution
assistance is received by Capital Analysts or its affiliate, Lincoln Investment, is available only to ERISA
accounts and as the secondary Sweep Product for balances in excess of $2,490,000 in the Level Fee Sweep
Product.
As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made
available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with
Pershing, this creates a conflict of interest for Capital Analysts because it provides an incentive for us to offer a
Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional compensation
and shares it with us and our affiliate.
For additional information and clarity regarding all Sweep Products offered including the designated Sweep
Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank
lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public
website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The
Lincoln Investment Companies Sweep Program General Terms and Conditions for instructions on how to access
the applicable money market mutual fund prospectus.
In aggregate, the above-described third-party payments and revenue sharing from Pershing to Capital Analysts’
affiliate, Lincoln Investment, attributable to Capital Analysts advisory accounts in 2024 represented approximately
eight percent of Capital Analysts’ total advisory revenue in 2024. The receipt of these third-party payments and
expense credits create a conflict of interest to Capital Analysts to use Pershing as a custodian over other custodians
that do not share these fees, do not provide expense credits or that would share lesser amounts. Capital Analysts
mitigates these conflicts by disclosing them to you and not sharing them with your Advisor.
Other Conflicts and Potential Conflicts Related to Our Relationship to Pershing and its Affiliates
Trade Administration Fee Reduction. Lincoln Investment pays Pershing a fee based upon the amount of assets
in advisory programs for which Pershing provides trade administration services for Lincoln Investment and
Capital Analysts advisory accounts (“Trade Administration Fee”). Pursuant to written agreements with Pershing
and BNYMA, Lincoln Investment is eligible for an approximate 34% reduction in the Trade Administration Fee,
contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated
products by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from this
expense reduction. Lincoln Investment’s eligibility for this expense reduction creates a conflict of interest to
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Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian and/or
trade administrator and certain BNY affiliated products or services over other custodians, trade administrators or
products/services that do not provide for expense reductions or that would provide for lesser reductions to us.
Additionally, under our agreements with Pershing and BNYMA, Lincoln Investment and/or Capital Analysts
must continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated products or
services in order to continue to receive the reduction in Trade Administration Fee. Therefore, Lincoln Investment
and its affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon asset levels
invested in certain BNY affiliated products or services.
BNYMA Overlay Fee Reduction. Lincoln Investment pays BNYMA a fee based upon the amount of assets in
Lincoln Investment and Capital Analysts advisory accounts where BNYMA acts as Overlay Manager (“Overlay
Fee”). Pursuant to written agreements with Pershing and BNYMA, Lincoln Investment is eligible for up to a
40% reduction in the Overlay Fee, contingent upon attainment and maintenance of agreed upon asset levels
invested in certain BNY affiliated products by Lincoln Investment and its affiliate, Capital Analysts. Clients do
not directly benefit from this expense reduction. Lincoln Investment’s eligibility for these expense reductions
creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use
Pershing as a custodian, BNYMA as Overlay Manager and certain BNY affiliated products or services over
other custodians, overlay managers or products/services that do not provide for expense reductions or that would
provide for lesser reductions to us. Additionally, under our agreements with Pershing and BNYMA, Lincoln
Investment and/or Capital Analysts must continue to meet or surpass the agreed upon asset levels invested in
certain BNY affiliated products in order to continue to receive this expense reduction. Therefore, Lincoln
Investment and its affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon
asset levels invested in certain BNY affiliated products or services.
Mutual Fund Surcharge Fee Waiver. Lincoln Investment has agreed to pay Pershing a surcharge fee for
transactions in certain mutual fund share classes in Lincoln Investment and Capital Analysts advisory programs.
Pursuant to written agreements with Pershing and BNYMA, Lincoln Investment is eligible for a waiver of
surcharge fees for transactions in certain advisory programs traded by Pershing/BNYMA, continual application
of which is contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY
affiliated products or services by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly
benefit from this expense reduction. Lincoln Investment’s eligibility for this waiver creates a conflict of interest
to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian,
BNYMA as Overlay Manager and/or Pershing as trade administrator, and certain BNY affiliated products or
services over other custodians, overlay managers/trade administrators or products/services that do not provide
for mutual fund surcharge fee waivers or that would provide for lesser waivers. Additionally, under our
agreements with Pershing and BNYMA, Lincoln Investment and/or Capital Analysts must continue to meet or
surpass the agreed upon asset levels invested in certain BNY affiliated products in order to continue to receive
these surcharge fee waivers. Therefore, Lincoln Investment and its affiliate, Capital Analysts, have an incentive
to continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated products or
services.
Pursuant to a written agreement, Lincoln Investment is obligated to provide certain providers/custodians, such as
Pershing and its affiliates, including BNYMA, the opportunity to participate in Lincoln Investment’s conferences or
events, without the separate payment of sponsor or registration fees. The ability to participate in such events
provides Pershing, BNYMA and its affiliates the opportunity to promote their affiliated products and services to
Capital Analysts, its affiliate Lincoln Investment and our Advisors. Increased use of BNY affiliated products by
Advisors of the firm will benefit the firm by assisting us with meeting the asset level required for us to receive a
reduction/waiver in certain Pershing/BNYMA expenses. We recognize this as a conflict for Capital Analysts and its
affiliate, Lincoln Investment, and mitigate this conflict by disclosing it to you.
Sales & Marketing Support Revenue
Lincoln Investment, as the broker-dealer affiliate of Capital Analysts, receives Sales and Marketing Support as
described below and includes Flat Fee Sponsors, Other Sales Support and Asset and Sales Based Sponsors
(collectively, “Sales and Marketing Support”). In order to minimize Capital Analysts’ conflicts of interest associated
with the receipt of these fees by its affiliate, Lincoln Investment does not receive Flat Fee Sponsor and Other Sales
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Support payments that are based on the amount of advisory account assets or advisory account transactions with a
particular sponsor, or that are based on ERISA advisory account assets. However, Flat Fee and Other Sales Support
Sponsors can compensate Lincoln Investment from assets of the mutual fund, the fund’s investment adviser,
distributor or other fund affiliates’ assets. While payments out of the fund's investment adviser, distributor or other
fund affiliate's revenues or profits are not directly paid from the fund's assets, fund affiliate revenues or profits can,
in part, be derived from fees earned for services provided to and paid for by the fund. Payments out of fund assets
can lower investor returns and performance over time. Lincoln Investment can also receive Shareholder Services
Fees from the same fund families and investment advisers that provide Sales and Marketing Support, and
Shareholder Services Fees are in addition to the payment of Sales and Marketing Support fees. These sources of
payments are a conflict of interest to Capital Analysts to recommend and promote those funds, fund families,
investment advisers, distributors or other fund affiliates over others that do not provide Sales and Marketing Support
or that provide lower amounts of Sales and Marketing Support.
Flat Fee Sponsors. Lincoln Investment, Capital Analysts’ affiliated broker-dealer, has partnered with a select
group of third-party money managers and product sponsors who pay to assist Lincoln Investment in the training
and education of and outreach to Advisors at firm sponsored events, on such topics as advisory products and
services, practice management, tools and technology, consumer education, and policies, rules and regulations.
Additional opportunities can include but are not limited to attendance at and support of recognition club events,
exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial
support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based
on the sales of their proprietary products or services. Sponsors can compensate Lincoln Investment from fund
assets, the fund’s investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can
lower investor returns and performance over time. Advisors do not share in any portion of these payments so as
to mitigate any conflict for an Advisor to recommend one product or money manager over another. This
financial support allows Lincoln Investment to defray or offset costs associated with firm sponsored events and
other educational and outreach tools and services. The financial support by these Sponsors to Lincoln
Investment associated with Capital Analysts presents a conflict of interest to Lincoln Investment and Capital
Analysts.
All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the
payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example,
Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to
educate Advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to
attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not
Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these
sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to
mitigate any such conflict.
In 2024, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all
investment advisory assets with Lincoln Investment Planning, LLC and Capital Analysts, LLC did not exceed
1.5% of total revenue for either of the affiliated registered investment advisers and in aggregate was less than
one percent of the combined revenue for both affiliated registered investment advisers. We do not believe that
these revenues are material. In 2024, Flat Fee Sponsors who compensated Lincoln Investment with a flat fee
payment, and offer a fund or advisory program that could be used in your Capital Analysts advisory account, in
order from highest to lowest payment were Russell Investments, Clark Capital Management, AAMA, PIMCO
Funds, American Funds, Federated Investors, Meeder Funds and Franklin Templeton Group.
Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational
expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support.
Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in
their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops,
mailings, administrative expenses and technology support. The amount received from any one product sponsor
or third-party money manager in 2024 did not exceed $30,000. The sales support presents a conflict of interest in
that it could incentivize an Advisor to offer one product or money manager over another that does not provide
these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and
subsidies, the amount is approved by The Lincoln Investment Companies and is monitored to ensure that it is not
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too frequent or excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and
educational meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of
interest that could incentivize an Advisor to offer one product or money manager over another that does not offer
these meetings or seminars. We must grant permission to its Advisors to attend any meeting or seminar hosted
by a product or advisory service sponsor. The Lincoln Investment Companies approve events that are limited to
education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and
reimbursement to the Advisor, through us, for travel expenses only. The education of our Advisors in the
offerings that are available to them is a key component of providing prudent investment advice to you.
Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory
assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or
transactions in which you may invest
Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our
investors, and in addition to the compensation described above, Lincoln Investment, the broker-dealer affiliate of
Capital Analysts, receives Sales and Marketing support from product sponsors, mutual fund companies,
insurance companies and other third-party providers to assist in the marketing and sales efforts of employees and
Advisors (“Asset and Sales Based Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate
and train employees and Advisors with respect to investment products and services, practice management, tools
and technology, consumer education, and policies, rules and regulations. Additional opportunities can include
but are not limited to attendance at and support of recognition club events, exhibit booths, advisor presentations,
seminars, mailings and publications. The support provided by these sponsors is based on brokerage-only (non-
investment advisory) assets and brokerage transactions and not based on your advisory account assets or ERISA
advisory assets. Lincoln Investment receives compensation from these sponsors in various forms, including as a
flat fee, a percentage of the amount of brokerage assets held by investors, a percentage of sales, or any
combination of these methods. The amounts of these payments can vary by the type of product and by provider
and can include, but are not limited to, distribution fees and shareholder service fees. All Asset and Sales Based
Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the payment, the
access to Lincoln Investment sponsored events and other opportunities can differ. The higher the payment, the
greater the access for the Asset and Sales Based Sponsor to attend events, participate in marketing and sales
opportunities and interact with Advisors. This presents a conflict of interest to Advisors to offer these sponsors’
products or services over others. Advisors do not share in any portion of these payments so as to mitigate any
such conflict. Additionally, some Asset and Sales Based Sponsors make a monthly or quarterly payment or
additional monthly or quarterly payment based on the assets you hold in a fund or variable insurance product
over a period of time. As you may have both a brokerage account and an advisory account with us, we want you
to understand that Lincoln Investment will receive Sales and Marketing Support based on assets or sales in
connection with your brokerage account assets and transactions. The Asset and Sales Based Sponsors payments
present a conflict of interest to Lincoln Investment to recommend Asset and Sales Based Sponsors that provide
sales and marketing support over others that do not or that provide lesser amounts. Some of the Asset and Sales
Based Sponsor revenue is used by Lincoln Investment to support the ongoing operational expenses of Lincoln
Investment, and its affiliates, and not used solely for sales and marketing support.
The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to
Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2024: Security Benefit
Life, Franklin Templeton Group, Athene, Jackson National Life Ins Co, Invesco Investment Services, Allianz,
AXA Equitable Life Insurance Company, Lincoln National Life, Nationwide, Brighthouse Financial, Prudential,
Mewbourne Development Corporation, Blue Rock Capital, Transamerica Life, Simplicity, Federated Investors,
Hines Securities, Pershing, Black Creek Capital Markets, Voya Mutual Funds, and Meeder Funds. The Asset and
Sales based Compensation in 2024 was less than $2.5 million dollars from these product sponsors and
represented less than one percent of the total revenues of Lincoln Investment. We are disclosing this information
to you as certain providers and products offered by the providers shown above could be available within the
investment advisory offerings of Lincoln Investment’s affiliate, Capital Analysts.
Outside of the Sweep Program, Pershing, as clearing firm for accounts introduced by Lincoln Investment, shares
with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund
companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not
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material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual
fund product that generated the compensation to the firm.
Other Conflicts and Potential Conflicts
Other financial services firms and third parties could offer advisory services, securities products, or insurance at a
lower overall cost to you than what is available through your Capital Analysts account, or you could invest directly
with a provider.
Ongoing Fiduciary Conflicts. Capital Analysts has a supervisory duty to periodically monitor clients’ portfolios
to ensure suitability of investments and to ensure that the advisory services are being performed in recognition of
our fiduciary duty to you, which includes acting in your best interest. A conflict of interest exists if an Advisor is
assessing an advisory fee but no services are being performed. Supervision is performed over accounts and
Advisors to monitor for activities that could be deemed a breach of our fiduciary duty to you, including such
periodic reviews as accounts where there is no documentation of services being performed and accounts with
uninvested cash balances over a 12-month period of time with no rationale for holding such a large cash position
in an advisory account. In an advisory relationship, our fiduciary relationship will be most successful if both the
client and the Advisor partner to ensure that there is regular and meaningful contact and that the advisory
account continues to meet the needs of the client.
Affiliates Other Businesses. Capital Analysts principal business is as an investment adviser. The majority of
Capital Analysts revenue comes from the advisory fees we collect from you. Through its affiliated broker-dealer,
Lincoln Investment also receives compensation from its brokerage business. This compensation comes from
securities and insurance product commissions and mutual fund concessions, 12b-1 distribution fees associated
with the sale of mutual funds, shareholder service fees, trailing commissions from annuity sales, and persistency
bonuses on insurance and other sources. Lincoln Investment is also an SEC registered investment adviser and
Capital Analysts promotes the services of this investment adviser. You always have the option to purchase
advisory services, securities products or insurance through non-affiliated investment advisers, brokers or agents.
Your Advisor’s Other Businesses. Your Advisor may have more than one relationship with you – one as an
Advisor over an advisory account and one as a registered representative/agent of Lincoln Investment over a non-
advisory account where he or she may receive a sales commission for the sale of securities or insurance products
which would be in addition to any advisory fees earned on your advisory assets. In these situations, our Advisor
may have greater financial incentives to offer you both investment and/or insurance sales as well as advisory
services.
Your Advisor may also be associated with Capital Analysts’ affiliated investment adviser, Lincoln Investment.
This affiliated relationship presents a conflict of interest. Through his or her affiliation with Capital Analysts and
possibly with Lincoln Investment, your Advisor may be in a position where he or she can offer the same or
similar advisory services to you for different fees and compensation structures. If an identical Sub-Adviser or
strategy is available through two affiliated registered investment advisers, you may pay higher fees for an
advisory service that is similarly offered through another affiliated investment adviser. You always have the
option to purchase advisory services, securities products or insurance through non-affiliated investment advisers,
brokers or agents.
Capital Analysts pays out to each Advisor a specified percentage of the Advisor’s fee. This percentage varies by
Advisor based on such factors as Advisor experience, type of contract the Advisor has with the firm, amount of
investor assets with the firm, type of advisory service, categories of products and the amount of investor assets
managed by the IM&R Team. These varying payout rates can create a conflict of interest for your Advisor to
recommend certain services and categories of products, including advisory services managed by the IM&R
Team and your Advisor, over others with a lower payout rate. Capital Analysts can pay compensation, including
bonus payments, to Advisors who agree to engage in mentorship of another financial professional. Most of
Capital Analysts’ Advisors are independent contractors who may also offer other non-security financial services
and products, such as life, health, disability, long-term care and fixed annuity insurance products, and real estate.
These services may be offered independent of The Lincoln Investment Companies.
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Sales Contests. Lincoln Investment offers sales contests based on such criteria as gross compensation to the
Advisor, new accounts, new investors, initiation of periodic contributions, total fee-based assets and net sales of
fee-based programs, inclusive of Capital Analysts. These contests can provide your Advisor with a conflict of
interest and an incentive to offer you fee-based advisory services over commission-based brokerage services,
offer you advisory services managed by the IM&R Team and your Advisor over third-party advisory services
and to conduct additional business in order to be eligible. Top achievers in these contests are eligible to receive
Lincoln Investment-sponsored trips, awards, cash prizes, bonus commissions, bonus payments, club points,
monetary donations in their name to a charity of their choice or other nominal prizes subject to applicable law.
To mitigate the conflicts of interest presented by these incentives, no contest is offered which will award the
Advisor based upon a specific investment product or on a specific third-party product sponsor. Brokerage
commissions and brokerage assets associated with Massachusetts residents are excluded from Lincoln
Investment’s sales contests consistent with applicable state law. For Massachusetts’ residents, this creates a
financial incentive for your Advisor to recommend advisory services over brokerage services. We mitigate these
conflicts by disclosing them to you and supervising the investment advisory activities and brokerage practices of
its Advisors. In our capacity as an investment adviser, Capital Analysts and its Advisors recognize they have a
fiduciary duty to investment advisory clients. Although Lincoln Investment does not offer specific product sales
incentives for securities products, issuers of non-securities insurance products, such as fixed annuity issuers, may
offer sales incentives to Advisors in the form of cash bonuses and trips if certain sales thresholds are met. You
should ask your Advisor about these incentives at the time of sale.
Payments to Employers and Organizations Associated with an Employer who Sponsor Non-ERISA Plans.
Lincoln Investment, Capital Analysts’ affiliate, has contracts with employers to enable employees who work for
these employers to open and invest in a primary or supplemental retirement account through payroll deduction
contributions through an account with us. The majority of employers with whom Lincoln Investment has
contracts offer non-ERISA 403(b) and 457(b) retirement plans to their employees. Also, many of these
employers are school districts and the employees are teachers or other eligible employees. Lincoln Investment
and our Advisors make contributions from time-to-time to organizations that are associated with an employer,
such as administrators and teachers’ associations, consultants, non-profits, and scholarship or grant funds.
Lincoln Investment and our Advisors can also sponsor a business or social event, conference, meeting,
fundraiser or scholarship by making a monetary contribution or by providing nominal supplies to assist the
employer and/or their employees.
Third Party Administrator (TPA) Payments. TPAs that provide administrative services to the employer charge
the employer an annual per participant retirement plan administration fee for their services. Certain TPAs and/or
employers list Lincoln Investment as an investment provider (along with other providers) and we have agreed to
pay the per-participant TPA fee for a participant who opens or holds an account with us. This reduces the cost to
the employer sponsor of the retirement plan and/or the participant.
Exclusive Provider. Less than one percent of our employer contracts are an exclusive arrangement where
Lincoln Investment is the only provider who has been authorized to work with the employees to establish a
primary/supplemental retirement plan account. You can ask your Advisor whether Lincoln Investment has an
exclusive arrangement with your employer.
Other Non-Exclusive Provider Payments. In order to be a 403(b) provider/vendor in California,
providers/vendors must register with 403bCompare, a program of the California State Teachers’ Retirement
System (“CalSTRS”). Lincoln Investment is registered with 403bCompare and pays an annual 403(b)
provider/vendor fee as determined and assessed by CalSTRS. The total fee assessed to all providers/vendors
covers the cost to administer and maintain the 403bCompare.com website.
The payments and benefits described in this section create a conflict of interest to the employer and employees
since they could serve as an incentive to select the products and services of Lincoln Investment and its affiliates
over other providers that do not make these payments or pay lesser amounts. We mitigate these conflicts by
disclosing them to you and avoiding payments that we consider too frequent or excessive.
Other Asset Level Payments (Available to Certain Advisors). Certain Advisors are eligible to receive,
directly or indirectly, additional compensation from Capital Analysts when specified thresholds of total assets
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are met by that Advisor and other Advisors with whom they are associated (“Other Asset Payment” or “OAP”).
OAP creates a conflict of interest for the Advisor to recommend certain offerings, including advisory services
managed by the IM&R Team and the Advisor, over others for which they would not receive additional
compensation in the form of OAP. These payments to your Advisor directly or indirectly would result in your
Advisor receiving greater compensation than what is indicated as the Financial Advisor Fee in your investment
advisory agreement. The payment of OAP to an Advisor, including your Advisor, has no impact on the total
client fee paid by you for the selected offering. These payments also create a conflict of interest for Capital
Analysts to compensate Advisors in order to maintain or increase assets managed by the IM&R Team and the
Advisor, over other advisory services or platforms where Capital Analysts receives less revenue. Capital
Analysts mitigates these conflicts by disclosing them to you and supervising the investment advisory activities
and brokerage practices of its Advisors.
Loans, Advances and Other Benefits. On occasion, Capital Analysts’ affiliate, Lincoln Investment extends a
loan, provides a bonus, provides a commission/fee advance, and pays for practice management services for an
Advisor to assist the Advisor in transitioning to the firm, and/or running his or her business. Sometimes these
loans or advances are forgiven (waived) or reduced, in whole or in part, interest rates reduced, and/or a bonus
provided if an Advisor remains affiliated with the firms or achieves certain sales or assets under management
thresholds, revenue targets, production levels, asset additions, new client goals, client retention goals, recruiting
goals and certain practice management goals or conditions set forth by the firms, individually or with other
Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firms during the repayment period in order to receive these benefits over
other firms that do not offer these incentives or offer a similar level of incentives. These practices also present a
conflict in that the Advisor has a financial incentive to generate more business or to recruit other financial
professionals to generate more business, and achieve certain sales, revenue or asset management thresholds in
order to satisfy or reduce the amount of the loans or advances. In situations where a sales, production, recruiting,
revenue, assets under management threshold or other financial contingency exists, this conflict of interest will be
disclosed in your Advisor’s Form ADV 2B Supplement (BIO Brochure), which is required to be delivered by the
Advisor to every client. Capital Analysts mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required
which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to
the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm
and/or for running their business, which can include but is not limited to, technology services, administrative
support, licensing, insurance and administrative fees, the opportunity to participate in a unit appreciation rights
plan of an affiliate or parent of Lincoln Investment, and reimbursement of fees associated with transitioning
accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firms over other firms that do not offer these incentives or offer a similar level
of incentives. Capital Analysts mitigates these conflicts by disclosing them to you and supervising the investment
advisory activities and brokerage practices of its Advisors.
Advisor Referral Program. Lincoln Investment compensates Advisors and employees who have referred
another financial professional to the firm if that referred financial professional then decides to affiliate with
Lincoln Investment and/or its affiliate, Capital Analysts. This creates an incentive for Advisors and employees to
affiliate with our firm over others that do not offer similar compensation, and to refer financial professionals in
order to receive this compensation. We do not believe that this practice presents a material conflict of interest.
Gifts and Entertainment. Offering or receiving a gift or entertainment from a product or advisory service
sponsor could create a conflict of interest. Lincoln Investment has instituted a policy that prohibits excessive
and/or too frequent gifts or entertainment activities to mitigate this conflict.
Political Contributions. Providing significant political contributions to a state or local official or candidate
could create the perception that Capital Analysts or its Advisors are seeking quid pro quo arrangements with that
state or local government or its employees to open an account with our firm. Lincoln prohibits contributions in
excess of $350 per election if the Advisor can vote for the candidate and $150 per election if the Advisor cannot
vote for the candidate.
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Charitable Donations. Providing significant charitable donations to a charity organization could create the
perception that Capital Analysts or its Advisors are seeking quid pro quo arrangements with that charity or its
employees to open an account with our firm. Lincoln allows contributions to charities, but prohibits any
donations that are deemed excessive or too frequent.
Accounts Maintained on Institutional Platforms
The following applies to clients whose accounts are held at Schwab or other institutional platforms
(“Institutional Platforms”).
Capital Analysts can recommend that clients establish brokerage accounts with one or more Institutional
Platforms to maintain custody of clients’ assets and to effect trades for their accounts. The final decision to
custody assets with an Institutional Platform is at the discretion of the Advisor’s clients, including those accounts
under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA
accountholder.
Products & Services Available to Us from Institutional Platforms
Institutional Platforms serve independent investment advisory firms like ours. They provide Capital Analysts and
our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of
which are not typically available to the Institutional Platform’s retail customers. Institutional Platforms also
make available various support services. Some of those services help us manage or administer our clients’
accounts while others help us manage and grow our business. Institutional Platform support services are
generally available on an unsolicited basis and at no charge to us. Some institutions such as Charles Schwab and
Co., Inc. require we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab to avail
ourselves of those services at no charge. These Institutional Platform providers generally do not charge
separately for custody services but are compensated by account holders through commissions or other
transaction-related or asset-based fees for securities trades that are executed through them or that settle into their
accounts.
Services that Benefit Clients
Institutional brokerage services include access to a broad range of investment products, execution of securities
transactions, and custody of client assets. The investment products available through Institutional Platforms
include some to which we might not otherwise have access or that would require a significantly higher minimum
initial investment by our clients. These services generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Institutional Platforms also make available to us other products and services that benefit us but may not directly
benefit the client or their account(s). These products and services assist us in managing and administering our
clients’ accounts. They can include both their own investment research and that of third parties. We can use this
research to service all or some substantial number of our clients’ accounts, including accounts not maintained at
the Institutional Platform providing the services. In addition to investment research, Institutional Platforms make
available software and other technology that:
•
•
•
•
•
provides access to client account data (such as duplicate trade confirmations and account statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Institutional Platforms also offer other services intended to help us manage and further develop our business
enterprise. These services can include:
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•
•
•
•
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Institutional Platforms may provide some of these services. In other cases, they will arrange for third-party
vendors to provide the services. They can also discount or waive their fees for some of these services or pay all
or a part of a third party’s fees. While, as a fiduciary, Capital Analysts endeavors to act in its clients’ best
interests, Capital Analysts’ recommendation that clients maintain their assets in accounts at the Institutional
Platform can be based in part on the benefit to Capital Analysts or its Advisors of the availability of some of the
foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody
and brokerage services provided by these Institutional Platforms, which creates a conflict of interest.
Item 5: Account Requirements and Types of Clients
Types of Clients
Capital Analysts primarily serves individuals, high net worth individuals, trusts, institutions, foundations,
businesses, and charitable organizations as well as the retirement assets of individuals and businesses, individual
retirement accounts (“IRAs”) and employer sponsored ERISA plans. We also offer our institutional investment
advisory services to third-party investment advisers and trust companies. Clients may open qualified and non-
qualified accounts with Capital Analysts. Not all investors and plans, including retirement plans, are eligible to
invest in one or more of Capital Analysts advisory programs. Please consult with your Advisor or your employer to
determine if your assets are eligible to invest.
Account Requirements
Capital Analysts imposes a minimum dollar value of assets for its Capital Analysts Managed Program accounts as
described below. These minimum account requirements may be waived at our sole discretion. Other Wrap Fee
Programs, such as CAAMS Select and Advisor Managed Model or Client Custom Portfolios available on Pershing
have minimums that vary by third-party money manager and Advisor, respectively.
Capital Analysts Managed Program Name
Minimum
Investment
CAAMS Complete (including Alternatives and Yield)
CAAMS Custom Income Strategies
CAAMS AssetBuilder
CAAMS ETF
CAAMS Stock
CAAMS UMA
CAAMS Strategist
$50,000
$250,000
$15,000
$50,000
$50,000
$50,000
$50,000
Item 6: Portfolio Manager Selection and Evaluation
All Capital Analysts Managed Programs are managed with discretion by the IM&R Team. See the Methods of
Analysis, Investment Strategies and Risk of Loss section below for more information about how the team manages
the Capital Analysts Managed Wrap Fee Programs, including the selection of portfolio managers for the Strategists
programs.
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Other Advisory Business
Capital Analysts offers the following additional investment advisory services for a fee. A description of each service
is provided in Capital Analysts’ Form ADV 2A Brochure, a copy of which accompanies this Brochure.
1.
2.
3.
4.
Capital Analysts Managed Programs (Non-Wrap Programs)
Advisor Managed Model and Client Custom Portfolios (Non-Wrap Programs)
Third-Party Managed Model and Custom Portfolios (Non-Wrap Programs)
ERISA Retirement Plan Advice
Performance-Based Fees and Side-by-Side Management
Capital Analysts and our Advisors do not receive performance-based fees. A performance-based fee is an advisory
fee that compensates the Advisor for the Advisor's success in managing a client's money or "a fee based on the share
of the capital gains and appreciation of a client's funds." A performance-based fee may induce an advisor to take
greater and undue risks with client's funds in an attempt to generate higher compensation to the advisor.
Your Advisory Fees with Capital Analysts are typically assessed as a percentage of the total value of your advisory
account assets as of each month-end and are not performance-based fees.
Method of Analysis, Investment Strategies and Risk of Loss
The IM&R Team meets regularly to review current holdings and market conditions, make changes as appropriate,
and ensure that the investment philosophy is consistently applied to each model portfolio. The management of all
Capital Analysts Managed Programs includes investment selection and monitoring, portfolio construction, and
portfolio rebalancing and realignment in accordance with the investment objectives of the managed model portfolio.
Investment strategies include both long-term solutions and short-term strategies, where appropriate, that coordinate
with either the client’s stated objectives (when managing a custom portfolio) or the objectives of the model portfolio
(when managing the model to a stated objective). Our goal is to manage the portfolio with the appropriate asset mix
to optimize portfolio return within the given level of risk tolerance. Option writing may be used from time to time.
The investment management strategies of the Capital Analysts Managed Programs differ by Program and by model
or custom portfolio, and can be strategic or involve tactical overlays. Investing in securities involves risk of loss that
you, the investor, should be prepared to bear.
The primary objective of most advisory services and advice offered by Capital Analysts and its Advisors is to
provide to you a risk-appropriate diversified portfolio. A risk-appropriate diversified portfolio applies the disciplines
and theories of asset allocation. Asset allocation means, first and foremost, working to design a portfolio that
sufficiently allocates your assets across different asset classes to help reduce the exposure to any single asset class
and market loss you could incur in your account(s) if you didn’t diversify. It is important to understand that asset
allocation, although a proven method to reduce risk to a portfolio, does not guarantee a profit or protect against loss.
Asset classes include, but are not limited to, domestic and international equities, domestic and international bonds,
cash and cash equivalents, as well as alternative investment types such as real estate and commodities. Equities can
be further broken down by market capitalization (company size based on annual revenues) ranging from large
companies (large-cap) to medium and small companies (medium- and small-cap). Bonds, meanwhile, can be further
broken down by issuer type – such as corporate, municipal, and government – and by duration, ranging from short
term to long.
The IM&R Team, once it establishes an asset allocation model portfolio, may periodically re-balance the account
back to any stated asset allocation.
Capital Analysts utilizes a proprietary screening and rating methodology for mutual funds in Capital Analysts
Managed Programs called Capital Analysts Performance Statistics Leaders (“CAPSL”). Capital Analysts also offers
Advisors the results of CAPSL for consideration with Advisor Managed Model and/or Client Custom Portfolios.
The objective of CAPSL is to identify mutual funds that consistently outperform their peers and the market for
consideration of inclusion in diversified investment portfolios. While the CAPSL list represents funds that have
exhibited strong characteristics over full market cycles, it is by no means a buy list. CAPSL is a comprehensive
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mutual fund research tool proprietary to Capital Analysts. On a quarterly basis, the IM&R Team screens U.S. open-
ended funds for inclusion on the CAPSL list. Morningstar Direct is used to quantitatively screen over 25,000 funds.
Initial screens typically include funds with a five-year track record and those that have at least $100 million in
AUM. Qualifying mutual funds are sorted by Morningstar category and undergo a multi-factor quantitative analysis.
Finalists are further subjected to style analysis and a qualitative analysis. The final CAPSL list of 125 funds
represents less than 1% of the mutual fund universe. This CAPSL list is made available to Advisors quarterly.
However, the mutual fund recommendations of Advisors are not limited to those on the CAPSL list.
For Capital Analysts Managed Programs which invest in stocks, the IM&R Team utilizes a proprietary research and
selection methodology which applies various fundamental and technical screens to the investable universe of stocks
and compares the results with current research recommendations of major independent services including Value
Line, CFRA Research, and Argus Research. Additional investment research may also be factored into the stock
selection process.
In overseeing the CAAMS Select program, the IM&R Team utilizes a database that evaluates independent third-
party portfolio managers and strategies. Comparisons to both peers and appropriate benchmarks are evaluated. Each
third-party portfolio manager in the CAAMS Select program develops their own proprietary research methodology,
investment analysis and risk strategies. Third-party portfolio managers are solely responsible for their investment
advice and services.
The asset classes used by the IM&R Team in implementing the methods of analysis and investment strategies
described above carry material risks.
• Cash & Cash Equivalents: Capital Analysts may invest a portion of your assets in cash or cash equivalents to
achieve a model portfolio’s objective, provide ongoing distributions and/or take a defensive position. Cash
holdings may result in a loss of market exposure. For discretionary advisory programs managed by Capital
Analysts, Capital Analysts allocates a portion of account assets to the Sweep Product or free credit balance. See
Other Compensation to Lincoln Investment, Capital Analysts and Our Conflicts of Interest for additional
information and conflicts applicable to The Lincoln Investment Companies Sweep Program.
• Environmental, Social and Governance (ESG) Funds: Environmental, Social and Governance (“ESG”)
investing can be referred to in many different ways, such as sustainable investing, socially responsible
investing, and impact investing. ESG fund practices can include, but are not limited to, strategies that select
companies based on their stated commitment to one or more ESG factors (e.g., environmental, social and
governance) - for example, companies with policies aimed at minimizing their negative impact on the
environment or companies that focus on governance principles and transparency. Funds that elect to focus on
companies’ ESG practices may have broad discretion in how they apply ESG factors to their investment or
governance processes. An ESG fund portfolio might include securities selected in each of the three categories,
or in just one or two of the categories. A fund’s portfolio might also include securities that don’t fit any of the
ESG categories, particularly if it is a fund that considers other investment methodologies consistent with the
fund’s investment objectives.
In selecting mutual funds for the CAAMS ESG ETF model portfolios, Capital Analysts can consider data from
third-party providers. This data could include “scoring” and “rating” data compiled to help managers, such as
Capital Analysts, compare funds. Some of the data used to compile third-party ESG scores and ratings may be
subjective. Other data may be objective in principle, but are not verified or reliable. Capital Analysts’ Portfolio
Manager will make the ultimate decision as to whether or not a fund is ESG for purposes of the CAAMS ESG
ETF model portfolios and whether or not a fund should be included in the CAAMS ESG ETF model portfolios.
CAAMS ESG ETF model portfolios can include funds that take a diversified ESG approach (e.g., funds that fit
two or three ESG categories) or funds that target a specific ESG category (e.g., funds that fit just one ESG
category). CAAMS ESG ETF’s model portfolios can also include funds that do not have any ESG mandate.
Capital Analysts’ ESG practices may significantly influence performance. Because funds may be included or
excluded based on ESG factors rather than other investment methodologies, CAAMS ESG ETF model portfolio
performance may differ (either higher or lower) from the overall market or comparable model portfolios that do
not employ similar ESG practices.
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•
Equities: The price of equities fluctuate due to many factors including changes in interest rates, global events,
industry and company specific events, investor expectations, and general market conditions. You can receive
more or less than the original purchase price when selling a security. Concentrated positions in equities
typically pose additional risks as a downturn in your investment will cause a more significant loss.
Diversification assists in reducing concentration risk. Equity mutual funds may include small-, mid- and large-
capitalization stocks. Small- and mid-capitalization companies may have greater price volatility, lower trading
volume and less liquidity than large-capitalization companies.
•
Exchange Traded Funds (“ETFs”): While investing in ETFs has similar risks as investing in individual
equities, ETFs typically invest in a diverse group of securities. The level of diversification varies by ETF. While
ETFs reduce the effects of concentration risk as compared to investing in a single security, certain ETFs are
susceptible to industry, commodity or country risk. Investing in a diverse selection of ETFs may help to reduce
this risk. Another important factor to consider with ETFs is that the portfolio of securities in which they invest
are typically not actively managed. Leveraged and Inverse ETFs bear unique risks that investors who wish to
trade in these securities must understand; due to the significant risk involved in these securities, Capital
Analysts will approve their use only on an exception basis.
•
Fixed Income Investments: One of the most important risks associated with fixed income securities is interest
rate risk, the risk encountered in the relationship between bond prices and interest rates. The price of a bond will
change in the opposite direction of movements in prevailing interest rates. For example, as interest rates rise,
bond prices will generally fall. If an investor has to sell a bond prior to the maturity date, an increase in interest
rates could mean that the bondholder, will experience a capital loss (i.e., selling the bond below its original
purchase price).
Reinvestment risk is the risk that the interest rate at which the interim cash flows can be reinvested will decline
and thus reinvestments will receive a lower interest rate. Reinvestment risk is greater for longer holding periods.
Default risk is commonly referred to as “credit risk” and is based on the probability that the issuer of the debt
obligation may default. Default risk is rated by quality ratings assigned by commercial rating companies.
Call risk is the risk related to call provisions on debt obligations. You should be aware of four risks associated
with call provisions.
1) The cash flow patterns of callable bonds are not known with certainty.
2) Since the issuer will typically exercise their right to call the bonds when interest rates have dropped,
you may be exposed to reinvestment risk. You would have to reinvest the proceeds after the bond is
called at relatively lower interest rates.
4)
3) The potential for capital appreciation of a callable bond is reduced relative to that of a non-callable
bond, because its price may not rise much above the price at which the issuer can call the issue.
If the issue is purchased at a premium, you may lose the difference between the purchase price and call
price.
Inflation risk arises because the value of the cash flows being received from a debt obligation may actually lose
purchasing power over the course of time due to the effects of inflation.
Liquidity risk depends on the ease with which an asset can be sold at or near its current value. The best indicator
to measure an issue’s liquidity is the size of the spread between the bid price and the ask price quoted by a
dealer. A wider spread on the asset indicates a greater liquidity risk. If you plan on holding a bond until its
maturity date, liquidity risk is less of a concern.
Finally, exchange rate risk, which is encountered in non-dollar denominated bonds or bonds whose payments
occur in a foreign currency, has unknown U.S. currency cash flows. The dollar cash flows are dependent on the
exchange rate at the time the payments are received. For example, consider a bond whose coupon payment is
paid out in Japanese yen. If the yen depreciates relative to the U.S. dollar, fewer net dollars will be received.
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Conversely, if the yen should appreciate relative to the U.S. dollar, the investor will benefit by receiving more
net dollars.
Debt funds may include mortgage-backed securities and Treasury Inflation-Protected Securities (“TIPS”).
Mortgage-backed securities are subject to greater declines in value than traditional fixed income securities. This
is primarily due to decreased prepayments when interest rates fall, which could lengthen the average life of a
security. TIPS can provide a hedge against inflation, which helps preserve the purchasing power of the
investment. Because of this inflation adjustment feature, inflation protected bonds typically have lower yields
than conventional fixed rate bonds. These bonds will likely decline in price during periods of deflation, which
could result in losses.
• A number of fund companies are offering Floating Rate funds, also called Bank Loan funds. The fund invests
mainly in floating rate loans (sometimes referred to as “adjustable rate loans”) typically issued to below-
investment-grade companies. These loans may or may not hold a senior position in the capital structure of the
underlying U.S. and foreign corporations, partnerships or other business entities. Senior Loans may allow them
to have priority of claim ahead of (or at least as high as) other obligations of a borrower in the event of
liquidation and may be collateralized or uncollateralized. They typically pay interest at rates that float above, or
are adjusted periodically based on, a benchmark that reflects current interest rates. These funds are designed for
investors seeking to participate in the market for Senior Loans, which may have higher risks than conventional
debt securities. Investors should be willing to assume the greater risks of short-term share price fluctuations and
the special credit risks that are typical for a fund that invests mainly in below-investment-grade fixed income
securities. The fund is not designed for investors needing an assured level of current income. Lincoln
Investment’s use of these securities in its managed portfolios is only in well-diversified portfolios, to minimize
the risks to the portfolio yet allow for the potential participation in the higher yields associated with these higher
risk investments.
•
International Investing: Investing in the global market can assist with diversification of a portfolio but it is
important to consider some of the unique risks with such a strategy. Funds purchased for your account may
invest in international securities. Each country has unique rules and regulations covering corporations and their
stock markets which offer investors varying degrees of protection. There are special risks associated with
foreign investing, including currency fluctuations, economic instability and political developments. Fluctuations
in foreign currency-denominated securities may be magnified by changes in foreign exchange rates. These risks
may be magnified in emerging markets.
• Options: Certain options strategies are highly specialized contracts based on securities and entail greater than
ordinary investment risks.
For further information regarding the risks associated with the portfolios managed by Capital Analysts and its
Advisors and the best suited investment strategies for your account(s), please review the risk level of the Wrap Fee
Program portfolio you have selected and your fund prospectuses, or consult with your Advisor.
Voting Client Securities
The IM&R Team, through the Proxy Voting Committee, votes proxies on behalf of all accounts in the Capital
Analysts Managed Programs custodied at Pershing, with the exception of proxies for securities held in CAAMS
Strategist accounts. The Committee does not vote proxies for any other Capital Analysts accounts, and no Capital
Analysts Advisors may vote proxies on behalf of clients. Proxies for securities held in CAAMS Strategist accounts
are voted by the client. For accounts in programs other than the Capital Analysts Managed Programs mentioned
above, you will receive proxies and solicitations for voting client securities directly from your custodian, transfer
agent or us, or a designee thereof.
The Capital Analysts Proxy Voting Policy and Procedures are designed to ensure that when the responsibility for
voting client proxies rests with Capital Analysts, such proxies are voted in the clients’ best economic interest.
Economic interest means in a manner most likely to protect and promote the long-term economic value of the
securities held in the clients’ accounts. The Proxy Voting Committee, guided by the Proxy Voting Policy and
Procedures, is responsible for arriving at voting decisions that support economically advantageous corporate
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practices, while leaving direct oversight of company management and strategy to the Board of Directors and allow
the markets to value corporate assets appropriately. The procedures offer guidelines and factors to consider for
various categories of shareholder votes.
In addition, Capital Analysts could encounter a material conflict in voting client proxies. Capital Analysts has a duty
to recognize a material conflict and to resolve the conflict before voting the proxy. Material conflicts of interest
include situations where Capital Analysts or a member of the IM&R Team has a business or familial relationship
with an executive officer or member of the Board of Directors of a company for which the firm is voting proxies.
Members of the IM&R Team are required to disclose all business and familial relationships that may present a
material conflict of interest with respect to a future proxy vote, and the Proxy Voting Committee will abstain from
voting the proxies of a company where such a material conflict exists.
To obtain a copy of the full Capital Analysts Proxy Voting Policy and Procedures, or to inquire on how a particular
proxy was voted on your behalf, contact your Advisor.
Item 7: Client Information Provided to Portfolio Managers
When your Wrap Fee Program account is opened, your Advisor will assist you in completing confidential investor
profile containing personal and financial information such as your risk tolerance, investment objectives, net worth,
and investing time horizon. This information will be communicated to the IM&R Team when the Wrap Fee Program
offers custom portfolio management. Your Advisor will contact you annually thereafter to confirm there have been
no changes in your risk tolerance, investment objectives or financial situation, which would need to be
communicated to the CAAMS portfolio manager who is performing the custom management.
Capital Analysts, the IM&R Team, your Advisor, and any other portfolio manager(s) rely on the accuracy of the
information you provide to manage your account(s). You are responsible to notify your Advisor of any changes in
your financial situation or investment objectives.
Item 8: Client Contact with Portfolio Managers
You may contact and consult with Capital Analysts, your Advisor, and the IM&R Team in writing, over the phone
or electronically. The IM&R Team may hold regular conference calls to discuss investment strategies or current
market events. In general, you should contact Capital Analysts and the IM&R Team through, or together with, your
Advisor so that the financial advice you receive is consistent.
Item 9: Additional Information
Disciplinary Information
Provided below is a summary of legal or disciplinary events within the past ten years that may be material to your
evaluation of Capital Analysts’ advisory business.
September 14, 2018:
Capital Analysts entered into a settlement with the SEC for alleged violations of the Investment Advisers Act of
1940 (“Advisers Act”) in connection with its mutual fund share class selection practices and receipt of
shareholder servicing fees for the CAAMS Wrap Fee Programs managed on the Pershing LLC platform. The
firm neither admitted nor denied the SEC’s allegations in agreeing to the settlement. The SEC alleged that
from April 2013 through March 2016, Capital Analysts did not disclose that it had a conflict of interest when
it invested CAAMS Wrap Fee clients in mutual fund share classes that paid 12b-1 fees to its affiliated broker-
dealer, Lincoln Investment Planning, LLC (“Lincoln Investment”) when a lower-cost share class of the same
fund without a 12b-1 fee was available. The SEC also alleged that Capital Analysts did not meet its duty of best
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execution; failed to adopt and implement written policies and procedures reasonably designed to address mutual
fund share class selection and related conflicts of interest; and did not adequately disclose that its affiliate
Lincoln Investment received shareholder servicing fee revenue in connection with Capital
Analysts’ recommendation of certain mutual funds for the CAAMS Wrap Program. The SEC’s Order recognized
remedial actions voluntarily undertaken by Capital Analysts. Capital Analysts was censured and ordered to cease
and desist from further violations of the Advisers Act. Under the terms of the settlement, Capital Analysts paid
to the US Treasury a $300,000 civil monetary penalty and shareholder services fee revenue, with interest, in the
amount of $770,476. The firm also refunded to affected clients $1.02 million in 12b-1 fees.
Your Advisor should provide, along with this brochure, a Form ADV 2B Brochure Supplement that describes
your Advisor’s education, business experience, professional designations and material legal or disciplinary
history, if any. For further information regarding Capital Analysts’ disciplinary events, you may go to
www.adviserinfo.sec.gov or https://brokercheck.finra.org and search for Capital Analysts, LLC.
Other Financial Industry Activities and Affiliations
Relationship with Lincoln Investment
As noted earlier, Capital Analysts is an affiliate of Lincoln Investment Planning, LLC, which is a registered
broker-dealer and investment adviser, as well as a general insurance agency. The majority of Capital Analysts
advisors are also registered representatives of Lincoln Investment. This relationship presents a conflict of
interest. Additionally, through its relationship with Lincoln Investment, Capital Analysts introduces client
accounts to Pershing, a broker-dealer and member of the New York Stock Exchange, which provides custody
and clearing of securities, including exchange traded securities. Pershing carries accounts on a fully disclosed
basis. Please refer to the “Other Compensation and Our Conflicts of Interest” section under Item 4 of this
brochure for more information.
Other Affiliated Investment Adviser
Capital Analysts is a wholly-owned subsidiary of Lincoln Investment Capital Holdings, LLC. Advisors of
Capital Analysts may be dually registered to offer the advisory services of Lincoln Investment Planning, LLC,
an affiliated investment adviser.
Advisors’ Other Business Activities and Affiliations
Capital Analysts' Advisors are independent contractors, many of whom hold themselves out to the public under a
name other than Capital Analysts and offer other financial services independent of Capital Analysts, such as, life,
health, disability, long term care and fixed annuity insurance products, real estate, and business succession
planning services. A few of our Advisors may also be qualified lawyers and accountants or hold certain
professional designations not required by us to conduct their business. These services are offered independent of
Capital Analysts as outside business activities and Capital Analysts assumes no responsibility or supervision
over these activities. Please refer to the "Other Compensation and Other Conflicts of Interest” section under Item
4 of this brochure, or refer to your Advisor’s ADV 2B brochure supplement, for more information regarding
outside business activities and how we address these conflicts. You may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org for further information regarding your Advisors' other business activities or
affiliations.
Independent Registered Investment Advisers
Capital Analysts and its affiliate, Lincoln Investment, permit certain Advisors to maintain or affiliate with an
independent registered investment advisory firm which may offer advisory services similar to Capital Analysts
and Lincoln Investment. Such independent registered investment advisory firms are unaffiliated with Capital
Analysts and Lincoln Investment. These services are offered independent of Capital Analysts and Lincoln
Investment as private securities transactions. Your Advisor can be associated with Lincoln Investment, Capital
Analysts, or an unaffiliated registered investment adviser as an investment adviser representative, and/or
associated with Lincoln Investment as a registered representative of Lincoln Investment’s broker-dealer. As
such, your Advisor can be in a position to offer you advisory services under Lincoln Investment, Capital
Analysts, the unaffiliated independent registered investment advisory firm, and brokerage services under Lincoln
Investment’s broker-dealer, or all of the above.
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Advisors affiliated with other registered investment advisory firms must provide to their clients the firm’s Form
ADV Part 2A, applicable supplements, advisory agreements and disclosures if you are opening an account with
such other investment advisory firm. To inquire as to whether your Advisor is affiliated with a separate
registered investment advisory firm, it will be listed on their Financial Professional BIO Brochure (Form ADV
Part 2B), a copy of which they are required to provide to you, you may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
As an investment adviser, Capital Analysts has established a Code of Ethics under which all Capital Analysts
supervised employees and Advisors must comply. In our capacity as an investment adviser, Capital Analysts
owes a fiduciary duty to our investment advisory clients and is held to legal standards under applicable federal
and state securities laws. Capital Analysts has a fiduciary responsibility to (1) provide investment advice that the
advisor believes is in the best interest of the client; (2) place clients interest above the interests of Capital
Analysts and your advisor by providing full and fair disclosure of all material facts and conflicts of interest to
clients, and (3) conduct all personal securities transactions consistent with our Code of Ethics.
Capital Analysts’ Advisors are held to a professional standard that requires them to avoid any abuse of an
individual's position of trust and responsibility; not take inappropriate advantage of their positions; comply with
applicable securities laws and regulations; and maintain confidentiality of client's financial circumstances. You
may request a full copy of Capital Analysts’ Code of Ethics from your Advisor or Capital Analysts’ Compliance
Department at (800) 242-1421, ext. 4300.
Participation or Interest in Client Accounts and Personal Trading
Capital Analysts, its Advisors, members of the IM&R Team, and employees may buy or sell for themselves
securities that are also recommended to clients. Other than as described in its Code of Ethics and its Insider
Trading policies and procedures, Capital Analysts does not impose on itself or any person associated with it any
restrictions in connection with the purchase or sale, directly or indirectly, of investments for his or her own
account. Capital Analysts requires that Advisors disclose conflicts of interest to you if an investment product is
recommended in which Capital Analysts or the Advisor has a material financial interest.
The Advisor and his or her employees must give first priority when placing an order to buy or sell to client
securities purchases and sales over their own personal transactions in the same security. This means that any
transaction by the Advisor or his/her employee must be placed either simultaneously with the client’s transaction
(i.e., aggregating the orders and sharing in the same price and execution costs) or after all client trades are placed
on the same trading day. While this does not guarantee that the client will receive a better price, it does establish
that the client trades will occur at the same time or before that of the Advisor or his/her employees. At no time
may an Advisor participate in the profits or losses of an investor's account. Personal trading accounts of Advisors
are monitored regularly to ensure compliance.
Brokerage Practices
Capital Analysts utilizes its affiliate, Lincoln Investment, as its introducing broker-dealer unless specifically directed
by a client or third-party manager to place trades with another broker-dealer. Lincoln Investment’s primary clearing
arrangement is with Pershing. Pershing may make a market in stocks, bonds, and ETFs in which Lincoln Investment
has acted as broker. Lincoln Investment and Capital Analysts have policies and procedures in place to monitor trade
execution practices at Pershing to its best execution obligations with respect to these types of securities on behalf of
Capital Analysts’ clients.
Capital Analysts does not receive “research” or higher execution costs (soft dollars) from broker-dealers in exchange
for the directing of brokerage. Most transactions clear through Pershing to facilitate our ability to access and
properly monitor your investments.
Capital Analysts may on occasion place non-exchange traded securities transactions with Pershing through its
introducing broker-dealer affiliate, Lincoln Investment, unless otherwise directed by the client. Clients have the right
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to utilize a broker-dealer other than Pershing; however, Capital Analysts reserves the right to accept or reject such
accounts based on its ability to provide adequate account monitoring and best execution.
Trade Aggregation Policy
Offering advisory services to clients includes an obligation on the part of Capital Analysts and its Advisors to
ensure that the allocation of investment opportunities or trades among its various client accounts, as well as
accounts in which it (or its affiliates) has a proprietary interest, is performed in a manner that is fair and
equitable in its treatment of all clients and, wherever possible, avoids conflicts of interest.
Therefore, Capital Analysts has adopted an Aggregated Trade Allocation Policy to be used by Capital Analysts
and Advisors who have been granted full discretionary authority by their clients when placing orders in the
same security on the same day for one or more clients or accounts. By aggregating orders, Advisors ensures
that all clients receive that same price for the security on the same day. This policy is intended to prevent
favoritism of one client over another and establish a rational and predictable fashion for the allocation of trade
pricing on a given day for a given security.
Trades in the following situations will typically be aggregated:
• Capital Analysts or the Advisor recognizes ahead of time that he/she will be buying or selling the same
security in more than one client account on the same day;
• Capital Analysts or the Advisor reasonably believes that aggregating may facilitate a better execution
price for all clients; and
• The securities involved are exchange-traded rather than open-ended funds or annuity sub-accounts.
Trades in the following situations will not typically be aggregated:
• Where prohibited by or inconsistent with the client’s investment advisory agreement;
• The trade is a result of the implementation of a change of investment strategy for a specific client;
• The trade is part of a new client’s account allocation;
• The trade is a result of rebalancing to an asset allocation policy pursuant to an account review with the
client; and/or
• Capital Analysts or the Advisor reasonably believes that aggregating orders would adversely impact price
and/or best execution for the client.
If the security to be purchased in aggregate cannot be obtained in the total quantity required, the allocation of
that security will be made on a pro rata basis determined by the ratio of the quantity obtained to the share
quantity required to implement the investment strategy. Each client would participate in the order at the
average price for all of the transactions on a given day. The transaction cost to all advisory clients shall be the
standard ticket charge for the aggregated order.
If implementing the trade requires transactions over several days, each day’s execution shares and average
price on all executions for that day shall be allocated by the end of each trading day or no later than the next
trading day.
In the course of executing an aggregated trade, a list of clients’ accounts and shares to be bought or sold is to
be prepared. This is to be used in allocating the trade and the list is to be kept as a record with the original
aggregated trade order. Allocation of shares, prices, and costs shall be done on a timely basis, in no event to
exceed 24 hours following execution. Capital Analysts and your Advisor do not receive any additional
compensation for aggregating trades.
With respect to accounts managed on a discretionary basis by Capital Analysts’ IM&R Team, portfolios that
utilize the same trading discipline in multiple models managed across multiple platforms are subject to the
Advisory Program Rotation Policy. Due to platform differences, it is not always possible to trade all
reallocations and rebalancing within all similar model portfolios on the same day or, in the case of exchange-
traded securities, at the same time. Therefore, the firm has established an Advisory Program Rotation Policy
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whereby the firm will attempt to rotate the order of trade initiation by platform for multi-platform models to
ensure clients are treated equitably and fairly over time. Advisory Program models will rotate the order in
which their transactions are sent by platform, allowing each model to occupy each position in the trade rotation
once per reallocation event before the cycle resets.
Capital Analysts’ advisory assets at Pershing comprise the majority of the firm’s managed assets. In order to
minimize financial impact to the majority of clients, the trade allocation policy will not apply in the event of
significant market volatility and Capital Analysts will give priority to advisory assets at Pershing.
Capital Analysts Managed Program model portfolios are generally traded in concert as described above;
however, there are certain portfolios within Capital Analysts Managed Programs that are managed on a custom
basis which trade separately from the models.
Review of Accounts
Account Review Policies and Procedures
Your Advisor is responsible to ensure that the recommended advisory service is in your best interest. Many of
our programs are managed to defined levels of risk, so choosing the appropriate risk level or tolerance for
market fluctuation and potential loss of investment is an important part of your decision. Furthermore, the
Advisor Fee portion of your fees compensates your Advisor for his or her services.
Discretionary authority granted to Advisors may be limited or full. See the Investment Discretion paragraph
below for the definition of limited versus full discretionary authority. If Capital Analysts or your Advisor have
been granted full discretionary trading authority over your advisory account, Capital Analysts or your Advisor
will provide ongoing monitoring and will make changes in your account as deemed necessary. If your Advisor
has been granted limited discretionary trading authority over your advisory account, your Advisor will provide
ongoing monitoring. For all other non-discretionary advisory accounts, you and your Advisor will review your
advisory account’s objectives, investments and performance relative to your objectives and financial situation
at least annually to allow your Advisor the opportunity to recommend changing or maintaining the objectives
or investments in your account. It is important, therefore, that you take the time to speak with your Advisor
regarding your financial objectives and needs and particularly when there is a material life event that could
affect or change your investment objectives or financial needs.
Capital Analysts has procedures in place to supervise the investment advisory activities of its Advisors. If you
have any questions about the trading or recommendations in your account, please call your Advisor's
Designated Supervisor.
Capital Analysts’ IM&RT team routinely reviews the advisory services managed, sponsored, and/or offered by
Capital Analysts. A description of the IM&R Team is provided at the end of this brochure. The IM&R Team
performs the following roles on Capital Analysts’ behalf:
• The management of all Capital Analysts Managed Programs;
• The selection of advisory services offered by Capital Analysts;
• The monitoring of advisory services offered by Capital Analysts;
• The removal of advisory services offered by Capital Analysts;
• The comparison of advisory results to predetermined benchmarks to monitor whether the investment
advisers’ offerings are providing value to clients.
Written Reports
At minimum, you will receive regular account statements, either monthly or quarterly depending on your
account activity, from the custodian(s) who carry your account(s). As most Capital Analysts advised or
managed accounts are custodied at Pershing, you will receive these statements directly from Pershing, either in
hard copy or electronic format. This statement will reflect all positions and transactions that have occurred in
your account as well as identify any fees, including the advisory fee, deducted from your account.
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Some Advisors and advisory services may also provide you supplemental advisory reports, which may include
performance reports, aggregated account reviews, or a portfolio snapshot. These supplemental reports,
typically generated on a quarterly, semi-annual or annual basis, are made available to you either electronically
or will be delivered to you at the time of a meeting. These supplemental reports are provided as a service to
you and should not replace your custodial statement(s). We urge you to compare these supplemental reports to
the account statements you receive. If you find any discrepancies, please contact your Advisor or Capital
Analysts.
Client Referrals and Other Compensation
Advisors and Capital Analysts can act as a promoter and introduce you to a third-party money manager. For this
introduction, the third-party money manager will pay Capital Analysts a Promoter/Referral Fee, which we will share
with your Advisor. This fee, which is typically an ongoing portion of the fee collected from you by the manager,
must be disclosed to you at the time of the introduction in a Disclosure Statement. In some instances, Capital
Analysts and your Advisor share in the money manager’s advisory fee; in other instances, Capital Analysts assesses
a separate fee for our referral in addition to the money manager’s fee. Please refer to the Disclosure Statement
provided to you at the time of the referral to determine the fee paid to Capital Analysts and your Advisor. Please
review the third-party money manager’s ADV Part 2A for more information about their advisory fees. See Item 4,
Advisory Business and Item 5, Fees and Compensation of the ADV Part 2A and Item 4, Services, Fees and
Compensation of the ADV Part 2A Appendix I for additional information and conflicts of interest. . No new
relationships in which Capital Analysts compensates or permits an Advisor to compensate an outside party for client
referrals are permitted. The outside party must execute an agreement with Capital Analysts, and you will receive a
Disclosure Statement at the time of the referral describing the relationship, material conflicts of interest and the
compensation paid by the promoter.
For details regarding other compensation received by Capital Analysts, its affiliate, Lincoln Investment, your
Advisor and associated conflicts of interest, see Item 4: Services, Fees and Compensation in the section titled "Other
Compensation to Lincoln Investment, Capital Analysts and Our Conflicts of Interest."
Custody
Advisers Act Rule 206(4)-2 (the “Custody Rule”) sets forth extensive requirements regarding possession or custody
of client funds or securities. The Custody Rule is designed to ensure that RIAs with access to client assets (securities
or cash) establish procedures to protect the assets from misappropriation, conversion, insolvency of the adviser or
unauthorized reallocation of securities among clients. Capital Analysts’ advisory account assets are held with
unaffiliated third-party custodians who serve as qualified custodians and provide clients with, at minimum, quarterly
account statements. Pershing acts as the custodian for the majority of Capital Analysts’ Asset Management Services
(“CAAMS”) programs. Capital Analysts is not a “qualified custodian” under the Custody Rule. For some advisory
assets, the firm is deemed to have custody and is therefore required to undergo an annual surprise exam.
If you have advisory assets held at Pershing or another qualified custodian, you will receive, at minimum, a
quarterly statement from the qualified custodian(s) of your advisory assets. We urge you to carefully review these
statements and compare them to any reports provided to you by Capital Analysts or your Advisor. The information
in these reports may vary from your custodial statements based on accounting procedures and reporting dates. Please
contact your Advisor or Capital Analysts regarding any statement discrepancies.
Investment Discretion
Depending on the advisory service chosen, Capital Analysts, its Advisors, or a third-party money manager may have
discretionary authority to determine which securities shall be bought and sold, and the total amount to be bought or
sold in your advisory account(s). This authorization does not grant Capital Analysts or its Advisors the right to
withdraw any funds or securities from your advisory account(s), except as specifically authorized in your advisory
agreement for the deduction of Advisory Fees. Your advisory agreement or account application will identify
whether, and to what degree, you have granted Capital Analysts, your Advisor, or a third-party money manager
discretionary authority on your account.
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Discretionary authority granted to Advisors may be limited or full. “Full discretion” means your Advisor has the
authority to decide on the securities to purchase, sell or trade in your account without prior consultation with you.
“Limited discretion” means that you authorize your financial professional to rebalance your account back to a pre-
authorized allocation. For other than a pre-authorized portfolio allocation, you will make the ultimate decision
regarding the purchase or sale of investments. Limited discretion, which has been granted to all Advisors with
respect to Advisor Managed Model Portfolios and Client Custom Portfolios held at Pershing, allows them, when
necessary, to liquidate shares in one or more securities for the sole purpose of using proceeds to satisfy a shortfall in
funds available for the deduction of the monthly investment advisory fee. An Advisor with limited discretion does
not have the authority to select new securities to be purchased in your account. The final decision as to any new
securities to be bought or sold remains with the client in a limited discretion account. “Non-discretionary”
investment management programs are those in which we or your Advisor will recommend investments to you and
you will make the ultimate decision regarding the purchase or sale of investments. Your written investment advisory
agreement or account application will identify whether, and to what degree, you have granted your Advisor
discretionary authority on your account.
If Capital Analysts or your Advisor have been granted full discretionary trading authority over your advisory
account, Capital Analysts or your Advisor will provide ongoing monitoring and will make changes in your account
as deemed necessary. If your Advisor has been granted limited discretionary trading authority over your advisory
account, your Advisor will provide ongoing monitoring. For all other non-discretionary advisory accounts, you and
your Advisor will review your advisory account’s objectives, investments and performance relative to your
objectives and financial situation at least annually to allow your Advisor the opportunity to recommend changing or
maintaining the objectives or investments in your account.
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Form ADV Part 2B Brochure Supplement
Capital Analysts, LLC
Form ADV Part 2B Brochure Supplement
As of August 8, 2025
Principal Office:
601 Office Center Drive, Suite 300
Fort Washington, PA 19034
Investment Management & Research
Shashi Mehrotra, CFA®
Christopher J. Surrichio, CFA®
Gerald E. Burhop, CFA®, CIPM®
Brian Moran
Ted O’Donoghue
This brochure supplement provides you with information about the five (5) members of the Investment Management
& Research Team (“IM&R Team”) of Capital Analysts, LLC (“Capital Analysts”) who have the most significant
day-to-day management responsibilities for the Capital Analysts managed portfolios. This information supplements
the information contained in the Capital Analysts Form ADV 2A and/or Wrap Fee Program brochure, which you
should have received.
If you have any questions about the contents of this brochure supplement, please contact us at (800) 242-1421.
Additional information about each of the members of the IM&R Team is available through the U.S. Securities and
Exchange Commission at www.adviserinfo.sec.gov.
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Shashi Mehrotra, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1966
Education
Master of Business Administration, Florida Atlantic University, 1994
Bachelor of Engineering, Osmania University, 1989
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Lincoln Investment Planning, LLC, May 2019 – July 2025, Senior Vice President and Chief Investment Strategist
Capital Analysts, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Capital Analysts, LLC, September 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, January 2017 – Present, Registered Representative
Legend Advisory, LLC, April 2011 – September 2019, Investment Adviser Representative
Legend Equities Corporation, January 1996 – January 2017, Registered Representative
Legend Advisory, LLC, July 1995 – September 2019, Chief Investment Officer/Chief Operating Officer
Professional Licenses/Designations
Mr. Mehrotra holds general securities principal and general securities representative licenses with Lincoln
Investment.
In addition, Mr. Mehrotra maintains the following professional designation:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Undergraduate
degree and four years of professional experience involving investment decision-making, or four years
qualified work experience (full time, but not necessarily investment related)
Education Requirements: Self-study program (250 hours of study for each of the three levels)
Exam Type: Three course exams
Continuing Education Requirements: None
DISCIPLINARY INFORMATION
Mr. Mehrotra has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
Mr. Mehrotra sits on the Board of Directors of Aqua Pulsar, a water-engineering company, where he assists with
strategic financial and investment decisions. You are under no obligation as an investment advisory client to
purchase any outside products or services that Mr. Mehrotra may offer.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team IM&R Team are compensated through salaries and bonuses. They may be
compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan.
Salaries are fixed annually and are driven by the marketplace. Compensation is not affected by an increase in
advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment.
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SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Mehrotra is Ed Forst, Chief Executive
Officer of Lincoln Investment Planning, LLC and Capital Analysts, LLC. Mr. Forst or his designee is responsible to
review the duties, responsibilities and trading assigned to Mr. Mehrotra. If you have any questions about the trading
in your account, please call Mr. Forst at (800) 242-1421.
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August 2025
Christopher J. Surrichio, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1970
Education
Bachelor of Arts, Economics, Boston College, 1992
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, June 2012 – July 2025, Vice President and Portfolio Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Investment Adviser Representative and Registered
Representative
Capital Analysts, Incorporated, 2002 – June 2012, Vice President
Professional Licenses/Designations
Mr. Surrichio holds general securities principal, general securities representative and research analyst licenses with
Lincoln Investment Planning, LLC (“Lincoln Investment”), a registered broker-dealer and investment adviser and an
affiliate of Capital Analysts, LLC.
In addition, Mr. Surrichio maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
DISCIPLINARY INFORMATION
Mr. Surrichio has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs offered by Capital Analysts and Lincoln
Investment Planning, LLC, an affiliated investment adviser. The management of portfolios for both investment
advisers may create a conflict.
Mr. Surrichio has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Surrichio is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Surrichio. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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August 2025
Gerald E. Burhop, CFA®, CIPM®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1964
Education
Master of Business Administration, Finance, Temple University, 1998
Bachelor of Science, Agricultural Journalism/Advertising, University of Wisconsin-Madison, 1988
Business Experience
Lincoln Investment Planning, LLC, 2002 – Present, Vice President and Portfolio Manager
Lincoln Investment Planning, LLC, October 1999 – Present, Registered Representative
Lincoln Investment Planning, LLC, April 2011 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, March 1999 – 2002, Mutual Fund Financial Analyst
Capital Analysts, LLC, March 2014 – Present, Investment Adviser Representative
Professional Licenses/Designations
Mr. Burhop holds general securities principal and general securities representative licenses with Lincoln Investment
Planning, LLC (“Lincoln Investment”), a registered broker-dealer and investment adviser and an affiliate of Capital
Analysts, LLC.
In addition, Mr. Burhop maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
Certificate in Investment Performance Measurement™ (CIPM®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Two years of
professional experience “substantially entailing performance-related activities,” or four years of investment
industry work experience
Educational Requirements: Self-study program (100 or more hours of study for each of the two levels)
Examination Type: Two level exams (Principles and Expert)
Continuing Education/Experience Requirements: Complete and record 15 hours of qualifying activities
annually
DISCIPLINARY INFORMATION
Mr. Burhop has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs offered by Capital Analysts and Lincoln
Investment Planning, LLC, an affiliated investment adviser. The management of portfolios for both investment
advisers may create a conflict.
Mr. Burhop has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
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Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Burhop is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Burhop. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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August 2025
Brian Moran
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1967
Education
Master of Business Administration, Drexel University, 2012
Bachelor of Science, Economics, University of Pennsylvania, 1990
Business Experience
Capital Analysts, LLC, May 2015 – Present, Vice President of Trading and Portfolio Manager
Capital Analysts, LLC, June 2012 – May 2015, Institutional Trading Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Registered Representative
Lincoln Investment Planning, LLC, August 2012 – Present, Investment Adviser Representative
Capital Analysts, Incorporated, 2001 – June 2012, Institutional Trading Manager
Professional Licenses/Designations
Mr. Moran holds general securities principal, general securities representative, municipal securities principal, and
options principal licenses with Lincoln Investment Planning, LLC (“Lincoln Investment”), a registered broker-
dealer and investment adviser and an affiliate of Capital Analysts, LLC.
DISCIPLINARY INFORMATION
Mr. Moran has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs offered by Capital Analysts and Lincoln
Investment Planning, LLC, an affiliated investment adviser. The management of portfolios for both investment
advisers may create a conflict.
Mr. Moran has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Moran is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Moran. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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August 2025
Ted O’Donoghue
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1976
Education
MBA, Investment Management/Finance, Smeal College of Business, Pennsylvania State University, 2008
Bachelor of Arts, Economics, Bucknell University, 2000
Business Experience
Capital Analysts, LLC, April 2012 – Present, Senior Research Analyst
Capital Analysts, LLC, March 2014 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, April 2012 – Present, Investment Adviser Representative and Registered
Representative
Commonwealth Financial Network, July 2008 – December 2011, Investment Consultant
Liberty Mutual, June 2007 – August 2007, CDP MBA Intern
Columbia Management, November 2002 – August 2006, Regional Sales Consultant
Professional Licenses/Designations
Mr. O’Donoghue holds general securities principal and general securities representative licenses with Lincoln
Investment, as well as through its affiliated RIA, Capital Analysts, LLC.
DISCIPLINARY INFORMATION
Mr. O’Donoghue has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs offered by Lincoln and Capital Analysts, LLC,
an affiliated investment adviser. The management of portfolios for both investment advisers may create a conflict of
interest.
Mr. O’Donoghue has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. O’Donoghue is Christopher J. Surrichio,
Deputy Chief Investment Officer. Mr. Surrichio or his designee is responsible to review the duties, responsibilities
and trading assigned to Mr. O’Donoghue. If you have any questions about the trading in your account, please call
Mr. Surrichio at (215) 881-7733.
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