Overview
- Headquarters
- Bronxville, NY
- Average Client Assets
- $2.4 million
- SEC CRD Number
- 126340
Fee Structure
Primary Fee Schedule (FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Negotiable | Negotiable |
| $5 million | Negotiable | Negotiable |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 65.60%
- Total Client Accounts
- 676
- Discretionary Accounts
- 673
- Non-Discretionary Accounts
- 3
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
Additional Brochure: FIRM BROCHURE (2026-03-30)
View Document Text
Form ADV
th
March 25
, 2026
Part 2A: The Brochure
Bronxville, New York
Form ADV
Part 2A: The Brochure
Capital Preservation Partners, Inc (CPP)
Part 2A of Form ADV
The Brochure
55 Pondfield Rd
Bronxville, NY 10708
www.cpp.bz.
Updated: March 25th, 2026
This brochure provides information about the qualifications and business practices of CPP.
If you have any questions about the contents of this brochure, please contact us by telephone
at (914) 337-2272, by facsimile at (914) 961-1715 or through our web site at www.cpp.bz. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority and SEC registration does not imply a
certain level of skill or training.
CPP delivers its Form ADV Part 2 along with each new client’s investment advisory agreement.
Following signature of the investment advisory contract, client has 5 days to unconditionally
rescind the contract at no charge. Client is bound however to settle any transactions CPP may have
effected for the account during the 5 days at client’s risk. Form ADV Part 2 is also provided annually
to existing clients if there are material changes or upon request.
Additional information about CPP is also available on the SEC’s website at: www.adviserinfo.sec.gov.
2
Form ADV
Part 2A: The Brochure
Material Changes
The following is only a description of the material changes to this brochure since its
last annual update, dated March 25th, 2026.
•
No Material Changes to report
3
Form ADV
Part 2A: The Brochure
Table Of Contents
Item 2
Material Change
3
Item 3
Table of Content
4
Item 4
Advisory Business
5
Item 5
Fees and Compensation
5
Item 6
Performance-Based Fees and Side-by-Side Management
6
Item 7
Types of Clients
8
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
8
Item 9
Disciplinary Information
9
Item 10
Other Financial Industry Activities and Affiliations
10
Item 11
Code of Ethics
10
Item 12
Brokerage Practices
13
Item 13
Review of Accounts
17
Item 14
Clients Referrals and Other Compensation
17
Item 15
Custody
18
Item 16
Investment Discretion
19
Item 17
Voting Client Securities
19
Item 18
Financial information
20
4
Form ADV
Part 2A: The Brochure
4. ADVISORY BUSINESS
CPP was established in 1992 and became registered with the U.S. Securities and Exchange
Commission in 2009.
Kevin Mullins and Ilir Leo Gjoni are joint owners and share responsibility for all
operations of CPP. CPP provides its clients with financial planning and both discretionary
and, on occasion, non-discretionary investment advisory services. Further information
about CPP’s advisory services and financial planning can be found below. CPP generally
recommends to clients that they arrange for custody of their accounts at Charles Schwab
& Co. (“Schwab”)
5. FEES AND COMPENSATION
A. Investment Advisory Services
Prior to engaging CPP to provide investment advisory services, clients are required
to enter into a formal Investment Advisory Agreement with CPP setting forth the terms
and conditions under which CPP will manage the client's investments, and the fees or
other charges the client will pay. Separate account application, bank information and
custodial documents may also be required prior to establishing an account.
CPP determines a suitable portfolio based upon the information provided by the client
as to the Client's investment objectives, risk tolerance and financial circumstances.
CPP will create tailored investment portfolios though the use of but not limited to
stocks, bonds, mutual funds, ETF’s, equity linked CDs, preferred notes, etc. CPP will
review client portfolios on an ongoing basis to determine if any changes are necessary
based upon various factors, including, but not limited to, investment performance,
market conditions, fund manager tenure, factor exposure, asset class or style drift,
account additions/withdrawals, and/or a change in the client’s investment objective,
financial position, or tax situation. Based upon these factors, it is not uncommon that an
extended period of time will pass where CPP determines that changes to a client’s
portfolio are neither necessary nor prudent. CPP primarily recommends that clients
allocate their investment assets among various equity, fixed income and REIT products.
CPP then designs an investment portfolio in accordance with the client's investment
objectives, risk tolerance, and investment restrictions (if any) imposed by the client.
CPP generally requires the client(s) to grant our firm discretionary authority to manage
their account(s). Discretionary authorization allows CPP to determine the specific
securities, and the securities, to be purchased or sold for your account without the
client’s prior consent. As of CPP’s fiscal year end (December 31, 2025), CPP manages
[$218,325,929] on a discretionary basis and [$ 4,038,537] on a non- discretionary basis.
5
Form ADV
Part 2A: The Brochure
B. Financial Planning
To the extent specifically requested, and as determined by a client, CPP may also
include planning in connection with (i) financial independence/retirement planning;
(ii) capital and liquidity needs analysis and related financial modelling; (iii)
philanthropy planning and implementation; (iv) education planning; (v) employee
stock option planning; (vi) consideration and evaluation of financing transactions and
risk reduction strategies for concentrated equity positions; (vii) advice incident to
major asset purchases and sales; and (viii) managing philanthropic plans, tax
strategies, wealth transfer strategies, and legacy plans as desired. Planning and
consulting services are offered to clients in varying combinations and with various
corresponding fee arrangements depending upon the level and scope of the requested
service(s) to be provided.
C. Wrap Fees Programs
A wrap fee program is an investment program where the investor pays one stated fee
that includes management fees, transaction costs, fund expenses, and other
administrative fees. CPP does not participate in any wrap programs
6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
A. Investment Advisory and Other Fees
The client will pay CPP an investment advisory fee of 1.25% annually billed quarterly
in advance on assets from $0-500,00 and 1.1% on assets above $500,00 or as
individually negotiated. CPP reserves the right to negotiate investment management
fee arrangements with prospective and existing clients. CPP Advisors can agree to
make exceptions to its standard fee schedule on a case-by-case basis at its discretion.
Investment management and other fees assessed (including without limitation those
associated with financial planning, tax, estate planning and other services) vary from
client to client depending upon a number of factors, including the amount of assets
under management, the nature of the assets, the type of analysis required to manage
the account(s), the level of service required by the client, the longevity of the client
relationship with CPP Advisors, and other factors Payments are divided into
Quarterly (see definition below) installments based on the assets under management
or as individually negotiated.
6
Form ADV
Part 2A: The Brochure
The client agrees to pay an annual asset management fee in advance divided into
Quarterly installments based on the market value of the portfolio at the beginning of
each of those four Quarters in accordance with the above fee schedule. The annual
management fee will be re-calculated every three (3) months. Asset management fees
are billed in advance of each Quarter and payment is due on or before the tenth (10th)
business day of the respective Quarter. Clients will have management fees directly
deducted from their account, unless different payment instructions have been
individually negotiated and agreed upon.
A Quarter is defined as three sequential months. The first chargeable Quarter is the
three-month period beginning on the first day of the month in which the respective
Investment Advisory Agreement is signed. The second, third and fourth Quarters of
that year, for purposes of the management fee, are the three-month periods that follows.
For the avoidance of doubt, the management fee may not align with the calendar year.
CPP automatically prorates advisory fees to account for capital flows in clients’
advisory accounts. If a deposit is made by a client, then in the following Quarter, CPP
will calculate an additional fee for the prior Quarter based upon the adjusted value of
the account from the date of the deposit through the last day of the Quarter in which
the deposit was made, and the fee will be debited from the client’s account. If a
withdrawal is made by a client, then in the following Quarter, CPP will calculate the fee
to be credited to the client for the prior Quarter based upon the adjusted value of the
account from the date of the withdrawal through the last day of the Quarter in which
the withdrawal was made, and a fee rebate will be credited to the client’s account. All
fees deducted will be reflected on client statements from Schwab.
Investment management fees are separate and distinct from, and in addition to, other
fees that the client may pay including financial planning and consulting fees,
transaction fees, short term redemption fees, underlying mutual fund fees and
expenses paid to the fund by shareholders of the fund as outlined in each fund's
prospectus, and custodial fees. In addition, clients will pay brokerage and transaction
fees, commissions, transfer taxes, exchange fees, and any other charges that may be
imposed with regard to the client's brokerage account and securities transactions. See
Item 12 for information regarding brokerage practices.
CPP and its supervised persons do not accept compensation for the sale of securities
or other investment products, including asset-based sales charges or service fees from
the sale of mutual funds such as 12b-l fees.
CPP reserves the right to liquidate client holdings in the event that clients are unable
to make advisory fee payments. CPP will provide clients with notice prior to effecting
such liquidations.
7
Form ADV
Part 2A: The Brochure
B. Termination and Fee Refunds
The Client shall have five (5) business days from the execution date of the Investment
Advisory Agreement to terminate the services without penalty. Thereafter, the
Investment Advisory Agreement may be terminated
in accordance with the
termination provisions of the Agreement which is generally 30 days after receipt
of written notice to terminate by either party to the other. The client's death, disability
or incompetence will not terminate or change the terms of the agree agreement.
However, the client's executor, guardian, attorney-in-fact or other authorized
representative may terminate the Agreement by providing CPP with proper written
notice. Termination of the Agreement will not affect (i) the validity of any action
previously taken by CPP under the Agreement; (ii) liabilities or obligations of the
parties from transactions initiated before termination of the Agreement; or (iii) the
client’s obligation to pay CPP fees that have already been earned under the
Agreement. Clients will receive a prorated refund of advisory fees which will be based
on the date of the termination notice signed by the client.
C. Performance-Based Fees and Side-by-Side Management
CPP does not charge clients any performance-based fees. Performance-based fees
would include, but not be limited to, any fee that would be based upon a share of capital
gains or capital appreciation of the assets in the client's account.
7. TYPES OF CLIENTS
CPP's clients are generally comprised of individuals, corporations, trusts, pensions and
profit-sharing plans. CPP does not have any requirements for opening or
maintaining accounts such as minimum account size.
8. METHODS OF ANALYSIS, INVESTMENT
STATEGIES AND RISK LOSS
A. Methods of Analysis
CPP employs fundamental and technical analysis prior to purchasing or selling a
security for a client's account. The following is a brief description of the two types
of analysis:
▪
8
Fundamental Analysis - is a method of evaluating a security that entails
attempting to measure its intrinsic value by examining related economic,
financial and other qualitative and quantitative factors. In doing so, CPP
Form ADV
Part 2A: The Brochure
attempts to study market factors that can affect the value of the securities
(like the overall economy and industry conditions) and company-specific
factor (like financial condition and management). CPP’s analyses result in
value determinations for the securities which are compared with their current
market prices to determine what respective positions to take (if any).
▪
Technical Analysis - is a method of evaluating securities by analyzing
statistics generated by market activity, such as past prices and volume. When
analyzing securities using technical analyses, CPP does not attempt to measure
the securities’ intrinsic value, but instead uses charts and other tools to
identify patterns that can suggest future activity.
B. Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. The
amount of risk assumed varies from investor to investor and is one of the client-
specific factors evaluated by CPP in determining suitable portfolios for their clients.
The following is a list of some of the risks that an clients may be exposed to:
▪
▪
▪
▪
▪
▪
Systematic (Market) Risk- These are risks that affect the entire market and
cannot be avoided through diversification. This risk may be caused by
events such as changing interest rates, a recession, or wars.
Unsystematic Risk -These are risks specific to a company or industry sector
and may be avoided or mitigated by diversification.
Credit Risk - The risk that a company or municipality will not be able to
repay its lenders. This is very important to those investing in fixed- income
investments such as bonds.
Country Risk - This is risk associated with investing in foreign securities.
This risk includes political, exchange rate, economic, sovereign and transfer
risk (which is the risk of capital being locked up or frozen by government
action.)
Liquidity Risk -The risk that a given security or asset cannot be traded quickly
enough in the market to prevent a loss.
Interest Rate Risk - The risk of changing interest rates and their impact on
interest-bearing assets, such as bonds. In general, as interest rates
increase, the price of a fixed-rate bond will decrease, and vice versa.
9. DISCIPLINARY INFORMATION
Neither CPP nor it management has been involved in any legal or disciplinary actions
or administrative proceedings that would be material to a client’s evaluation of CPP
or its management.
9
Form ADV
Part 2A: The Brochure
10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATES
CPP nor any of its management persons are registered, or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer. CPP nor any
of its management persons are registered, or have an application pending to register, as
a futures commission merchant, commodity pool operator, a commodity trading advisor,
or an associated person of the foregoing entities. CPP does not recommend or select other
investment advisers for its clients, receive compensation directly or indirectly from other
advisers, or have business relationships with other advisers that create a material conflict
of interest. Kevin J. Mullins, JD, CPA, one of the firm’s Managing Directors, owns and
operates an independent legal and accounting firm of the same name (hereinafter “KJM”).
Kevin regularly recommends the investment advisory services of CPP to KJM clients and,
alternatively, recommends the legal and accounting services of KJM to CPP clients. Kevin
is incentivized to recommend the services of both firms to clients to increase overall fees.
CPP is not responsible for the legal and accounting or other consulting work product and
results of KJM nor does CPP supervise or monitor the services or personnel of KJM or the
satisfaction of KJM clients (including CPP clients who may engage KJM). CPP does not
provide legal or accounting services. Fees charged by KJM are separate and exclusive of
advisory fees charged by CPP for investment management services provided by Kevin to
CPP clients. Kevin’s work for KJM may create a conflict for CPP clients as Kevin dedicates
some of his time to KJM business and clients instead of those of CPP. To mitigate this
conflict, Kevin ensures that CPP clients’ best interests are served and that he continuously
devotes appropriate time and attention to their portfolios. Kevin’s work for KJM may also
lead to increased risks for CPP related to confidentiality and data security which CPP
mitigates by enforcing appropriate compliance policies and procedures designed to
prevent the violation of applicable laws and a Code of Ethics the objective of which is
protecting the best interests of clients.
11. CODE OF ETHICS
A. Code of Ethics Disclosure
CPP has adopted a Code of Ethics (the “Code”). The Code sets forth a standard of
business conduct and fiduciary duty for CPP and all persons associated with CPP.
The purpose of the code is to set out accepted firm practices for integrity, objectivity,
competence, fairness, confidentiality, professionalism and diligence. In particular, the
Code is designed to:
▪
▪
Protect clients;
Guard against violations of the securities laws;
10
Form ADV
Part 2A: The Brochure
▪
▪
▪
▪
Require all Access Persons to report, and CPP to review, Access Persons’ personal
securities transactions and holdings as required;
Require Supervised Persons to report any violations of the Code to CPP’s CCO;
Protect CPP's reputation.
Ensure that CPP personnel always conduct themselves ethically.
In an effort to meet the above obligations, the Code and other compliance policies and
procedures of the firm set out expected conduct in the following areas:
I
outside business activities
▪
▪
▪
▪
▪
▪
▪
▪
▪
Compliance
Privacy and Confidentiality
Personal securities transactions and reporting
Insider trading
Conflicts of interest
Gifts and Entertainment
Reporting violations and sanctions
Recordkeeping
Material Non-Public Information
CPP provides a copy of its Code and any amendments to its Supervised Persons and, in
return, requires that they provide CPP with a written acknowledgment of their receipt
of the Code and any amendments.
Clients and prospective clients may obtain a complete copy of the Code upon request
by contacting CPP in writing at 55 Pondfield Road Bronxville, NY, 10708 or calling
them at (914) 337-2272.
B. Privacy Statement
CPP protects the material non-public information of its clients. Employees are
expected to exercise diligence and care in maintaining and protecting clients non-
public confidential information. CPP holds all personal information provided to the
firm in the strictest confidence. The records maintained by CPP include all personal
information collected from clients in connection with any of the services provided by
CPP. CPP does not disclose information to non- affiliated third parties, except as
permitted by law, and does not anticipate doing so in the future. If CPP were to
anticipate such a change in the firm's privacy policy, it would do so with client
consent and in accordance with the law. CPP uses health and financial information the
client provides in order to help meet clients’ personal financial goals and has
established the following procedures to mitigate any real or perceived infringements
of clients’ rights of privacy:
▪
CPP limits employee and agent access of information to only:
1.
2.
11
Those who have a business or professional reason for
knowing (i.e. broker/dealer or custodian);
Non-affiliated parties as permitted by law (i.e. federal
regulations permit CPP to share a limited amount of
information about the client with a brokerage firm in
order
Form ADV
Part 2A: The Brochure
3.
to execute securities transactions on their behalf, or so that
the Firm can discuss the client's financial situation with
their accountant or attorney.); or
Those required by judicial or regulatory process.
▪
▪
▪
▪
▪
▪
CPP maintains a secure office and computer environment to ensure that
client information is not placed at unreasonable risk.
The categories of non-public personal information collected from clients
depend upon the scope of the client’s engagement. It will include
information about their personal finances, information about their health
to the extent that it is needed for the planning process, information about
transactions between the client and third parties, and information from
consumer reporting agencies.
For unaffiliated third parties that require access to clients’ personal
information, including financial services companies, service providers, and
auditors, CPP also requires strict confidentiality in its agreements with
them and expects them to keep this information private. Federal and state
regulators may also review firm records as permitted by law.
Personal information contained in any form or document the client
completes in order for CPP to facilitate the commencement, continuation or
termination of a business relationship between the client and a non-
third-party service provider, such as a broker/dealer,
affiliated
investment adviser, or account custodian, shall be deemed as having been
automatically authorized by the client with respect to the corresponding
non-affiliated third party service provider.
CPP does not provide personally identifiable information to mailing list
vendors or solicitors for any purpose.
Personally identifiable information about a client will be maintained
during the time that they are a client and for the required time thereafter
that such records are required to be maintained by federal and state
securities laws and regulations, and, as applicable, consistent with the CFP
Board Code of Ethics and Professional Responsibility.
CPP’s Privacy Notice is initially given to all clients upon signing an Investment
Advisor Agreement and, as applicable, CPP’s Financial Planning Agreement and is
sent to all clients annually thereafter.
C. Personal Securities Trading Practices
CPP and/or employees may sell or hold a position in securities which may also be
recommended to clients. As a fiduciary, CPP and its Access Persons owe its clients the
loyalty to refrain from effecting personal securities transactions that might conflict with
clients’ best interests. Conflicts arise when CPP Access Persons take advantage of
investment opportunities that should have been exercised for clients or when they
use their knowledge of pending client transactions to place their trades before clients’
transactions.
12
Form ADV
Part 2A: The Brochure
CPP has established the following guidelines to mitigate potential conflicts of interest
when placing personal security transactions. CPP's Access Persons may effect personal
securities transactions in the same holdings as clients only after client transactions for
the same security, unless the Access Persons’ transactions are part of a block trade
for the given security. Access
Person trade orders are aggregated with those of clients to increase trade efficiency only
when doing so is in the best interest of clients. There are no restrictions on Access
Persons for placing trades in open-end mutual funds on the same day as clients.
12. BROKERAGE PRACTICES
A. Recommending Broker/Dealers to Client
Currently, CPP recommends Schwab to clients as custodian and broker/dealer, though
clients may choose to arrange custody and trade execution through other service
providers. If a client chooses to use another broker/dealer, then CPP will not have
trading authority over the client’s account. In such cases, it is the client's responsibility
to the effect of trading implement investment recommendations. CPP is independently
owned and operated and is not affiliated with or a related person of Schwab.
CPP considers a number of factors prior to selecting or recommending broker/dealers,
including but not limited to, their familiarity with the securities to be sold or purchased,
their execution skills, order-flow capabilities, their commission rates or other fee
schedules, their custodial services, their level of net capital (financial strength) and
excess SIPC. CPP routinely compares order execution disclosure information of Schwab
to other broker/ dealers to ensure that Schwab remains competitive in providing best
execution for their clients. Clients are advised, however, that they may be able to effect
transactions in securities through other securities broker/dealers at lower commission
rates, particularly with respect to securities listed on a national securities exchange or
in the over-the-counter market While Schwab may sometimes charge commissions
higher than those obtainable from other broker/dealers, CPP will only cause its clients
to pay brokerage commissions which it has determined, in good faith, to be reasonable
in relation to value of the brokerage and other services provided by such securities
broker/dealers. CPP will base its decision upon the transactions involved and its overall
responsibilities with respect to clients’ investment management accounts.
B. Security Transactions
Securities transactions are generally executed through Schwab. However, CPP may
utilize other broker/dealers and custodians when requested by the client or when the
client's retirement plan sponsor selects the custodian. CPP's clients must be aware that
if they direct CPP to use a particular broker, it may limit CPP in their ability to
13
Form ADV
Part 2A: The Brochure
achieve best execution or negotiate commissions with other broker/dealers on behalf
of the client or limit the client's ability to participate in block trading. Aggregating orders
on behalf of clients may allow clients into funds with lower expense ratios as on an
individual level they do not meet the fund minimum. Aggregating securities purchases
may allow for the opportunity to purchase securities with better pricing due to the size
and having access to a larger market. The block purchases are then allocated to the
clients account based on client specific investment criteria at no additional cost to the
client.
C. Research and Other Soft Dollar Benefits
CPP does not receive research or other products or services other than execution from
Schwab or other broker/dealers in connection with client securities transactions (“soft
dollar benefits”), but does receive products and services from Schwab that benefit CPP a
n d may not necessarily benefit client accounts or all client accounts. Some of these other
products and services assist CPP in managing and administering client accounts. These
include software and other technology that provide access to client account data (such as
trade confirmations and account statements), facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts), facilitate payment of CPP's fees from
it client's accounts, and assist with back office functions, record keeping and client
reporting. These services may be used to service all or a substantial number of client
accounts, including accounts not maintained at Schwab and include:
▪
▪
▪
▪
▪
▪
Financial planning software;
Client reporting and consolidated statement software;
Client communication software;
Client relationship management software;
Coaching; and
Investment research
Currently, CPP has not purchased any discount pricing program through Schwab.
Clients should be aware that research reports obtained through Schwab and, in fact, all
other sources, is used to service all of CPP’s clients, regardless of whether they pay only
for financial planning advice to CPP, which may be by the hour, or commissions to Schwab
on transactions in securities effected by CPP in its capacity as the client’s investments.
CPP recommendations to clients to maintain their accounts with Schwab may be based
in part on the benefits to CPP described above, such as the availability of some of the
foregoing products and services and not solely on the nature, cost, or quality of custody
and brokerage services provided by Schwab, which may create a conflict of interest.
D. Brokerage for Client Referrals
14
It is the practice of some broker/dealers to give client referrals to investment advisors
as an Incentive for directing business through them. CPP does not receive client
referrals from Schwab or any broker/dealers.
Form ADV
Part 2A: The Brochure
E. Directed Brokerage
CPP may utilize broker/dealers and custodians other than Schwab when requested by
a client or when a client’s retirement plan custodian is selected by the Plan’s sponsor.
CPP's clients must be aware that if they direct CPP to use a particular broker/dealer
that it may limit CPP’ s ability to achieve best execution, negotiate commissions on
behalf of the client and aggregate trade orders. As a result, clients may pay higher
commissions, have higher transaction costs, and receive less favorable prices.
F. Best Execution
As stated earlier, CPP routinely compares order execution disclosure information of
Schwab to other broker dealers to ensure that Schwab remains competitive in
providing best execution for their clients’ securities transactions. The commissions
and/or transaction fees charged by Schwab may be higher or lower than those
charged by other broker/dealers. The commissions paid by CPP’s clients with CPP’s
duty to obtain "best execution." However, a client may pay a commission that is
higher than another qualified broker/dealer might charge to effect the same
transactions where CPP determines, in good faith, that the commission is reasonable
in relation to the value of the brokerage services received. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of
broker/dealer services, including among others, the value of research provided,
execution capability, commission rates, and responsiveness. Consistent with the
foregoing, while CPP will seek competitive rates; they may not necessarily obtain the
lowest possible commission rates for their client’s transactions.
G. Brokerage and Custodian Transaction Fees
CPP generally recommends Schwab to its clients for custody and trading of their
accounts. Advisory fees charged by CPP are separate and distinct from other fees the
client may be charged by Schwab and/or other third parties to service the accounts including
but not limited to:
▪
▪
▪
▪
▪
▪
▪
Transaction fees such as ticket charges charged by the broker/dealer or custodian.
Mutual fund exchange fees
Commissions, if applicable
Inactivity fees
Custodial fees for overnight mail, wire orders, checks returned for insufficient
funds for those clients with check writing privileges.
Custodial maintenance and termination fees for IRA's
H. Trade error Policy and Procedures :
Other service fees under special circumstances.
15
CPP has established the following procedures in the event that a trading error occurs
Form ADV
Part 2A: The Brochure
during the execution of a security, other than a mutual fund transaction:
1)
Upon discovery of the trade error, CPP will immediately notify the Chief
Compliance Officer (CCO) who will, in turn, notify the broker/dealer or
custodian's trading department with details concerning the error. The
broker/dealer or custodian will counteract or “flatten” the
incorrect
transaction with a covering transaction, regardless of whose fault it is. This
immediate action will be taken to limit the potential effects that capital market
fluctuations may have upon further price deterioration or appreciation.
2)
The CCO will give the broker/dealer or custodian the correct transaction that
should have been executed.
3)
The broker/dealer or custodian will confirm the correct price that the
client should have received had the order been processed correctly.
4)
A trade error report containing the following information must be completed:
▪
▪
▪
▪
▪
▪
Account registration and number;
The trade and settlement dates;
The number of shares or dollar value of the trade;
An explanation of the error;
The resolution of the error; and
If the client lost money due to the error, include any information to
evidence that the client was made whole and not harmed in any way.
5)
Any restitution to the client's account must be made through the
broker/dealer or custodian.
6)
The CCO or a designated alternate will review the trade error report to
ensure that all documents regarding the trade error have been attached to
the report before filing the document in the trade error file.
CPP has established the following procedures in the event that a trading error occurs
during the execution of a mutual fund transaction:
1)
Upon discovery and reporting of the trade error to the CPP COO, the CCO
will notify the broker/dealer or custodian's trading department with
details concerning the error.
2)
The broker/dealer or custodian will reverse the errors and reenter the
correct transaction order in such a manner as to ensure that the client’s
correct trade is processed without detriment to the client. If required, the
broker/dealer’s Compliance Department will provide the custodial or
mutual fund company with a Letter of Indemnity.
3)
A trade error report containing the following information must be
completed:
16
Form ADV
Part 2A: The Brochure
•
•
•
•
•
•
Account registration and number;
The trade and settlement dates;
The number of shares or dollar value of the trade;
An explanation of the error;
The resolution of the error; and
If the client lost money due to the error, include any
information to evidence that the client was made whole and not
harmed in any way.
4)
Any restitution to the client’s account must be made through the
broker/dealer.
The CCO or a designated alternate will review all trade error reports to ensure that
all documents regarding the trade error have been attached to the report before filing
the document in the trade error file.
13. REVIEW OF ACCOUNTS
All accounts are under regular review by CPP's Chief Compliance Officer and the
respective financial advisers. Client portfolio reviews occur at least quarterly by the
financial advisors to assess the asset classes, economic and market conditions, and any
extreme gains/losses in the portfolios, all of which are conditions that may trigger
portfolio adjustments.
All investment advisory and financial planning clients are advised that it remains their
responsibility to advise CPP of any changes in their investment objectives and/or
financial situation. All clients (in person or via telephone) are encouraged to
comprehensively review financial planning issues, investment objectives and account
performance with CPP at a minimum on an annual basis, or as applicable.
At a minimum, clients are provided with transaction confirmation notices and regular
summary account statements directly from the broker/dealers used to trade in the
respective accounts, and/or the custodian for their accounts quarterly, but may
receive more frequent notices depending on the trading activity in the account.
Any client that does not receive an account statement from the custodian should
call CPP immediately so that CPP can help correct the problem.
14. CLIENT REFERRALS AND
OTHER COMPENSATION
17
CPP relies on client referrals and advertising to introduce new clients to their business. It
is CPP's policy not to compensate clients for referring potential clients to their
Form ADV
Part 2A: The Brochure
business, because the client would be considered a solicitor and would have to satisfy
requirements under Rule 206(4)-1 of the Investment Advisers Act of 1940 before a
cash referral fee could be paid to them.
15. CUSTODY
Due to increased regulatory concerns over advisors with what the SEC construes as
‘custody by a Registered Investment Adviser’, it is CPP's intention not to have custody
over client assets as a regular course of business. CPP will, only to the extent that it
procures a client's prior consent deduct advisory fees directly from the client’s
account(s) but shall have no other access to client funds or securities through the
clients’ custodians. CPP calculates advisory fees on a quarterly basis (see definition
above), which are payable in advance.
CPP has established the following procedures that are designed to help ensure that CPP
does not obtain custody of client assets, other than for the deduction of advisory
fees: A. Account Custodian
All clients are required to open an account with a qualified custodian where the clients’
assets will be held. CPP's personnel will assist clients in preparing paperwork to open
new custodial accounts but only the clients are permitted to actually authorize, by their
signature, the opening of the account and the direction and management of the account
thereafter.
Once the account is established, it is the custodian's responsibility to send clients
account statements, transaction confirmations, proxy material, and any other
information relating to their account. CPP will not route original custodial
statements to its clients on behalf of a custodian. However, CPP is responsible, within
reason, to ensure that clients receive custodial statements directly from the custodian
on, at a minimum, a quarterly basis. To meet this responsibility, CPP will request
duplicate copies of its clients’ statements. Any client that does not receive an account
statement from the custodian should call the custodian directly and CPP immediately
so that the problem can be corrected.
B. Handling Client Assets
Due to custody regulations, CPP's personnel can only handle or forward checks clearly
made payable to a third party, such as the client's independent custodian. CPP may not
handle or forward any other client check or security certificate received by the firm. All
such instruments must be returned to the client within three (3) business days, and
may not be forwarded to any party other than the client or a client's representative.
Clients must be aware that if they personally deliver securities certificates to CPP's
18
Form ADV
Part 2A: The Brochure
Office, CPP and/or office personnel is not allowed to physically handle the securities
certificates. CPP may provide direction to clients in completing the transfer and
shipping of paperwork to help ensure that the securities certificates are properly
deposited with the client’s custodians. However, it is the clients’ responsibility to
deposit overnight pouches with the respective couriers for forwarding of securities
certificates to their designated custodians. Securities certificates inadvertently
received in the mail will be returned to clients within three business days.
C. Other Custody Related Issues
▪
CPP has invoked the following restrictions to ensure that custody is not inadvertently
obtained:
▪
▪
▪
▪
Supervised Persons are prohibited from obtaining, maintaining or utilizing
client- assigned log-ons and passwords to access and/or service any client self-
directed accounts.
Supervised Persons will not accept signatory power over any client's checking
or custodial account(s).
CPP will not hold client securities in CPP's name or in bearer form.
Proceeds from sales or redemption of client securities will not be directed to the
custody of CPP.
Advisors will not require clients to prepay fees six months or more in advance.
16. INVESTMENT DISCRETION
For discretionary accounts, CPP is granted complete discretionary authority in writing
by the client when the client signs CPP's
Investment Advisory Agreement. This
discretionary authorization gives CPP the authority to buy, sell, hold, exchange, invest,
and otherwise deal with the client’s investment assets at CPP’s sole discretion and
without consulting with the client in advance. This authorization is perpetual and will
remain in full force and effect until the agreement is terminated. CPP does not have
discretionary authority on the amount of commissions that are charged by the
broker/dealer or custodian.
17. VOTING CLIENT SECURITIES
CPP will not take any action on behalf of clients, and is not obligated to render any
advice to clients, with respect to:
▪
▪
The voting of proxies solicited by, or with respect to, the issuers of any securities
held in the clients’ portfolios or,
The legal proceedings involving securities or other investments presently or
formerly held in the clients’ portfolios, or the issuers thereof, including
bankruptcies.
19
Form ADV
Part 2A: The Brochure
The clients’ custodians are expected to send all such proxy and legal proceedings
information and documents it receives to the clients so that the clients may take
whatever action they deem appropriate.
18. FINANCIAL INFORMATION
As previously discussed in this brochure, CPP provides financial planning and
investment management services on a discretionary basis for which clients are billed
quarterly in advance. Clients are not required to prepay planning or management fees
to CPP or its Supervised Persons more than three months in advance, and if clients
terminate their financial planning or investment advisory agreements prior to the end
of a Quarter, as defined herein, the clients are reimbursed any unearned fees.
CPP has never been petitioned or been subject to bankruptcy proceedings, and there
are no financial conditions that would prevent CPP from meeting any contractual
commitment to its clients.
20
Additional Brochure: WEBSITE (2026-03-30)
View Document Text
Home
About Us
Services
Resources
Client Access
Contact Us
You have goals. We help you achieve them.
Serving our clients since 1992.
Click here
Want to learn more about our services?
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
About Us
Who We Are
Capital Preservation Partners, Inc is a financial planning firm that guides investors through ever-changing markets and retirement planning strategies. Capital Preservation creates
custom portfolios structured towards meeting individual goals and needs. CPP evaluates investments and fund managers to implement conservative growth with downside protection
strategies.
Capital Preservation was founded in 1992 by Kevin Mullins and Michael S. Hymes, driven by the desire to provide their tax clients with comprehensive and fee-only investment advice.
Over three decades later CPP remains an independent financial planning firm that believes trust, integrity, responsibility, and stewardship never go out of style. Our history of delivering
exceptional results while nurturing long-standing client relationships is a testament to these values in action.
We invite you to get to know us and learn how we may be of service to you and yours.
Heritage
Quality
We strive to provide personalized client service and are uncompromising in our
efforts to deliver superior results to clients.
Since our founding in 1992, CPP has remained independent and provides
unbiased advisory services. Our Investment Advisory Firm is built on trust,
integrity, and professional experience.
Expertise
Consistency
CPP as assembled a professional network with diverse specialized knowledge.
Accounting, legal and insurance specialists can assist in developing customized
solutions.
We implement thorough investment process to minimize volatility and improve
consistency of returns. We seek repeatable and predictable results to most
effectively grow wealth.
Meet the Team
Ilir Leo Gjoni, CFP®
Kevin Mullins CPA,
Madeline Noveck,
J.D., CFP®
CFP®
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Services
Financial Planning
Financial well-being is a continuous process and
conversation aimed at achieving both short-term
and long-term goals. It involves comprehending
one's current and future income, family
requirements, medical circumstances, and
providing support in evaluating or creating estate
documents, as well as examining gifting
possibilities.
How Our Clients Benefit
Achieving financial goals becomes easier with a
clear and concise plan. You work hard to achieve
financial goals, but without the proper plan it can
be lost. There is much more to it than just putting
money into retirement accounts. Our partnership
will enable you to stay on course, concentrate on
your career, alleviate the burden of daily living,
and support you in accomplishing your objectives.
Wealth Management
Capital Preservation Partners, Inc is an
independent, fee-based Wealth Advisor to
individuals, families, small businesses, and other
types of institutions. While many of our clients
share the need for receiving informed advice and
targeted investment solutions, no two clients are
the same. That is why we take the time required to
listen and understand the current situation, future
aspirations, and possible constraints. In keeping
with our culture, we strive to provide value-added
client service and investment outcomes as a
fiduciary for our clients.
Families
Corporations
Nonprofits
We work with business owners and executives to
set investment guidelines, manage 401k plans and
create customized pension plans to maximize
retirement savings.
We work with individuals and their families to
achieve lifetime financial goals. From educational
and retirement aspirations to multigenerational
needs of single family offices, we are committed to
providing the best service and solutions over
lifetimes.
We serve a wide variety of local nonprofit entities
including foundations, endowments, media and
community organizations, providing them with
advisory services and best-in-class mission-
aligned, equity, fixed income and balanced
strategies.
Our Mission is Your Success
We aim to continually provide you with comprehensive financial advice and be the
consultants for all your wealth management decisions. Our highly educated and client-
focused advisors will help you every step of the way, from defining your goals, to developing
your plan towards success
Our Clients are Our Culture
Whether your goals include retirement planning, leaving a legacy behind for your family, or
reducing taxes, we’ve got you covered. We are committed to helping you achieve the unique
goals that are most important to you.
How We're Different
Invest with a Trusted Partner, as fiduciaries your interest are paramount. No sales quotas to
fill or commissionable products sold. Our success is based on your success.
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Blog
Ilir Leo Gjoni | Mar 26, 2026
A More Flexible Way to Think About
Retirement
Retirement Finance Lifestyle Risk Management
Many retirement plans are built on a quiet assumption: that spending stays roughly
the same from year one to year thirty.
It sounds reasonable. But research
Read More
Capital Preservation Partners | Jul 17, 2023
Financial FAQs
Finance Retirement
From retirement savings to living abroad, here are some of our commonly asked
questions.
Read More
Capital Preservation Partners | Jul 17, 2023
Seven Key Tips for Planning Elder Care
Family Lifestyle Retirement Health Disability
Noticing signs of decline in our loved ones is always hard, and making care decisions
for them often feels even harder. While it's impossible to make the
Read More
Capital Preservation Partners | Jul 17, 2023
5 Amazing Places to Retire Outside of the
U.S.
Lifestyle Finance Retirement Real Estate Tax Planning
Would you enjoy your retirement more in the U.S. or abroad?
Read More
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Calculators
Link Disclosure: The information being provided is strictly as a courtesy. When you click on any of the links provided here, you are leaving this website and viewing information provided by a third party. We make no representation as to the completeness or accuracy of
information provided by any third-party website. Nor is the company liable for any direct or indirect technical or system issues or any consequences arising out of your access to or your use of third-party technologies, websites, information, and programs made available
through this website. By accessing these calculators, you assume total responsibility and risk for your use of the third-party website.
Information and interactive calculators are made available to you as self-help tools for your independent use and are not intended to provide investment, tax, or legal advice. We cannot and do not guarantee their applicability or accuracy in regard to your individual
circumstances. All examples are hypothetical and are for illustrative purposes. We encourage you to seek personalized advice from qualified professionals regarding all personal finance issues.
Retirement
Social security retirement income estimator
How does inflation impact my retirement income needs?
Convert discretionary expenses to savings
Savings
Becoming a millionaire
How long will it take to double my money?
How long until my savings reach my goal?
Save now vs. save later
How much should I save to reach my goal?
What will my current savings grow to?
Calculate rate of return
How do taxes and inflation impact my return?
Insurance
What is my life expectancy?
What are the chances of becoming disabled?
How much will I earn in my lifetime?
What are the tax advantages of an annuity?
How long will my current life insurance proceeds last?
Taxation
Federal income tax calculator
How much self-employment tax will I pay?
What is my tax-equivalent yield?
Tax refund estimator
Tax freedom day
Home & Mortgage
Comprehensive mortgage calculator
Should I convert to a bi-weekly payment schedule?
What are the tax savings generated by my mortgage?
Compare an interest-only versus traditional mortgage
College
Will I be able to pay back my student loans?
Advantages of the Coverdell ESA.
Advantages of a 529 College Savings Plan
What is the value of a college education?
What are the payments on a parental (PLUS) loan?
Cash Flow
Should I pay down debt or invest more?
How long will my money last?
Historical inflation - Compare purchasing power
Credit
How long will it take to pay off my credit card(s)?
How long until my loan is paid off?
What would my loan payments be?
What is the balance owing on my loan?
Which is better, cash up front or payments over time?
What is the impact of making extra debt payments?
Should I pay off debts or invest the money?
Paycheck & Benefits
Convert my salary to an equivalent hourly wage.
Convert my hourly wage to an equivalent salary.
Auto
Auto purchase - Loan vs. 0% dealer financing?
What would my auto payments be?
Auto loan - Accelerated payoff
FINRA Calculators
Smart Bond Investing Accrued Interest Calculator
Retirement Calculator
College Savings Calculator
Savings Calculator
401(k) and IRA Minimum Required Distribution Calculator
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Useful Links
Internal Revenue Service
Taxes
Social Security Administration
Government Agencies
News
The Wall Street Journal
New York Times
Link Disclosure: The information being provided is strictly as a courtesy. When you link to any of the websites provided here, you are leaving this website. We make no representation as to the completeness or accuracy of information provided at these websites. Nor is the
company liable for any direct or indirect technical or system issues or any consequences arising out of your access to or your use of third-party technologies, websites, information and programs made available through this website. When you access one of these websites,
you are leaving our website and assume total responsibility and risk for your use of the websites you are linking to.
Information is made available to you as a self-help tool for your independent use and is not intended to provide investment, tax, or legal advice. We cannot and do not guarantee their applicability or accuracy in regard to your individual circumstances. All examples are
hypothetical and are for illustrative purposes. We encourage you to seek personalized advice from qualified professionals regarding all personal finance issues.
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Contact Us
Capital Preservation Partners, Inc.
Contact Us
First Name
55 Pondfield Road
Bronxville, NY 10708
(914) 337-2272
Last Name
Phone
Email Address
Message
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.
Home
About Us
Services
Resources
Client Access
Contact Us
Privacy Policy
CAPITAL PRESERVATION PARTNERS, INC., an independent Investment Advisory Firm, considers client privacy to be a fundamental aspect of our client relationships. We are committed to
maintaining the confidentiality, integrity, and security of our current, prospective and former clients’ personal information.
In the course of providing you with advisory services, we may collect, retain, and use client information for the purpose of administering our operations, providing client service, and
complying with legal and regulatory requirements. This information may come from sources such as account applications, investment policy statements, from your transactions, and other
forms from other written, electronic or verbal correspondence from your brokerage, attorney, accountant or other advisor you may employ. We do not sell, exchange or disclose client
information with outside organizations unless the third party is essential in administering our operations or except as required or permitted by law.
No confidential information, whatever the source, regarding any customer or client, may be disclosed except the following: We reserve the right to disclose or report personal information
where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities. Adviser reserves the right to disclose information with
other Adviser employees in connection with the Adviser’s business and to non-affiliated third parties with whom the Adviser has a contractual agreement to jointly offer, endorse or sponsor
a financial product or service; and to service and maintain customer accounts including effectuating a transaction. Adviser may disclose information about client or client’s account to a non-
affiliated third party at client’s written request.
Finally, to further safeguard client information digitally, we maintain password protected systems, updated anti-virus and anti-spyware software, and encrypted hardware and software
firewalls.
| Form ADV | Form CRS | Disclosure | Privacy Policy | BrokerCheck
© 2026 Capital Preservation Partners. All rights reserved.