Overview
- Headquarters
- Austin, TX
- Average Client Assets
- $2.0 million
- Minimum Account Size
- $500,000
- SEC CRD Number
- 300349
Fee Structure
Primary Fee Schedule (ADV PART 2A-CAPSTAR FINANCIAL SERVICES LIMITED LIABILITY CORPORATION)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 2.00% |
| $250,001 | and above | 1.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $18,125 | 1.81% |
| $5 million | $88,125 | 1.76% |
| $10 million | $175,625 | 1.76% |
| $50 million | $875,625 | 1.75% |
| $100 million | $1,750,625 | 1.75% |
Clients
- HNW Share of Firm Assets
- 45.78%
- Total Client Accounts
- 826
- Discretionary Accounts
- 818
- Non-Discretionary Accounts
- 8
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection, Educational Seminars
Regulatory Filings
Primary Brochure: ADV PART 2A-CAPSTAR FINANCIAL SERVICES LIMITED LIABILITY CORPORATION (2026-03-20)
View Document Text
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Capstar Financial Services
LLC. If you have any questions about the contents of this brochure, please contact us at (512) 215-9030 or by email
at: barbara@capstarfinancial.com. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Additional information about Capstar Financial Services LLC is also available on the SEC's website
at www.adviserinfo.sec.gov. Capstar Financial Services LLC's CRD number is: 300349.
6500 River Place Blvd Ste 200 Building 1
Austin, TX 78730
(512) 215-9030
barbara@capstarfinancial.com
capstarfinancial.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 3/20/2026
i
Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of Capstar Financial
Services LLC on 03/04/2025 are described below. Material changes relate to Capstar Financial Services
LLC's policies, practices, or conflicts of interests.
• There are no material changes to report.
ii
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ............................................................................................................................................................................................................................ ii
Item 3: Table of Contents .......................................................................................................................................................................................................................... iii
Item 4: Advisory Business ........................................................................................................................................................................................................................ 2
Item 5: Fees and Compensation ................................................................................................................................................................................................................ 4
Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................................................................................ 7
Item 7: Types of Clients ............................................................................................................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ........................................................................................................................................... 7
Item 9: Disciplinary Information ............................................................................................................................................................................................................10
Item 10: Other Financial Industry Activities and Affiliations .................................................................................................................................................... 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................................... 12
Item 12: Brokerage Practices ................................................................................................................................................................................................................... 13
Item 13: Review of Accounts ................................................................................................................................................................................................................. 14
Item 14: Client Referrals and Other Compensation ......................................................................................................................................................................... 15
Item 15: Custody .......................................................................................................................................................................................................................................... 15
Item 16: Investment Discretion ............................................................................................................................................................................................................... 15
Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................................................................................. 15
Item 18: Financial Information................................................................................................................................................................................................................ 16
Item 19: Requirements For State Registered Advisers .................................................................................................................................................................. 16
Item 4: Advisory Business
A. Description of the Advisory Firm
Capstar Financial Services LLC (hereinafter “Capstar Financial”) is a corporation organized
in the State of Texas. The firm was formed in September 2009, and the principal owner is
Suzette Marie Porter. The firm is registered as an RIA with the SEC.
B. Types of Advisory Services
Portfolio Management Services
Capstar Financial offers ongoing portfolio management services based on the individual
goals, objectives, time horizon, and risk tolerance of each client. Capstar Financial creates
an analysis for each client, which outlines the client's current situation (income, tax levels,
expenses, assets). Each client must complete a risk tolerance questionnaire. Once all the
information is gathered Capstar Financial will construct a plan to aid in the selection of a
portfolio that matches each client's specific situation. Capstar may select certain Third-
Party Money Managers to actively manage a portion of its clients’ assets. The specific terms
and conditions under which a client engages a Third-Party Money Manager may be set
forth in a separate written agreement with the designated Third-Party Money Manager. In
addition to this brochure, clients may also receive the written disclosure documents of the
respective Third-Party Money Managers engaged to manage their assets. Portfolio
management services include, but not limited to, the following:
•
•
•
Investment strategy
Asset allocation
Risk tolerance
•
•
•
Personal investment policy
Asset selection
Regular portfolio monitoring
Capstar Financial evaluates the current investments of each client with the respect to their
risk tolerance levels and time horizon. Capstar Financial and Third-Party Money Managers
will request discretionary authority from the clients to select and execute transactions
without permission from the client prior to each transaction. Risk tolerance levels are
documented in the Investment Policy Statement.
Capstar Financial seeks to provide that investment decisions are made in accordance with
the fiduciary duties owed to its accounts and without consideration of Capstar Financials'
economic, investment or other financial interests. To meet its fiduciary obligations, Capstar
Financial attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios.
2
Financial Planning
Financial plans and financial planning may include but are not limited to investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Educational Seminars/Workshops
Capstar Financial provides periodic educational seminars and workshops to current
clients and prospective clients.
Selection of Third-Party Money Managers
Our firm evaluates a variety of information about Third-Party Money Managers, which
includes the Third-Party Money Managers’ public disclosure documents, materials
supplied by the Third-Party Money Managers themselves, and other third-party analyses
it believes are reputable. To the extent possible, the firm seeks to assess the Third-Party
Money Managers’ investment strategies, past performance, and risk results in relation to
its clients’ individual portfolio allocations and risk exposure. Our firm also takes into
consideration each Third-Party Money Manager’s management style, returns, reputation,
financial strength, reporting, pricing, and research capabilities, among other factors.
Our firm continues to provide services relative to the discretionary or non-discretionary
selection of the Third-Party Money Managers. On an ongoing basis, the firm monitors the
performance of those accounts being managed by Third-Party Money Managers. Our firm
seeks to ensure the Third-Party Money Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests.
Services Limited to Specific Types of Investments
Capstar Financial generally limits its investment advice to common stock, mutual funds,
fixed income securities, real estate funds (including REITs), insurance products including
annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury
inflation protected/ inflation linked bonds, non-U.S. securities and private placements.
Capstar Financial may use other securities as well to help diversify a portfolio when
applicable.
Capstar Financial will tailor a program for each individual client. This will include an
interview session to get to know the client's specific needs and requirements as well as a
plan that will be executed by Capstar Financial on behalf of the client. Capstar Financial can
use model allocations together with a specific set of recommendations for each client based
on their personal restrictions, needs, and targets. Clients may impose restrictions in
investing in certain securities or types of securities in accordance with their values or
beliefs. However, if the restrictions prevent Capstar Financial from properly servicing the
client account, or if the restrictions would require Capstar Financial to deviate from its
standard suite of services, Capstar Financial reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees.
Capstar Financial does not participate in wrap fee programs.
E. Assets Under Management
Capstar Financial has the following assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
$207,196,803
$607,668
December 2025
Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management fees
Total Assets Under Management
Annual Fees
$0.00 - $250,000
Up to 2.00%
$250,000 — and up
Up to 1.75%
This annual fee shall be paid quarterly, in advance, based upon the market value of the
Assets on the last business day of the previous quarter or the annual fee shall be paid
monthly, in arrears, based upon the daily average balance of the previous month. If a client
starts investing in the middle of a billing cycle the fees will be pro-rated.
These fees are generally negotiable, and the final fee schedule will be memorialized in the
client's advisory agreement. If a client has multiple accounts, Capstar Financial will
aggregate the account balances to lower the fees. Clients may terminate the agreement
without penalty for a full refund of Capstar Financials' fees within five business days of
signing the Investment Advisory Contract. Thereafter, clients may terminate the
Investment Advisory Contract immediately upon written notice, and the fees will be pro-
rated.
Financial Planning fees
Fixed Fees
The negotiated fixed rate for creating client financial plans is between $500 and $5,000.
Clients may terminate the agreement without penalty, for full refund of Capstar Financials'
fees, within five business days of signing the Financial Planning Agreement. Thereafter,
clients may terminate the Financial Planning Agreement generally upon written notice.
Educational Seminar/Workshop fees
Capstar Financial will charge no fee for a retirement elevated course.
Selection of Other Advisers Fees
In addition to the advisory fees paid to Capstar, clients also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, trust companies,
banks, and other financial institutions (collectively “Financial Institutions”). These
additional charges include securities brokerage commissions, transaction fees,
custodial fees, margin costs, fees attributable to alternative assets utilized by the Third-
Party Money Managers, reporting charges, fees charged by the Third-Party Money
Managers, charges imposed directly by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund
expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. The Firm’s brokerage practices are described at length
in Item 12, below.
Adviser will provide investment advisory services and portfolio management services
but will not provide custodial or other administrative services. At no time will Adviser
accept or maintain custody of a client’s funds or securities except for authorized fee
deduction. The Client may contact the Custodian directly for disbursements, or account
record changes, and may also do so in writing to the custodian. Adviser may act at the
client’s convenience to facilitate such written communications to the Custodian, provided
that such action is not construed to be custody of client assets.
B. Payment of Fees
Payment of Portfolio Management fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly or monthly basis. Fees are paid in
advance or in arrears; fee schedules may be dependent on the asset manager used and
will be definitively outlined in client agreements.
Payment of Financial Planning fees
Financial planning fees are generally paid via check for non-clients.
Fixed financial planning fees are paid 100% in advance, but never more than six months in
advance.
Payment of Third-Party Money Managers fees
The timing, frequency, and method of paying fees for selection of Third-Party Money
Managers will depend on the specific Third-Party Money Manager selected and will be
disclosed to the client prior to entering a relationship with the Third-Party Money Manager.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage
fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the
fees and expenses charged by Capstar Financial. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of fees
Capstar Financial collects fees in advance. Refunds for fees paid in advance but not yet
earned will be refunded on a prorated basis and returned within fourteen days to the client
via check or return deposit back into the client's account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the
fees collected in advance minus the daily rate* times the number of days elapsed in the
billing period up to and including the day of termination. (*The daily rate is calculated by
dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance
will be refunded based on the prorated amount of work completed at the point of
termination.
E. Outside Compensation for the Sale of Securities to Clients
Neither Capstar Financial nor its supervised persons accept any compensation for the sale
of investment products, including asset-based sales charges or service fees from the sale
of mutual fund securities
Item 6: Performance-Based Fees and Side-By-Side Management
Capstar Financial does not accept performance-based fees or other fees based on a share of
capital gains on or capital appreciation of the assets of a client.
Item 7: Types of Clients
Capstar Financial generally provides advisory services to the following types of clients:
•
•
•
Individuals
High-Net-Worth Individuals
Small Businesses
There is an account minimum of $500,000, which may be waived by Capstar Financial in its
discretion.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
Capstar Financials' methods of analysis include Modern portfolio theory and Technical
analysis.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
Technical analysis involves the analysis of past market data, primarily price and volume.
Investment Strategies
Capstar Financial uses long term trading and short-term trading.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one. Thus,
an investor will take on increased risk only if compensated by higher expected returns.
Conversely, an investor who wants higher expected returns must accept more risk. The
exact trade-off will be the same for all investors, but different investors will evaluate the
trade-off differently based on individual risk aversion characteristics. The implication is
that a rational investor will not invest in a portfolio if a second portfolio exists with a more
favorable risk-expected relurn profile — i.e., if for that level of risk an alternative portfolio
exists which has better expected returns.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Investment Strategies
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Short term trading risks include liquidity, economic stability, and inflation, in addition to
the long-term trading risks listed above. Frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and
taxes.
Solicitor Services/ Capstar Financial of Other Advisers: Although Capstar Financial will
seek to select only money managers who will invest clients' assets with the highest level of
integrity, Capstar Financials' selection process cannot ensure that money managers will
perform as desired and Capstar Financial will have no control over the day-to-day
operations of any of its selected money managers. Capstar Financial would not necessarily
be aware of certain activities at the underlying money manager level, including without
limitation a money manager's engaging in unreported risks, investment “style drift” or
even regulator breach or fraud.
Suzette Porter is a key person of Capstar Financial, and the company heavily relies on her.
To minimize the risk in the event of the loss of Suzette Porter a succession plan is set-up to
be able to continue the business without major interruption.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
A. Risks of Specific Securities Used
Clients should be aware that there is a material risk of loss using any investment strategy.
The investment types listed below (leaving aside Treasury Inflation Protected/Inflation
Linked Bonds) are not guaranteed or insured by the FDIC or any other government
agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of
the payments can vary. This type of investment can include corporate and government debt
securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/ inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver,
or Palladium Bullion backed “electronic shares” not physical metal) specifically may be
negatively impacted by several unique factors, among them (1) large sales by the official
sector which own a significant portion of aggregate world holdings in gold and other
precious metals, (2) a significant increase in hedging activities by producers of gold or
other precious metals, (3) a significant change in the attitude of speculators and investors.
Real estate funds (including REITs) face several kinds of risk that are inherent in the real
estate sector, which historically has experienced significant fluctuations and cycles in
performance. Revenues and cash flows may be adversely affected by: changes in local real
estate market conditions due to changes in national or local economic conditions or
changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt
and equity credit markets; the ongoing need for capital improvements; changes in real
estate tax rates and other operating expenses; adverse changes in governmental rules and
fiscal policies; adverse changes in zoning laws; the impact of present or future
environmental legislation and compliance with environmental laws.
Annuities are a retirement product for those who may have the ability to pay a premium
now and want to guarantee they receive certain monthly payments or a return on
investment in the future. Annuities are contracts issued by a life insurance company
designed to meet retirement or other long-term goals. Insurance and Annuity product
guarantees are subject to the claim-paying ability of the issuing company. Fixed indexed
annuities are not stock market investments. Market indexes do not include dividends paid
on the underlying stocks and do not therefore reflect the total return of the underlying
stocks. Guarantees provided by annuities are subject to the financial strength of the issuing
company and are not guaranteed by a bank or the FDIC. An annuity is not a life insurance
policy.
Private placements carry a substantial risk as they are subject to less regulation than are
publicly offered securities, the market to resell these assets under applicable securities
laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial
discount to the underlying value or result in the entire loss of the value of such assets.
Alternative Investments Risks. The performance of alternative investments (e.g.,
commodities, futures, hedge funds; funds of hedge funds, private equity or other types of
limited partnerships) can be volatile. Alternative investments generally involve various
risk factors and liquidity constraints, a complete discussion of which is set forth in the
offering documents of each specific alternative investment. Due to the speculative nature
of alternative investments a client must satisfy certain income or net worth standards prior
to investing.
Non-U.S. securities present certain risks such as currency fluctuation, political and
economic change, social unrest, changes in government regulation, differences in
accounting and the lesser degree of accurate public information available.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither Capstar Financial nor its representatives are registered as, or have pending
applications to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither Capstar Financial nor its representatives are registered as or have pending
applications to become either a Futures Commission Merchant, Commodity Pool Operator,
or Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Firm policies require associated persons to conduct business activities in a manner that
avoids conflicts of interest between the firm and its clients, or that may be contrary to law.
We will provide disclosure to each client prior to and throughout the term of an
engagement regarding any conflicts of interest involving its business relationships that
might reasonably compromise its impartiality or independence.
Advisers providing investment advice on behalf of the firm, in their individual capacity, may be
an agent for various insurance companies. As such, they are able to receive separate, yet
customary commission compensation resulting from implementing product transactions on
behalf of advisory clients. Clients, however, are not under any obligation to engage them when
considering implementation of advisory recommendations. The implementation of any or all
recommendations is solely at the discretion of the client. Clients should be aware that the
receipt of additional compensation creates a conflict of interest that may impair objectivity
when making advisory recommendations.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
Capstar Financial does utilize Third-Party Money Managers. The annual/ quarterly fees are
shared between Capstar Financial and the Third-Party Money Manager. The fees shared
will not exceed any limit imposed by any regulatory agency. This creates a conflict of
interest in that Capstar Financial has an incentive to direct clients to the third-party
investment advisers that provide Capstar Financial with a larger fee split. Capstar Financial
will always act in the best interests of the client, including when determining which third-
party investment adviser to recommend to clients. Capstar Financial will verify that all
recommended advisers are properly licensed, notice filed, or exempt in the states where
Capstar Financial is recommending the adviser to clients.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
Capstar Financial has a written Code of Ethics that covers the following areas: Prohibited
Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted
Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment,
Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with
Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. Capstar Financials' Code of Ethics is available free upon request to
any client or prospective client.
B. Recommendations Involving Material Financial Interests
Capstar Financial will not recommend to clients, or buy or sell for client accounts, securities
in which the firm or a related person has a material financial interest. (Examples of a
material financial interest would include acting as a principal, general partner of a
partnership/fund where clients are solicited to invest or acting as an investment advisor
to and investment Company that the firm recommends to clients.)
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Capstar Financial may buy or sell securities for
themselves that they also recommend to clients. The COO will always document any
transactions that could be constructed as conflicts of interest and Capstar Financial
will always transact client business before its own when similar securities are being
bought or sold.
D. Trading Securities At/Around the Same Time as Clients'
Securities
From time to time, representatives of Capstar Financial may buy or sell securities for
themselves at or around the same time as clients. This may provide an opportunity
for representatives of Capstar Financial to buy or sell securities before or after
recommending securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict of
interest. When similar securities are being bought or sold, Capstar Financial employees
will either transact clients' transaction before their own or will transact alongside clients'
transactions in block or bunch trade.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on Capstar Financials' duty to
seek “best execution,” which is the obligation to seek execution of securities transactions
for a client on the most favorable terms for the client under the circumstances. Clients will
not necessarily pay the lowest commission or commission equivalent, and Capstar
Financial may also consider the market expertise and research access provided by the
broker-dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in Capstar Financials' research efforts. Capstar
Financial will never charge a premium or commission on transactions, beyond the actual
cost imposed by the broker-dealer/custodian.
Capstar recommends clients to use Fidelity Brokerage Services LLC.
1. Research and Other Soft-Dollar Benefits
While Capstar Financial has no formal soft dollars program in which soft dollars are
used to pay for third party services, Capstar Financial may receive research, products,
or other services from custodians and broker-dealers in connection with client
securities transactions (“soft dollar benefits”). Capstar Financial may enter into soft-
dollar arrangements consistent with (and not outside of) the safe harbor contained in
Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no
assurance that any particular client will benefit from soft dollar research, whether or
not the client's transactions paid for it, and Capstar Financial does not seek to allocate
benefits to client accounts proportionate to any soft dollar credits generated by the
accounts. Capstar Financial benefits by not having to produce or pay for the research,
products or services, and Capstar Financial will have an incentive to recommend a
broker-dealer based on receiving research or services. Clients should be aware that
Capstar Financials' acceptance of soft dollar benefits may result in higher commissions
charged to the client.
2. Brokerage for Client Referrals
Capstar Financial receives no referrals from a broker-dealer or third party in exchange
for using that broker-dealer or third party.
3. Clients Directing Which Broker Dealer/Custodian to use
Capstar Financial will require clients to use a specific broker-dealer to execute
transactions. Not all advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
Capstar Financial does not aggregate or bunch the securities to be purchased or sold for
multiple clients. This may result in less favorable prices, particularly for illiquid securities
or during volatile market conditions.
C. Third Party Money Managers
Third Party Money Managers may utilize different broker-dealers/custodians as
mentioned above, and may also aggregate or block trade. Please refer to each Third
Party Money Managers disclosure brochure.
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client accounts for Capstar Financials' advisory services provided on an ongoing basis
are reviewed at least Quarterly by Suzette M Porter, Advisor, with regard to clients'
respective investment policies and risk tolerance levels. All accounts at Capstar Financial
are assigned to this reviewer. On at least an annual basis we will reach out to clients to
confirm each client’s profile information is accurate and up to date and when
necessary, update a client’s profile information. In the first year new clients have
quarterly reviews and will then have semi-annual or annual reviews based on the
clients’ preference.
All financial planning accounts are reviewed upon financial plan creation and plan
delivery by Suzette M Porter, Advisor. Financial planning clients are provided a one- time
financial plan concerning their financial situation. After the presentation of the plan, there
are no further reports. Clients may request additional plans or reports for a fee.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
With respect to financial plans, Capstar Financials' services will generally conclude upon
delivery of the financial plan.
C. Content and Frequency of Regular Reports Provided to Clients
Each client of Capstar Financials' advisory services provided on an ongoing basis will
receive a monthly statement detailing the client's account, including assets held, asset
value, and calculation of fees. This written report will come from Fidelity Investments.
Quarterly Reviews are provided by AssetMark and/or Advisors Excel.
Each financial planning client will receive the financial plan upon completion.
Item 14: Client Referrals and Other Compensation
Capstar Financial receives compensation from third-party advisers to which it directs
clients.
B. Compensation to Non - Advisory Personnel for Client Referrals
Capstar Financial does not directly or indirectly compensate any person who is not
advisory personnel for client referrals.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian,
Capstar Financial will be deemed to have limited custody of client's assets and must
have written authorization from the client to do so. Clients will receive all account
statements and billing invoices that are required in each jurisdiction, and they should
carefully review those statements for accuracy.
Item 16: Investment Discretion
Capstar Financial provides discretionary investment advisory services to clients. The
advisory contract established with each client sets forth the discretionary authority for
trading. Where investment discretion has been granted, Capstar Financial generally
manages the client's account and makes investment decisions without consultation with
the client as to when the securities are to be bought or sold for the account, the total
amount of the securities to be bought/sold, what securities to buy or sell, or the price per
share. In some instances, Capstar Financials' discretionary authority in making these
determinations may be limited by conditions imposed by a client (in investment
guidelines or objectives, or client instructions otherwise provided to Capstar Financial.
Item 17: Voting Client Securities (Proxy Voting)
Capstar Financial will not ask for, nor accept voting authority for client securities. Clients will
receive proxies directly from the issuer of the security or the custodian. Clients should direct all
proxy questions to the issuer of the security.
Third Party Money Managers may utilize a different proxy voting policy than
mentioned above. Please refer to each Third Party Money Managers disclosure
brochure.
Item 18: Financial Information
A. Balance Sheet
Capstar Financial neither requires nor solicits prepayment of more than $1,200 in fees per
client, six months or more in advance, and therefore is not required to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither Capstar Financial nor its management has any financial condition that is likely to
reasonably impair Capstar Financials' ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Capstar Financial has not been the subject of a bankruptcy petition in the last ten years.