Overview
Assets Under Management: $321 million
Headquarters: HENDERSON, NV
High-Net-Worth Clients: 90
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (CAPSTONE CAPITAL WEALTH ADVISORS ADV PART 2A AMENDMENT 10.08.25)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $5,000,000 | 1.00% |
| $5,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | and above | 0.50% |
Minimum Annual Fee: $10,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $87,500 | 0.88% |
| $50 million | $287,500 | 0.58% |
| $100 million | $537,500 | 0.54% |
Clients
Number of High-Net-Worth Clients: 90
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 74.56
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 578
Discretionary Accounts: 578
Regulatory Filings
CRD Number: 123764
Last Filing Date: 2025-01-03 00:00:00
Website: https://capstonecap.com
Form ADV Documents
Primary Brochure: CAPSTONE CAPITAL WEALTH ADVISORS ADV PART 2A AMENDMENT 10.08.25 (2025-10-08)
View Document Text
Item 1 - Cover Page
Part 2A of Form ADV: Firm Brochure
2600 Paseo Verde Pkwy, Ste 150
Henderson, NV 89074
Telephone: 702-433-7588
Email: service@capstonecap.com
Web Address: www.capstonecap.com
October 8, 2025
This brochure provides information about the qualifications and business practices of
Capstone Capital Wealth Advisors. If you have any questions about the contents of this
brochure, please contact us at 702-433-7588 or service@capstonecap.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. Registration
with the SEC or with any state securities authority does not imply a certain level of skill
or training.
Additional information about Capstone Capital Wealth Advisors is also available on
the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is 123764.
Item 2 - Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually when material
changes occur from the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the Firm’s last ADV annual update amendment dated March 13, 2025, the Firm
had the following non-material change:
• Adam M. Corrie became the Chief Compliance Officer of Capstone Capital
Wealth Advisors.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please
contact us at 702-433-7588 or by email at service@capstonecap.com.
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Item 3 - Table of Contents
Item 1 - Cover Page .................................................................................................................... i
Item 2 - Material Changes ......................................................................................................... ii
Item 3 - Table of Contents ....................................................................................................... iii
Item 4 - Advisory Business ...................................................................................................... 4
Item 5 - Fees and Compensation ............................................................................................. 6
Item 6 - Performance-Based Fees and Side-By-Side Management ....................................... 8
Item 7 - Types of Clients ........................................................................................................... 8
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................................ 8
Item 9 - Disciplinary Information .............................................................................................. 9
Item 10 - Other Financial Industry Activities and Affiliations ............................................... 10
Item 11 - Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ............................................................................................. 10
Item 12 - Brokerage Practices ................................................................................................ 11
Item 13 – Review of Accounts ................................................................................................. 12
Item 14 - Client Referrals and Other Compensation ............................................................ 13
Item 15 - Custody .................................................................................................................... 13
Item 16 - Investment Discretion ............................................................................................. 14
Item 17 - Voting Client Securities ........................................................................................... 14
Item 18 - Financial Information .............................................................................................. 15
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Item 4 - Advisory Business
Capstone Capital Wealth Advisors is an SEC registered investment adviser with its
principal place of business located in Nevada. Capstone Capital began conducting
business in 2002.
Capstone Capital Wealth Advisors is owned by Dawson Holdings LLC. Adam Dawson is
the sole managing member of Dawson Holdings, LLC.
As of December 31, 2024, Capstone Capital Wealth Advisors had $360,484,106 in
discretionary assets under management.
Our firm provides continuous advice to clients regarding the investment of their funds,
and we tailor our advice to clients’ individual needs through personal discussions that
establish their goals and objectives based on their particular circumstances, which we
use to create and manage their portfolio. As appropriate, we also review and discuss
clients’ prior investment history, family composition, and background.
We manage clients’ advisory accounts on a discretionary basis. Discretionary services
allow Capstone Capital Wealth Advisors to enter trades in clients’ accounts on their
behalf without prior approval. Account supervision is guided by the client's stated
objectives (i.e., maximum capital appreciation, growth, income, or growth and income),
as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service
and will generally include advice regarding the following securities:
• Exchange-listed securities
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Exchange-traded fund shares
Because some types of investments involve certain additional degrees of risk, they will
only be implemented/recommended when consistent with the client's stated investment
objectives, tolerance for risk, liquidity, and suitability.
Retirement Rollovers-No Obligation/Conflict of Interest:
Capstone Capital Wealth Advisors is deemed to be a fiduciary to advisory clients that
are employees of benefit plans or individual retirement accounts (IRAs) pursuant to the
Employee Retirement Income and Securities Act (“ERISA”). As such, our firm is subject
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to specific duties and obligations under ERISA and the Internal Revenue Code that
include among other things, restrictions concerning certain forms of compensation. The
way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interests and not put our interests ahead
of yours. To avoid engaging in prohibited transactions, Capstone Capital Wealth
Advisors may only charge fees for investment advice about products for which our firm
and/or our related persons do not receive fees other than Capstone Capital Wealth
Advisor's advisory fees.
While Capstone Capital Wealth Advisors may receive increased compensation as a
result of a rollover recommendation, the firm will only make these recommendations in
the best interest of the client taking into account such various factors as: i.) the
investment options available in the plan versus the investment options available in an
IRA, ii.) fees and expenses in the plan versus the fees and expenses in an IRA, iii.) the
services and responsiveness of the plan’s investment professionals versus those of
Capstone Capital Wealth Advisors, iv.) required minimum distributions and age
considerations, and v.) employer stock tax consequences, if any. No client is under any
obligation to roll over plan assets to an IRA managed by Capstone Capital Wealth
Advisors.
There are legacy clients of Capstone Capital Wealth Advisors who receive services with
differing fees under engagements that we no longer offer. Capstone Capital Wealth
Advisors offers the following services to clients:
INVESTMENT MANAGEMENT
Capstone Capital Wealth Advisors provides ongoing investment management services
to clients, and in so doing, we initially review clients’ existing investment portfolios and
other data to provide investment recommendations and advice consistent with each
client’s stated financial objectives. Capstone Capital Wealth Advisors takes discretionary
authority in clients’ accounts to invest their assets according to their stated investment
objectives, risk tolerance, investment time horizon, and any restrictions that they might
place on their accounts.
Clients understand that Capstone Capital Wealth Advisors will have no responsibility for
decisions made by clients that are independent from our advice, and that we will not be
responsible for assets not designated for our management or for the diversification of all
the client’s assets.
FINANCIAL PLANNING
Capstone Capital Wealth Advisors provides clients financial planning services that,
depending on the client’s needs, may focus on, but are not limited to, the following areas:
goal setting, retirement planning, business succession and exit planning, insurance
analysis and risk management, charitable giving, legacy planning, tax planning, and
investment planning.
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Clients understand that the responsibility for financial decision are theirs alone, and that
they are under no obligation to follow, either wholly or partially, any recommendations or
suggestions provided by Capstone Capital Wealth Advisors.
None of the foregoing services include the practice of law or accounting services.
WRAP FEE PROGRAM
Capstone Capital Wealth Advisors does not offer wrap fee programs.
Item 5 - Fees and Compensation
There are legacy clients of Capstone Capital Wealth Advisors who receive services with
differing fees under engagements that we no longer offer. Capstone Capital Wealth
Advisors charges fees to clients for its services as follows:
INVESTMENT MANAGEMENT FEES
Capstone Capital Wealth Advisors charges its fee for investment management services
as an annual fee calculated as a percentage of assets under management, charged on a
quarterly basis, in arrears, according to the following fee schedule:
• 1.00% for the first $5,000,000
• 0.75% for the next $5,000,000
• 0.50% for additional assets above $10,000,000
The client’s fee is calculated each quarter using the value of the assets on the last
business day of the prior quarter, subject to a $2,500 minimum fee per quarter. Clients
with less than $1 million under Advisor’s management may pay a higher fee percentage
than the schedule shown above. When our services begin or terminate on a day other
than the first day of a calendar quarter, the fee for the initial or last quarter of services will
be prorated based on the number of days under our management.
Clients authorize Capstone Capital Wealth Advisors to deduct our fee directly from their
account held at an independent custodian as it becomes due and payable. If clients have
more than one account, we make the determination as to which account the fee is taken
from based on each client's best interest, or at their instruction. The account custodian(s)
send clients a statement at least quarterly detailing all transactions in the client’s
account. Capstone Capital Wealth Advisors may also accept payment by check in our
sole discretion.
FINANCIAL PLANNING FEES
Capstone Capital Wealth Advisors charges its fee for financial planning services as a
one-time, fixed fee ranging from $5,000 to $20,000 based on the scope of the client’s
planning needs and the complexity thereof collected in advance. The financial planning
fee is due at the time the client signs their agreement with Capstone Capital Wealth
Advisors, and it is payable by check, credit card, or debit card. Upon early termination
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of the engagement, Capstone Capital Wealth Advisors will prorate the refund of any
unearned, prepaid fee paid for financial planning services based on the services
provided prior to termination, in our sole discretion.
Limited Negotiability of Advisory Fees: Although Capstone Capital Wealth Advisors has
established the fee schedule(s), we retain the discretion to negotiate alternative fees on
a client-by-client basis. Client facts, circumstances and needs will be considered in
determining the fee schedule. These considerations include the complexity of the client,
assets to be placed under management, anticipated future additional assets; related
accounts; portfolio style, account composition, reports, among other factors. The
specific quarterly fee schedule will be identified in the contract between Capstone
Capital Wealth Advisors and each client.
GENERAL INFORMATION
Termination of the Advisory Relationship: Any engagement agreement may be canceled
at any time without penalty, by either party, for any reason. To initiate a termination, the
client must notify Capstone Capital Wealth Advisors in writing. If an agreement is
canceled within five business days after the effective date of the agreement a client will
receive a full refund of fees. After five days, all fees owed to us for work performed
before termination and all credits owed to the client for fees paid that remain unearned
at time of termination become due immediately. We reserve the right to value a client's
account, prorate the fee and automatically debit the fees owed to us anytime during this
termination period. Fees for work completed up to the termination date will not be
refunded. We agree to provide investment services and reasonable logistical support in
transferring the client's account effectively ending our management of the account. If a
client terminates our services and later decides to use our services again, the client will
enter into a new agreement.
Mutual Fund and Exchange Traded Fund (“ETF”) Fees: All fees paid to Capstone Capital
Wealth Advisors for investment advisory services are separate and distinct from the
fees and expenses charged by mutual funds and ETFs to their shareholders. These
fees and expenses are described in each fund's prospectus. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. A
client could invest in a mutual fund or ETF directly, without our services. In this case,
the client would not receive the services provided by our firm which are designed,
among other things, to assist the client in determining which type of securities are most
appropriate for each client's financial condition and objectives. Accordingly, the client
should review both the fees charged by the funds and our fees to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.
Additional Fees and Expenses: In addition to our advisory fees, clients are also
responsible for the fees and expenses charged by custodians and imposed by broker
dealers, including, but not limited to, any transaction charges imposed by a broker
dealer when an independent investment manager effects transactions for the client's
account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form
ADV for additional information.
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Capstone Capital Wealth Advisors may charge up to $500.00 per hour for work not
related to investment advisory services. This fee applies to clients that are not receiving
our investment advisory services. This could include asset registration or re-registration
or consultation on investments not held at our firm.
Item 6 - Performance-Based Fees and Side-By-Side Management
Capstone Capital Wealth Advisors does not charge any performance-based fees and
does not use side-by-side management.
Item 7 - Types of Clients
Capstone Capital Wealth Advisors provides advisory services to the following types of
clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Pension and profit-sharing plans (other than plan participants)
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed
Capstone Capital Wealth Advisors has a minimum account size of $1 million for new
clients. Exceptions may be allowed in certain instances at the sole discretion of Capstone
Capital Wealth Advisors.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment
goals and risk tolerance. We base asset allocation decisions on academic and long-
term market research, not economic conditions, or short-term market predictions. We
strive to choose mutual funds or ETFs with broad market exposure, low turnover, and
low management fees. We also pay close attention to how the holdings of various funds
relate to each other, to improve diversification and minimize overlap.
Capstone Capital Wealth Advisors’ investment strategies have a long-term focus and
are closely coordinated with each client's specific investment objectives, risk tolerance,
investment time horizon and liquidity needs. Capstone Capital Wealth Advisors
determines and builds the portfolio with the client. If a client already owns certain
securities, the appropriateness, constraints, and all other factors are considered in
deciding whether to sell them or retain them in the overall investment plan.
We may periodically rebalance client portfolios as markets fluctuate, to bring portfolios
back to their original target allocation. Otherwise, portfolio allocations may gradually fall
outside the client’s risk tolerance.
Securities investments are not guaranteed, and you may lose money on your
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investments. We ask that you work with us to help us understand your tolerance for risk.
Clients should understand that investing in any securities, including mutual funds and
ETFs, involves a risk of loss of both income and principal. The following are some of the
investment risks faced by investors:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market value to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by
external factors independent of a security’s particular underlying circumstances.
For example, political, economic, and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as
much as a dollar last year, because purchasing power is eroding at the rate of
inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of
the dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may
have to be reinvested at a potentially lower rate of return (i.e., interest rate). This
primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
carry a higher risk of profitability than an electric company, which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases
the risk of profitability, because the company must meet the terms of its
obligations in good times and bad. During periods of financial stress, the inability
to meet loan obligations may result in bankruptcy and/or a declining market value.
Item 9 - Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's
or prospective client's evaluation of our advisory business or the integrity of our
management. Our firm and our management personnel have no reportable disciplinary
events to disclose.
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Item 10 - Other Financial Industry Activities and Affiliations
Neither our firm nor any of its management persons are registered, or have an
application pending to register, as a broker-dealer or registered representative of a
broker-dealer.
Neither our firm 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.
Neither our firm nor any our related persons have arrangements that are material to its
advisory or its clients with a related person who is a broker-dealer, investment
company, other investment advisor, financial planning firm, commodity pool operator,
commodity trading adviser or futures commission merchant, banking or thrift institution,
accounting firm, law firm, insurance company or agency, pension consultant, real
estate broker or dealer, or an entity that creates or packages limited partnership.
Item 11 - Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of
business conduct which we require of our employees, including compliance with
applicable federal securities laws.
Capstone Capital Wealth Advisors and our personnel owe a duty of loyalty, fairness,
and good faith towards our clients, and have an obligation to adhere not only to the
specific provisions of the Code of Ethics but to the general principles that guide the
Code.
Our Code of Ethics includes policies and procedures for the review of quarterly
securities transactions reports as well as initial and annual securities holdings reports
that must be submitted by the firm’s access persons.
A copy of our Code of Ethics is available to our advisory clients and prospective clients.
You may request a copy by sending an email to service@capstonecap.com, or by calling
us at 702-433-7588.
Capstone Capital Wealth Advisors does not recommend to its clients’ securities in
which the firm or a related person has a material financial interest.
Capstone Capital Wealth Advisors or persons associated with the firm may buy or sell
the same securities that the firm recommends to clients or securities in which clients
are already invested. A conflict of interest may exist in such cases because Capstone
Capital Wealth Advisors can trade ahead of the client and potentially receive more
favorable prices than the client will receive. To eliminate this conflict of interest, it is
Capstone Capital Wealth Advisors’ policy that neither the firm’s access persons nor
Capstone Capital Wealth Advisors shall have priority over a client’s purchase or sale of
securities. The firm maintains a list of all reportable securities holdings for our firm,
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and anyone associated with Capstone Capital Wealth Advisors that has access to advisory
recommendations ("access person") and these holdings are reviewed on a regular
basis by our firm's Chief Compliance Officer or their designee.
Item 12 - Brokerage Practices
In the event that the client requests that we recommend a broker dealer/custodian for
execution and/or custodial services, the firm generally recommends that investment
management accounts be maintained at Charles Schwab & Co., Inc. (“Schwab”), a
registered broker-dealer and member of SIPC, to maintain custody of clients' assets and
to effect trades for their accounts. Schwab is independently owned and operated and not
affiliated with the firm. Schwab does not supervise or otherwise monitor the firm’s
investment management services to its clients. Schwab provides us with access to
institutional trading and custody services, which typically are not available to Schwab’s
retail investors. Schwab’s services include brokerage, custody, research and access to
mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
Factors that we consider in recommending Schwab or any other broker-dealer/custodian
to clients include financial strength, reputation, execution capabilities, pricing, research,
and service. Although the transaction fees paid by our clients shall comply with our duty
to obtain best execution, a client may pay a fee that is higher than another qualified
broker-dealer might charge for the same transaction. The firm, in good faith, believes
that the transaction fees charged are reasonable in relation to the value of the brokerage
and research 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 the
value of research provided, execution capability, fee rates, and responsiveness.
Accordingly, although we will seek competitive rates, we may not necessarily obtain the
lowest possible fee rates for client account transactions. The brokerage transaction fees
charged by the designated broker-dealer/custodian are exclusive of, and in addition to,
the firm’s investment management fee.
Although not a material consideration when determining whether to recommend that a
client utilize the services of a particular broker-dealer/custodian, the firm may receive
from Schwab (or another broker-dealer/custodian) without cost (and/or at a discount)
support services and/or products which assist us to better monitor and service client
accounts maintained at such institutions. Included within the support services that may
be obtained by the firm may be investment-related research, pricing information and
market data, software and other technology that provide access to client account data,
compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/or gratis attendance at conferences, meetings,
and other educational and/or social events, marketing support, computer hardware
and/or software and/or other products used by us in furtherance of its investment
advisory business operations.
As indicated above, certain of the support services and/or products that may be
received may assist the firm in managing and administering client accounts. Others do
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not directly provide such assistance but rather assist the firm to manage and further
develop its business enterprise.
Our clients do not pay more for investment transactions effected and/or assets
maintained at Schwab because of this arrangement. There is no corresponding
commitment made by us to Schwab or any other any entity to invest any specific
amount or percentage of client assets in any specific mutual funds, securities, or other
investment products as result of the above arrangement.
The firm’s Chief Compliance Officer is available to address any questions that a client or
prospective client may have regarding the above arrangement and any corresponding
perceived conflict of interest such arrangement may create.
The firm does not receive referrals from broker-dealers; nor engage in directed
brokerage arrangements.
To the extent that the firm provides investment management services to its clients, the
transactions for each client account generally will be affected independently, unless the
firm decides to purchase or sell the same securities for several clients at approximately
the same time. The firm may, (but is not obligated to), combine or “bunch” such orders
to obtain best execution, to negotiate more favorable fee rates, or to allocate equitably
among the firm’s clients differences in prices and commissions or other transaction
costs that might have been obtained had such orders been placed independently.
Under this procedure, transactions will be averaged as to price and will be allocated
among clients in proportion to the purchase and sale orders placed for each client
account on any given day. We shall not receive any additional compensation or
remuneration resulting from such aggregation.
Schwab provides clients with consolidated statements. Our employees are not
registered representatives of Schwab and do not receive any commissions or fees from
recommending these services.
Item 13 - Review of Accounts
INDIVIDUAL PORTFOLIO MANAGEMENT REVIEWS
While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed at least annually.
Accounts are reviewed in the context of each client's stated investment objectives and
guidelines. More frequent reviews may be triggered by material changes in variables
such as the client's individual circumstances, or the market, political or economic
environment.
Adam M. Dawson, or another person designated by him, is responsible for the review
of accounts at least annually. In addition to the statements and confirmations of
transactions clients receive from their custodian at least quarterly, we provide quarterly
statements summarizing account performance, balances, and holdings.
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Item 14 - Client Referrals and Other Compensation
Our firm may pay referral fees to independent persons or firms for introducing clients to
us. Under the agreement between the firm and the referring person or firm, we will
compensate them with a portion of our advisory fee for persons referred to us who
become a client. We maintain this arrangement in accordance with applicable state and
federal laws.
As a matter of firm practice, the advisory fees paid to us by clients referred to us under
these arrangements are not increased because of the referral arrangement.
Item 15 – Custody
Capstone Capital Wealth Advisors does not accept or maintain physical custody of any
client cash or securities. All clients’ assets are held by an independent qualified
custodian. Capstone Capital Wealth Advisors will only have custody of assets to the
extent it deducts its advisory fees from client accounts and in the use of Standing
Letters of Authorization (SLOA’s) for third-party money movement. As previously
disclosed in the "Fees and Compensation" section (Item 5) of this Brochure, clients give
Capstone Capital Wealth Advisors the authorization to directly deduct the firm’s fee
from their account held by the independent custodian. As part of this billing process, the
client's custodian is advised by Capstone Capital Wealth Advisors of the amount of the
fee to be deducted from the client's account. On at least a quarterly basis, the
custodian is required to send to the client a statement showing all transactions within
the account during the reporting period, including the deduction of Capstone Capital
Wealth Advisors’ fee.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy
of the calculation, among other things. Clients should contact us directly if they believe
there may be an error in their statement.
For SLOA’s: All transfers from client custodial accounts to third party accounts will be
preceded or accompanied by client written authorization. Capstone Capital Wealth
Advisors will ensure that the SLOA will satisfy the requirements needed to avoid the
need for the surprise annual audit for third-party money transfers and will contain the
specific information needed to avoid custody when using a SLOA for a first-party
money transfer.
Account Statements
Clients will receive at least quarterly account statements from the broker-dealer, bank
or other qualified custodian that holds and maintains client’s investment assets detailing
the assets in the account and any transactions including fee deductions.
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Performance Reports
In addition to the account statements the clients receive directly from their custodians,
we also send reports directly to our clients on a quarterly basis. We urge our clients to
carefully compare the information provided on these statements to ensure all account
transactions, holdings and values are correct and current. If you are not receiving at
least quarterly custodial account statements, please contact us at the number on the
cover page of this brochure.
Item 16 - Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case
we place trades in a client's account without contacting them prior to each trade to
obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the
client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell and process the order.
Clients give us discretionary authority when they sign a discretionary agreement on the
new account document and in the Investment Management Agreement with our firm
and may limit this authority by giving us written instructions. Clients may also
change/amend such limitations by once again providing us with written instructions.
Capstone Capital Wealth Advisors requires it be provided with written authority to
determine which securities and the amounts of securities that are bought or sold in
a client's account.
Item 17 - Voting Client Securities
Capstone Capital Wealth Advisors does not vote proxies on securities or provide advice
about how to vote proxies for securities held in client portfolios. Clients retain the
responsibility for receiving and voting proxies for all securities maintained in their
accounts. Clients should receive proxies or other similar solicitations directly from the
client's selected custodian or transfer agent. Should we receive a duplicate copy, we
generally do not forward it to the Client. Capstone Capital Wealth Advisors will have no
power, authority, responsibility, or obligation to take any action with regard to any claim
or potential claim in any bankruptcy proceeding, class action securities litigation or other
litigation or proceeding relating to securities held at any time in a client account, including
without limitation, to file proofs of claim or other documents related to such proceeding,
or to investigate, initiate, supervise, or monitor class action or other litigation involving
client assets. Further, we will not offer or provide guidance on these matters; clients
should contact the issuer or their legal counsel.
Corporate Actions / Issuer Communications
For some clients, Capstone Capital Wealth Advisors is the primary recipient for issuer
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communications related to corporate actions such as mergers, acquisitions, spin-offs,
and stock splits. For these situations, the client may delegate responsibilities to Capstone
Capital Wealth, in writing, to receive notices, provide guidance, and/or carry out the
action. If no such delegation is given to Capstone Capital Wealth Advisors in writing by
the client, the client remains responsible for all actions taken regarding Corporate Actions
for the securities that they hold.
Item 18 - Financial Information
Capstone Capital Wealth Advisors does not require or solicit pre-payment of fees
more than $1,200 per client, for services to be provided six months or more in
advance. Therefore, we are not required to include a financial statement.
As an advisory firm that maintains discretionary authority for client accounts or is
deemed to have custody, we are also required to disclose any financial condition
reasonably likely to impair our ability to meet our contractual obligations. Capstone
Capital Wealth Advisors has no additional financial circumstances to report.
Capstone Capital Wealth Advisors has not been the subject of a bankruptcy petition
within the past ten years.
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