Overview
- Headquarters
- La Jolla, CA
- Average Client Assets
- $2.5 million
- Minimum Account Size
- $2,000,000
- SEC CRD Number
- 298439
Fee Structure
Primary Fee Schedule (CCW - ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.90% |
| $5,000,001 | $10,000,000 | 0.80% |
| $10,000,001 | $15,000,000 | 0.70% |
| $15,000,001 | $20,000,000 | 0.60% |
| $20,000,001 | $50,000,000 | 0.40% |
| $50,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | Below minimum client size | |
| $5 million | $48,000 | 0.96% |
| $10 million | $88,000 | 0.88% |
| $50 million | $273,000 | 0.55% |
| $100 million | $423,000 | 0.42% |
Clients
- HNW Share of Firm Assets
- 80.59%
- Total Client Accounts
- 963
- Discretionary Accounts
- 963
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting
Regulatory Filings
Additional Brochure: CCW - ADV PART 2A (2026-04-21)
View Document Text
Form ADV Part 2A
Firm Brochure
Castle Coast Wealth, LLC
4225 Executive Square, Suite 1030
La Jolla, California 92037
T: 858-546-1247
https://www.castlecoastwealthllc.com/
April 2026
Item 1 – Cover Page
This brochure provides information about the qualifications and business practices of Castle Coast Wealth, LLC.
(“CCW” or “Firm”). If you have any questions about the contents of this brochure, please contact us at (858) 546-
1247 or compliance@castlecoastwealth.com The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Castle Coast Wealth, LLC. (CRD# 298439) is a registered investment advisor with the SEC. Registration of an
investment advisor does not imply any certain level of skill or training.
Additional information about Castle Coast Wealth, LLC. also is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Since the last annual update of this brochure on 3/3/2026, no material changes have occurred.
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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 .......................................................................................................................................... 1
ITEM 5 – FEES AND COMPENSATION ............................................................................................................................... 4
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................. 6
ITEM 7 – TYPES OF CLIENTS ............................................................................................................................................... 6
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................... 6
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 ............................................................................................................................................................................ 11
ITEM 12 – BROKERAGE PRACTICES ................................................................................................................................. 12
ITEM 13 – REVIEW OF ACCOUNTS .................................................................................................................................. 14
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................................... 14
ITEM 15 – CUSTODY ......................................................................................................................................................... 14
ITEM 16 – INVESTMENT DISCRETION ............................................................................................................................. 15
ITEM 17 – VOTING CLIENT SECURITIES .......................................................................................................................... 15
ITEM 18 – FINANCIAL INFORMATION ............................................................................................................................. 15
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Item 4 – Advisory Business
Castle Coast Wealth, LLC. (“CCW” or the “Firm”) has been in business since 2019, and was formerly known as
Litton Financial, LLC. The Firm is based in La Jolla, California. The Firm’s primary owner is Charlie Gillespie.
ASSET MANAGEMENT
CCW offers asset management services to advisory Clients. CCW will offer Clients ongoing asset management
services through determining individual investment goals, time horizons, objectives, and risk tolerance.
Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment
program will be based on the above factors.
Discretionary Management
When the Client elects to use CCW on a discretionary basis, the Client will sign a limited trading
authorization or equivalent allowing CCW to determine the securities to be bought or sold and the
amount of the securities to be bought or sold. CCW will have the authority to execute transactions in
the account without seeking Client consent on each transaction.
CCW may also recommend that certain qualified Clients consider an investment in private funds/offerings.
CCW’s role relative to the private investment funds can include, but not limited to, initial and ongoing due
diligence, performance reporting, and investment monitoring services. CCW’s Clients are under no obligation
to consider or make an investment in private investment fund(s). Each prospective private fund investor will be
required to complete a Subscription Agreement or similar application, pursuant to which the Client shall
establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk
factors that are associated with such an investment. Please see Item 8 for more information on the risks
associated with this type of investment.
FINANCIAL PLANNING
Services include an evaluation of a client’s current and future financial state using currently known variables to
predict future cash flows, asset values, recommend purchase and sales, and withdrawal plans. CCW will use
current net worth, tax liabilities, asset allocation, and future retirement and estate plans in developing financial
plans. Topics for planning may include, but are not limited:
• Personal net worth statement: A snapshot of assets and liabilities serves as a benchmark for measuring
progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set aside for debt
repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other financial priorities.
Including a strategy for accumulating the required retirement capital and its planned lifetime
distribution.
Long-term investment plan: Build a customized asset allocation strategy based on specific investment
•
objectives and a risk profile. This strategy sets guidelines for selecting, buying, and selling investments
and establishing benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the extent permissible
by the tax code. The strategy should include identification of tax favored investment vehicles that can
reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement accounts and life
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insurance, provide a second look at your current estate planning documents, and prompt you to update
your plan when the legal environment changes or you have major life events such as a marriage, death,
or births.
If a conflict of interest exists between the interests of CCW and the interests of the Client, the Client is under no
obligation to act upon CCW’s recommendation. If the Client elects to act on any of the recommendations, the
Client is under no obligation to affect the transaction through CCW.
ERISA PLAN SERVICES
CCW offers service to qualified and non-qualified retirement plans, including 401(k) plans, 403(b) plans, pension
and profit-sharing plans, cash balance plans, and deferred compensation plans (“Plan”). CCW offers services as
an ERISA 3(21) Investment Advisor or as an ERISA 3(38) Investment Manager:
Limited Scope ERISA 3(21) Fiduciary. CCW acts as a limited scope ERISA 3(21) fiduciary that can advise, help,
and assist plan sponsors with their investment decisions. As an investment advisor CCW has a fiduciary duty to
act in the best interest of the Client. The plan sponsor is still ultimately responsible for the decisions made in
their plan, though using CCW can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Plan about asset classes and investment alternatives available
for the Plan in accordance with the Plan’s investment policies and objectives. The Plan Sponsor
will make the final decision regarding the initial selection, retention, removal, and addition of
investment options. CCW acknowledges that it is a fiduciary as defined in ERISA section 3(21) (A)
(ii).
• Assist the Plan in the development of an investment policy statement (“IPS”). The IPS establishes
the investment policies and objectives for the Plan. Plan shall have the ultimate responsibility
and authority to establish such policies and objectives and to adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a qualified
default investment alternative (“QDIA”) for participants who are automatically enrolled in the
Plan or who have otherwise failed to make investment elections. The Plan retains the sole
responsibility to provide all notices to the Plan participants required under ERISA Section
404(c)(5) and 404(a)5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to the
guidelines set forth in the IPS and make recommendations to maintain, remove, or replace
investment options.
• Meet with the Plan Sponsor on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Plan understands CCW’s assistance
in education of the Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor Interpretive
Bulletin 96-1). As such, CCW is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to
the Plan participants. CCW will not provide investment advice concerning the prudence of any
investment option or combination of investment options for a particular participant or
beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
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CCW may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these
services, as agreed upon between CCW and the Plan.
3. CCW has no responsibility to provide services related to the following types of assets (“Excluded
Employer securities;
Stock brokerage accounts or mutual fund windows;
Assets”):
•
• Real estate (except for real estate funds or publicly traded REITs);
•
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to CCW on the ERISA Agreement. Specific
services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. CCW acts as an ERISA 3(38) Investment Manager in which it has discretionary
management and control of a given retirement plan’s assets. CCW would then become solely responsible and
liable for the selection, monitoring, and replacement of the plan’s investment options.
1. Fiduciary Services include:
Advisor has discretionary authority and will make the final decision regarding the initial
selection, retention, removal, and addition of investment options in accordance with the Plan’s
•
investment policies and objectives.
Assist the Plan Sponsor with the selection of a broad range of investment options consistent
with ERISA Section 404(c) and the regulations thereunder.
•
Assist the Plan Sponsor in the development of an investment policy statement. The IPS
establishes the investment policies and objectives for the Plan.
•
Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically enrolled in the
•
Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the
sole responsibility to provide all notices to the Plan participants required under ERISA Section
404(c) (5).
Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to the
•
guidelines set forth in the IPS and make recommendations to maintain, remove, or replace
investment options.
Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment
recommendations.
•
2. Non-fiduciary Services include:
Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. The Advisor’s assistance in education
•
of the Plan participants shall be consistent with and within the scope of the Department of
Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As
such, the Advisor is not providing fiduciary advice as defined by ERISA to the Plan participants.
Advisor will not provide investment advice concerning the prudence of any investment option
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or combination of investment options for a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
•
CCW may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these
services, as agreed upon between Advisor and Plan Sponsor.
3. CCW has no responsibility to provide services related to the following types of assets (“Excluded
Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
g. Other hard-to-value or illiquid securities or property.
Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are created
that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or
types of securities. These restrictions, however, may prohibit engagement with CCW.
Wrap Fee Programs
CCW does not participate in a Wrap Program.
Assets under Management
As of December 31, 2025, our firm manages $423,691,740.11. All assets were managed on a discretionary basis,
and no assets were managed on a non-discretionary basis. Additionally, the firm provided non-managed
advisory services to clients totaling $34,046,765, referred to as Assets under Advisement.
Item 5 – Fees and Compensation
ASSET MANAGEMENT FEES
Castle Coast Wealth, LLC charges a standard investment management fee:
Managed Assets
Up to $3,000,000
$3,000,001 - $5,000,000
$5,000,001 - $10,000,000
$10,000,001 - $15,000,000
$15,000,001 - $20,000,000
$20,000,001 - $50,000,000
$50,000,001 and above
Annual Management Fee (%)
1.00%
0.90%
0.80%
0.70%
0.60%
0.40%
0.30%
This is a blended fee schedule, meaning different asset levels are assessed different fees, as shown above.
Then, the fees from each level are blended into a single fee.
Fees are billed monthly in arrears based on the average daily balance of the account(s) for the previous month.
If a client opens a managed account during any month, the firm’s asset management fees will be prorated
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based on the number of days the account was open with a balance during that month.
Lastly, please note that CCW may group certain related Client accounts, often known as “householding,” for the
purposes of achieving the minimum account size and determining the annualized fee. For fee calculation
purposes, a client’s managed assets are combined with those of their immediate family, defined as spouse or
partner and dependent children (collectively, a “household’).
FINANCIAL PLANNING FEES
CCW typically charges a fixed fee for financial planning. Financial Planning services are ongoing and include the
development, delivery, and monitoring of the plan. Financial Planning fees are calculated as an annual flat fee
based on the scope and complexity of engagement with the respective Client. Financial Planning Fees are billed
monthly and typically deducted from an asset management account managed by CCW, or may be paid by check.
Our Financial Planning Services fees will never exceed $50,000 annually. On rare occasions and at the discretion
of Castle Coast Wealth, it can charge an hourly fee for a project-based financial planning arrangement. The
maximum hourly fee to be charged will not exceed $500.
ERISA PLAN SERVICES FEES
The annual fees are based on the market value of the Included Assets and shall not exceed 1%. Fees may be
charged quarterly or monthly in arrears or in advance based on the assets as calculated by the custodian or
record keeper of the Included Assets (without adjustments for anticipated withdrawals by Plan participants or
other anticipated or scheduled transfers or distribution of assets) on the last business day of the previous
quarter.
The fee schedule, which includes compensation of CCW for the services, is described in detail in the ERISA Plan
Agreement. The Plan is obligated to pay the fees; however, the Plan Sponsor may elect to pay the fees. Clients
may elect to be billed directly or have fees deducted from Plan Assets. CCW does not reasonably expect to
receive any additional compensation, directly or indirectly, for its services. If additional compensation is
received, CCW will disclose this compensation, the services rendered, and the payer of compensation.
Payment of Fees
Asset Management Fees are generally deducted directly from the Client’s Account.
Financial Planning Fees are invoiced directly to the Client. Financial Planning fees are paid in advance, either
annually, semi-annually, or quarterly, depending on the fee amount. Fees will never be billed $1,200 or more
six months or more in advance.
ERISA Fees are generally deducted directly from the Client’s/Plan Assets.
CCW, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g.,
historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.).
For all services, Clients may terminate their engagement with CCW within five (5) business days of signing an
Agreement with no obligation and without penalty. After the initial five (5) business days, the Agreement may
be terminated by CCW with thirty (30) days written notice to Client and by the Client at any time with written
notice to CCW. For accounts opened or closed mid-billing period, fees will be prorated based on the days
services are provided during the given period. In the case of hourly engagements, fees will be prorated based
on the work completed at the stated hourly rate. All unpaid earned fees will be due to CCW, and all unearned
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fees will be refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before
any increase in said fees occurs.
Additional Fees
Custodians may charge brokerage commissions, transaction fees, and other related costs on the purchases or
sales of mutual funds, equities, bonds, options, margin interest, and exchange-traded funds. Mutual funds,
money market funds, and exchange-traded funds may also charge internal management fees, which are
disclosed in the fund’s prospectus. CCW does not directly receive any compensation from these fees. All of
these fees are in addition to the management fee you pay to CCW. For more details on the brokerage practices,
see Item 12 of this brochure.
Prepayment of Fees
Financial Planning fees are paid in advance, either annually, semi-annually, or quarterly, depending on the fee
amount. Fees will never be billed over $1,200 six months or more in advance.
External Compensation for the Sale of Securities
CCW does not receive any external compensation from the sale of securities.
Item 6 – Performance-Based Fees and Side-By-Side Management
Fees are not based on a share of the capital gains or capital appreciation of managed securities. CCW does not
use a performance-based fee structure nor “side-by-side” management because of the conflict of interest.
Performance-based compensation may create an incentive for CCW to recommend an investment that may
carry a higher degree of risk to the Client.
Item 7 – Types of Clients
CCW’s Clients are generally individuals, high-net-worth individuals, pension and profit-sharing plans, charitable
organizations, trusts, corporations, and other businesses. Client relationships vary in scope and length of
service. Clients are not required to have a certain amount of investment experience or sophistication.
• Our firm typically requires a minimum household balance of $2,000,000 for new clients and $1,000,000
for clients that have been referred to us for our Asset Management service. We have in the past and
may in the future, at our discretion, choose to aggregate other accounts of the client to meet this
minimum, or make other exceptions as appropriate in the circumstances. The above minimums can
vary and have in the past and may in the future be lowered and/or waived at our sole discretion.
• Written financial plans are generally assessed a minimum fee of $2,000.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a
guarantee of future returns. Security analysis methods may include:
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually
consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement
patterns (trend following or mean reversion). The resulting strategies may involve high-frequency trading. The
results of the analysis are taken into consideration in the decision to buy or sell securities and in the
management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models
used may be based on assumptions that prove to be incorrect.
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Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information,
such as management expertise, industry cycles, strength of research and development, and labor relations.
Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on
reports such as balance sheets. The two techniques, however, will often be used together in order to examine
a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with
intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one.
This approach depends on the kind of intelligence that machines (currently) lack, since things like positive
associations with a brand, management trustworthiness, customer satisfaction, competitive advantage, and
cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the Client during
consultations. The Client may change these objectives at any time by providing written notice to CCW. Each
Client executes a client profile form or similar form that documents their objectives and their desired
investment strategy.
Risks of Investments and Strategies Utilized
Investing in securities involves risk of loss that Clients should be prepared to bear. CCW’s investment
approach constantly keeps the risk of loss in mind. Investors may face the following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial instruments using
strategies and investment techniques with significant risk characteristics. The investment program utilizes such
investment techniques as option transactions, margin transactions, short sales, leverage, and derivatives
trading, the use of which can, in certain circumstances, maximize the adverse impact to which a client may be
subject.
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 values to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next 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.
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.
Management Risk. The advisor’s investment approach may fail to produce the intended results. If the advisor’s
assumptions regarding the performance of a specific asset class or fund are not realized in the expected time
frame, the overall performance of the Client’s portfolio may suffer.
Cybersecurity Risk. CCW and its service providers may be subject to operational and information security risks
resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data
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maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential
information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting CCW and its
service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of
transactions, cause the release of private information about Clients, impede trading, subject CCW to regulatory
fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present
for issuers of securities in which Clients may invest in, qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity
incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and
reputational damages, and loss from damage or interruption of systems. Although CCW has established its
systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that these efforts
will always be successful, especially considering that CCW does not directly control the cybersecurity measures
and policies employed by third party service providers.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of
owning an ETF generally reflect the risks of owning the underlying securities they are designed to track,
although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that
increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices may not correlate
perfectly with changes in the underlying reference units; and (ii) the risk of possible trading halts due to market
conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in
the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A mutual
fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations of the
overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices of
common stock react to the economic condition of the company that issued the security, industry and market
conditions, and other factors which may fluctuate widely. Investments related to the value of stocks may rise
and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for
takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities,
including preferred stock, warrants, and options may also vary widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers.
Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some
small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be
subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be
followed by fewer investment research analysts, and may be subject to wider price swings and thus may create
a greater chance of loss than when investing in securities of larger-cap issuers. The market prices of securities
of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, to corporate
developments, and to market rumors than are the market prices of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities,
commodities contracts, and/or derivative instruments, including futures, options, and swap agreements. The
prices of commodities contracts and derivative instruments, including futures and options, are highly volatile.
Payments made pursuant to swap agreements may also be highly volatile. Price movements of commodities,
futures and options contracts, and payments pursuant to swap agreements are influenced by, among other
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things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control
programs and policies of governments, and national and international political and economic events and
policies. The value of futures, options, and swap agreements also depends upon the price of the commodities
underlying them. In addition, Client assets are subject to the risk of the failure of any of the exchanges on which
its positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of forward
and other derivative contracts are influenced by, among other things, interest rates, changing supply and
demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments,
and national and international political and economic events and policies. Clients are also subject to the risk of
failure of any of the exchanges on which their positions trade or of its clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in
securities of non-U.S. issuers pose a range of potential risks which could include expropriation, confiscatory
taxation, imposition of withholding or other taxes on dividends, interest, capital gains, or other income, political
or social instability, illiquidity, price volatility, and market manipulation. In addition, less information may be
available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting,
auditing and financial reporting standards, and requirements comparable to or as uniform as those of U.S.
issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In addition to
the risks associated with investments outside of the United States, investments in emerging markets (i.e., the
developing countries) may involve additional risks. Emerging markets generally are not as efficient as those in
developed countries. In some cases, a market for the security may not exist locally, and transactions will need
to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in
developed countries. When seeking to sell emerging market securities, little or no market may exist for the
securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and
financial reporting standards, practices, and requirements comparable to those applicable to issuers based in
developed countries, thereby potentially increasing the risk of fraud or other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk
that the category may be out of favor due to current market conditions or investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the Companies,
which could have an adverse effect on each of them. If the securities of the Companies experience poor
liquidity, investors may be unable to transact at advantageous times or prices, which may decrease the
Company’s returns. In addition, there is a risk that policy changes by central governments and governmental
agencies, including the Federal Reserve or the European Central Bank, which could include increasing interest
rates, could cause increased volatility in financial markets, which could have a negative impact on the
Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of infectious
illness or other public health issues, recessions, or other events could have a significant impact on the
Companies. For example, the rapid and global spread of a highly contagious novel coronavirus respiratory
disease, designated COVID-19, has resulted in extreme volatility in the financial markets and severe losses;
reduced liquidity of many Companies’ securities; restrictions on international and, in some cases, local travel;
significant disruptions to business operations (including business closures); strained healthcare systems;
disruptions to supply chains, consumer demand and employee availability; and widespread uncertainty
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regarding the duration and long-term effects of this pandemic. Some sectors of the economy and individual
issuers have experienced particularly large losses. In addition, the COVID-19 pandemic may result in a sustained
economic downturn or a global recession, domestic and foreign political and social instability, damage to
diplomatic and international trade relations and increased volatility and/or decreased liquidity in the securities
markets. The Companies’ values could decline over short periods due to short-term market movements and
over longer periods during market downturns.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer (typically an
insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate
payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity).
The payment stream from the issuer to the annuitant has an unknown duration based principally upon the
date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds
accumulated are forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be
purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed
amounts or in amounts that increase by a fixed percentage, variable annuities, pay amounts that vary according
to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable
annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified
period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender
charges, such as mortality and expense risk charges; administrative fees; underlying fund expenses; and
charges for special features, all of which can reduce the return. Earnings in a variable annuity do not provide
all the tax advantages of 401(k)s and other before-tax retirement plans. Once the investor starts withdrawing
money from their variable annuity, earnings are taxed at the ordinary income rate, rather than at the lower
capital gains rates applied to other non-tax-deferred vehicles which are held for more than one year. Proceeds
of most variable annuities do not receive a "step-up" in cost basis when the owner dies like stocks, bonds and
mutual funds do. Some variable annuities offer "bonus credits." These are usually not free. In order to fund
them, insurance companies typically impose mortality and expense charges and surrender charge periods. In
an exchange of an existing annuity for a new annuity (so-called 1035 exchanges), the new variable annuity may
have a lower contract value and a smaller death benefit; may impose new surrender charges or increase the
period of time for which the surrender charge applies; may have higher annual fees; and provide another
commission for the broker
Alternative Investments. When appropriate for a client’s objective, risk tolerance, and qualifications, CCW
recommends the Client participate in private issues, such as single purpose vehicles, funds of funds, private
equity, and hedge funds. These are usually structured as limited partnerships with differing minimum
investments, liquidity, fees, and carriers.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the
risks involved in an investment with CCW.
Item 9 – Disciplinary Information
CCW and its management have not been involved in any criminal or civil actions, administrative or self-
regulatory enforcement proceedings, nor any legal or disciplinary events that are material to a client’s or
prospective Client’s evaluation of CCW or the integrity of its management.
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Item 10 – Other Financial Industry Activities and Affiliations
CCW has no other financial industry activities or affiliations. Neither CCW nor its management persons are
registered as a broker-dealer or broker-dealer representative. Neither CCW nor its management persons are
registered as futures commission merchant, commodity pool operator, or a commodity trading advisor.
Relationships Material to this Advisory Business and Possible Conflicts of Interest
Investment Advisor Representatives of CCW receive external compensation from sales of investment-related
services as Insurance Agents. This represents a conflict of interest because it gives an incentive to recommend
services based on the fee amount received. This conflict is mitigated by disclosures, procedures, and CCW’s
fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required to engage
the Agent or Agency if they do not wish to. More information on this can be found in the respective Investment
Advisor Representative’s Form U4 and ADV 2B.
CCW does not utilize or select other advisors.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics
The affiliated persons (affiliated persons include employees and/or independent contractors) of CCW have
committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected
of CCW affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for
affiliated persons of CCW. The Code reflects CCW and its supervised persons’ responsibility to act in the best
interest of their client.
One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts
and how to mitigate any conflict of interest with our clients. We do not allow any affiliated persons to use non-
public material information for their personal profit or to use internal research for their personal benefit in
conflict with the benefit to our clients.
CCW’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information.
No advisory representative or other affiliated person, officer, or director of CCW may recommend any
transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a
security or its derivatives if the advisory representative possesses material, non-public information regarding
the security.
CCW’s Code is based on the guiding principle that the interests of the Client are our top priority. CCW’s officers,
directors, advisors, and other affiliated persons have a fiduciary duty to our clients and must diligently perform
that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation
to put the Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public
information regarding any Clients' purchase or sale of securities, or non-public information regarding the
portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients,
or who have access to such recommendations that are non-public.
CCW will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
Recommendations Involving Material Financial Interests
Neither CCW nor its related persons recommend to Clients, or buy or sells for Client accounts, securities in
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which CCW or a related person has a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
CCW and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options,
or futures) that CCW or an affiliated person recommends to Clients. In order to mitigate conflicts of interest,
such as frontrunning, CCW’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm
and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of affiliated
persons does not disadvantage Clients of CCW.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest
CCW and its affiliated persons may recommend securities, or buy or sell securities for Clients accounts, at or
about the same time, that they also buy or sell the same securities in their own account(s). CCW, for instance,
will place trades in an account in an attempt to earn better than money market rates. In order to mitigate
conflicts of interest, such as frontrunning, CCW’s Chief Compliance Officer, or their designee, will no less than
quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal
trading of affiliated persons does not disadvantage Clients of CCW.
Item 12 – Brokerage Practices
Selection of Brokers
CCW directs clients to establish brokerage accounts with the Schwab Advisor Services division of Charles
Schwab & Co., Inc. (Schwab), a FINRA-registered broker-dealer, member SIPC, to maintain custody of clients’
assets and to effect trades for their accounts. Although CCW recommends that clients establish accounts at
Schwab, it is the client’s decision to custody assets with Schwab. CCW is independently owned and operated
and not affiliated with Schwab.
Schwab provides CCW with access to its institutional trading and custody services, which are typically not
available to Schwab retail investors. These services generally are available to independent investment advisors
on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’
assets are maintained in accounts at Schwab Advisor Services. These services are not contingent upon CCW
committing to Schwab any specific amount of business (assets in custody or trading commissions). Schwab’s
brokerage services include the execution of securities transactions, 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.
For CCW, client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions and other transaction-related or asset-
based fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab Advisor Services also makes available to CCW other products and services that benefit CCW but may
not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some
substantial number of CCW’s accounts, including accounts not maintained at Schwab.
Schwab’s products and services that assist CCW in managing and administering clients’ accounts include
software and other technology that (i) provide access to client account data (such as trade confirmations and
account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client
accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of CCW’s fees from its
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clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting.
Schwab Advisor Services also offers other services intended to help CCW manage and further develop its
business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications
and conferences on practice management and business succession; and (iii) access to employee benefits
providers, human capital consultants, and insurance providers. Schwab may make available, arrange, and/or
pay third-party vendors for the types of services rendered to CCW. Schwab Advisor Services may discount or
waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to CCW. Schwab Advisor Services may also provide other benefits such as educational
events or occasional business entertainment of CCW personnel. In evaluating whether to recommend or
require that clients custody their assets at Schwab, CCW may take into account the availability of some of the
foregoing products and services and other arrangements as part of the total mix of factors it considers and not
solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create
a potential conflict of interest.
The Firm recognizes its responsibility to attain best execution and recognizes that limiting its custodial
relationships may affect its ability to provide best execution on a trade-by-trade basis. However, the Firm
evaluates its entire custodial relationship in assessing best execution on a client-by-client basis.
Research and Other Soft Dollar Benefits
CCW currently has no formal soft-dollar arrangements, where specific products or services are paid for with
soft dollars generated for the Firm by individual trades the Firm places in client accounts. However, the
custodian provides the Firm with certain brokerage and research products and services that qualify as
"brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934 ("Exchange Act").
Brokerage for Client Referrals
CCW does not receive Client referrals from any custodian or third party in exchange for using that broker-dealer
or third party.
Directed Brokerage
CCW does not allow Client directed brokerage.
Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution.
The determination of what may constitute best execution and price in the execution of a securities transaction
by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include
the overall direct net economic result to the portfolios, the efficiency with which the transaction is effected, the
ability to affect the transaction where a large block is involved, the operational facilities of the broker-dealer,
the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The
firm does not receive any portion of the trading fees.
Aggregating Trading for Multiple Client Accounts
When a client authorizes discretionary management, CCW is authorized in its discretion to aggregate purchases
and sales and other transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of CCW. All Clients participating in the aggregated order shall receive an average
share price with all other transaction costs shared on a prorated basis. If aggregation is not allowed or infeasible
and individual transactions occur (e.g., withdrawal or liquidation requests, odd-late trades, etc.) an account may
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potentially be assessed higher costs or less favorable prices than those where aggregation has occurred.
Item 13 – Review of Accounts
Frequency and Nature of Periodic Review and Who Makes Those Reviews
Account reviews are performed on an ongoing basis by the Firm’s Investment Advisor Representatives. Account
reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include,
but are not limited to, a review of Client documented risk tolerance, adherence to account objectives,
investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if
there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Financial plans are updated as requested by the Client and pursuant to a new or amended agreement, CCW
suggests updating at least annually.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment
information, and changes in a client’s own situation.
Content and Frequency of Regular Reports
CCW provides performance reports upon Client request. Clients also receive written account statements no
less than quarterly for managed accounts. Account statements are issued by the Client’s custodian. Client
receives confirmations of each transaction in account from Custodian and an additional statement during any
month in which a transaction occurs. Client should compare the CCW performance reports to their custodial
statements for accuracy and alert CCW to any discrepancies immediately.
Item 14 – Client Referrals and Other Compensation
CCW does not receive any economic benefits from external sources.
CCW may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with
CCW, which refer Clients to CCW in exchange for compensation. All such agreements will be in writing and
comply with the requirements of Federal or State regulation. If a client is introduced to CCW by a solicitor, CCW
may pay that solicitor a fee. While the specific terms of each agreement may differ, generally, the compensation
will be a flat fee per referral or a percentage of the introduced capital. Any such fee shall be paid solely from
CCW’s investment management fee and shall not result in any additional charge to the Client.
Each prospective Client who is referred to CCW under such an arrangement will receive a copy of this brochure
and a separate written disclosure document disclosing the nature of the relationship between the solicitor and
CCW.
Item 15 – Custody
All assets are held at qualified custodians, which means the custodians provide account statements directly to
Clients at least quarterly. Clients are urged to compare the account statements received directly from their
custodians to any documentation or reports prepared by CCW.
CCW is deemed to have limited custody solely because advisory fees are directly deducted from the Client’s
accounts by the custodian on behalf of CCW.
CCW is deemed to have custody of funds for certain accounts where you have established a standing letter of
authorization (“SLOA”) that allows us to disburse funds upon your direction to one or more third parties that
you designate. We follow seven conditions set forth in the SEC's No-Action Letter on Custody, dated 2/21/2017,
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which allow us to avoid an annual surprise custody examination.
CCW is not affiliated with the custodian. The custodian does not supervise CCW, its employees, or activities.
Item 16 – Investment Discretion
Clients authorize CCW discretionary authority, via the Advisory Agreement, to determine, without obtaining
specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or
sold.
CCW allows Clients to place certain restrictions. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to CCW in writing.
The Client approves the custodian to be used, and the commission rates paid to the custodian. CCW does not
receive any portion of the transaction fees or commissions paid by the Client to the custodian.
Item 17 – Voting Client Securities
Clients will receive proxy voting information directly from the issuer and/or custodian of the security. Clients
will not receive any such proxy voting material from CCW. When assistance on voting proxies is requested by
the Client, CCW will provide recommendations to the Client. However, CCW will not have the authority to vote
proxies on behalf of the Client. If in the future CCW obtains authority to vote proxies, this Brochure will be
appropriately amended.
Item 18 – Financial Information
CCW does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in
advance.
At this time, neither CCW nor its management persons have any financial conditions that are likely to reasonably
impair its ability to meet contractual commitments to Clients. CCW has not been the subject of a bankruptcy
petition in the last ten years.
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