Overview
- Headquarters
- Greenwood Village, CO
- Average Client Assets
- $4.1 million
- SEC CRD Number
- 331134
Fee Structure
Primary Fee Schedule (CAUSEY WEALTH LLC - ADV PART 2A DATED MARCH 30, 2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,500,000 | 1.00% |
| $1,500,001 | $3,000,000 | 0.85% |
| $3,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.60% |
| $10,000,001 | and above | 0.50% |
Minimum Annual Fee: $15,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $42,750 | 0.86% |
| $10 million | $72,750 | 0.73% |
| $50 million | $272,750 | 0.55% |
| $100 million | $522,750 | 0.52% |
Clients
- HNW Share of Firm Assets
- 92.85%
- Total Client Accounts
- 585
- Discretionary Accounts
- 517
- Non-Discretionary Accounts
- 68
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
Primary Brochure: CAUSEY WEALTH LLC - ADV PART 2A DATED MARCH 30, 2026 (2026-03-30)
View Document Text
Causey Wealth LLC | CRD No. 331134 | Form ADV: Part 2A (Firm Brochure) | Dated: March 30, 2026
Causey Wealth LLC
6400 S Fiddlers Green Circle, Suite 975
Greenwood Village, Colorado 80111
Form ADV: Part 2A
Firm Brochure
March 30, 2026
Additional information about Causey Wealth LLC is available on the SEC's website at www.adviserinfo.sec.gov.
This brochure provides information about the qualifications and business practices of Causey Wealth LLC. If you have any questions
about the contents of this brochure, please contact our office by email at info@causeywealth.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.
Our Form ADV Part 2B may be updated with immaterial changes between annual SEC filings. To obtain our latest filing or for
additional information, please visit https://adviserinfo.sec.gov/firm/summary/331134.
Causey Wealth LLC is registered as an investment adviser with the Securities and Exchange Commission. Registration with the SEC
does not imply a certain level of skill or training.
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ITEM 2 MATERIAL CHANGES
On July 28, 2010, the Securities and Exchange Commission (SEC) adopted amendments to Part 2 of Form ADV. These
amendments and related rules require Investment Advisers to provide a Firm Brochure (Disclosure Document) in a
narrative format.
The “Material Changes” section is used to provide our clients with a summary of any new and/or recently updated
information which is materially different from prior filings.
Our Firm Brochure is required to be updated no less than once annually within 90 days following the end of our fiscal year
(which ends on December 31st). Clients will be given a summary of any material changes within 120 days of that date.
If at any time a client would like to receive a complete copy of our current Firm brochure, please contact our office by
email at info@causeywealth.com or download from our website at www.causeywealth.com.
Material Changes – March 30, 2026
The following is a summary of material changes to this brochure and our other annual filings since our last annual update
dated March 31, 2025.
•
Item 5 (Fees and Compensation). We expanded our disclosure of additional costs borne by clients in connection
with their accounts, including fund operating expenses, custodial fees, and interest charges associated with
margin accounts and pledged asset lines of credit.
•
Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss). We expanded our risk disclosures to
address semi-liquid securities (interval funds and tender offer funds), margin and pledged asset line borrowing
risk, cybersecurity risk, key person risk, third-party service provider risk, and tax considerations.
•
Item 10 (Other Financial Industry Activities and Affiliations). We added disclosure of trustee and fiduciary
services and litigation consulting services provided by certain supervised persons.
•
Item 12 (Brokerage Practices). We added disclosure of products and services we receive from Schwab and our
trade aggregation practices.
•
Item 13 (Review of Accounts). We expanded our description of periodic and event-driven account reviews and
clarified the content of reports provided to clients.
•
Item 14 (Client Referrals and Other Compensation). We revised our compensation disclosure to describe the
firm's three compensation structures and the conflicts of interest they present.
•
Item 15 (Custody). We added Standing Letters of Authorization as a custody trigger and expanded our description
of safeguards for all four categories of deemed custody.
• Form 2B. We revised Form 2B to reflect the other business activities that certain supervised persons may engage
in beyond investment advisory services (e.g., trustee services and litigation consulting) and updated the
compensation disclosure to accurately describe how each supervised person is compensated.
• Form CRS. We revised Form CRS Item 3 to accurately describe how our financial professionals are compensated
and the conflicts of interest that result.
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TABLE OF CONTENTS
ITEM 3
Item 1
Cover Page ........................................................................................................................................... 1
Item 2
Material Changes ................................................................................................................................. 2
Item 3
Table of Contents ................................................................................................................................. 3
Item 4
Advisory Business ................................................................................................................................. 4
Item 5
Fees and Compensation ........................................................................................................................ 5
Item 6
Performance-Based Fees and Side-By-Side Management ....................................................................... 6
Item 7
Types of Clients .................................................................................................................................... 7
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 7
Item 9
Disciplinary Information ....................................................................................................................... 8
Item 10
Other Financial Industry Activities and Affiliations ................................................................................. 8
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 9
Item 12
Brokerage Practices ............................................................................................................................. 10
Item 13
Review of Accounts ............................................................................................................................ 13
Item 14
Client Referrals and Other Compensation ............................................................................................ 13
Item 15
Custody ............................................................................................................................................. 14
Item 16
Investment Discretion ........................................................................................................................ 16
Item 17
Voting Client Securities ....................................................................................................................... 16
Item 18
Financial Information ......................................................................................................................... 16
Item 19
Requirements for State-Registered Advisers ........................................................................................ 16
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ADVISORY BUSINESS
ITEM 4
Causey Wealth LLC (“Causey Wealth” or “the Firm”) is registered with the United States Securities and Exchange
Commission (the “SEC”) as a Registered Investment Adviser. Note that such registration does not imply a certain level of
skill or training.
Our Colorado-based firm was founded in 2024 when its principals spun the wealth management practice out of their prior
firm of which they were owners. Causey Wealth LLC is a privately held, wholly independent company owned by its
members, all of whom are current employees of the entity.
Our Wealth Management practice has multiple components:
Investment Advisory Services
1. Financial Planning
2.
3. Trust & Trustee Services
4. Litigation Support
Our financial planning and investment advisory practice works with individuals, trusts, estates, foundations, corporations
and other business entities, as well as pension and profit-sharing plans, towards achieving long-term financial planning
and investment goals. Our financial planning and investment management process has four distinct steps (all or some of
which may be followed):
1. We work closely with the client to construct a comprehensive financial plan which is referred to as a Personal
Financial Plan or Capital Sufficiency Analysis. The result of the financial plan guides the rate of return that will be
targeted in hopes of achieving the client’s long-term growth objectives and income needs. The targeted rate of
return considers the long-term impact of inflation on the client’s objectives. We refer to this adjusted return as
the real rate of return.
2. An Investment Policy Statement is developed that integrates the client’s risk tolerance and investment constraints
(such as need for current income) to the targeted real rate of return. A unique and customized strategy that is
believed to have a high likelihood of success in achieving the client’s individualized goals is then presented to the
client.
3. We utilize a diversified investment strategy, where we target a long-term Strategic Asset Allocation and use short-
term Tactical Asset Allocation changes (based on a three-to-five-year outlook) to capitalize on near- term market
opportunities.
4. Ongoing investment management requires that we correspond with our clients on a regular basis to review and
gauge performance relative to the agreed upon targeted real rate of return, as well as to discuss changing goals,
objectives, and income needs.
We believe that this process provides the foundation for the targeted investment strategy that is developed for all clients.
We believe that financial planning and investment advisory services require close and regular contact with our clients to
assess their changing needs and to develop strategies for reaching both short-term and long-term goals. In some cases, a
client may choose not to incorporate all the steps of the financial planning process described herein.
In employing our investment strategy, we utilize liquid investments such as mutual funds, exchange-traded funds,
individual stocks, fixed income (bond) investments, and cash or cash equivalents in our portfolios. Additionally, when
appropriate, we also utilize semi-liquid investments such as interval funds and tender offer funds.
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At times we consult with our clients on assets that they may bring to our management which are outside of those typically
used in our strategy. Causey Wealth LLC tailors its advisory services to the individual needs of our clients. Clients can
impose restrictions on investment in certain securities or certain types of securities. This is discussed in further detail in
Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss).
As of December 31, 2025, Causey Wealth LLC manages $365,974,929 on a discretionary basis and $27,226,081 on a non-
discretionary basis for individuals, trusts, estates, foundations, corporations and other business entities, non-profit
organizations and/or pension and profit-sharing plans.
FEES AND COMPENSATION
ITEM 5
Investment Advisory Fees
Causey Wealth LLC is compensated for the advisory services that we provide in the form of a management fee based upon
assets under management. In certain situations, the fee for our services can be in the form of a flat-fee retainer or based
on hourly charges. These rates are agreed upon in advance, and the advisory fee is billed in arrears on a quarterly,
semiannual, or annual basis depending upon the predetermined reporting arrangement between the client and the firm.
An invoice is sent to the client, and the client may choose to pay the invoice directly or provide authorization and instruction
to Causey Wealth LLC to deduct the fees directly from the client’s investment advisory account(s). Such fee deduction is
considered limited custody as described further in Item 15 (Custody).
Our standard advisory fee schedule is as follows:
-
-
-
-
$1,500,000
$3,000,000
$5,000,000
$10,000,000
Average Portfolio Value ($)
$0
$1,500,000
$3,000,000
$5,000,000
$10,000,000
Annual Rate
1.00%
0.85%
0.75%
0.60%
0.50%
Fees are calculated on the average of the month-end values of assets under management during the preceding billing
period. Investment assets not under our discretionary management are excluded from the fee calculation. Advisory fees
are billed in arrears on a quarterly, semiannual, or annual basis as agreed in the Investment Advisory Agreement. Because
fees are billed in arrears, clients do not pay fees in advance, and no refund calculation is necessary.
The minimum annual fee is $15,000. Fees may be reduced or modified based on the nature, complexity, and scope of
services provided. In no case will the annual advisory fee exceed 2.0% of assets under management.
Causey Wealth LLC receives no compensation other than the fees paid directly by its clients. No supervised person of the
Firm accepts commissions, sales charges, or other compensation for the sale of securities or investment products, other
than the non-monetary benefits discussed in Item 12 and Item 14.
These include the advisory fees described above and, where applicable, separately agreed-upon fees for other services
such as financial planning, litigation consulting, or trustee services. The Firm receives no commissions, no compensation
from product sponsors, and no portion of any fees, interest, or other charges assessed by the custodian, fund sponsors,
or any third party.
The following sections describe the additional costs that clients may bear in connection with the investments and services
in their accounts.
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Fund Expenses and Transaction Costs
Mutual funds, exchange-traded funds, interval funds, and tender offer funds held in client accounts carry their own
internal operating expenses, including management fees charged by the fund sponsor, which are described in each fund's
prospectus and are reflected in the fund's net asset value. Clients may also incur transaction fees and commissions, or
early redemption fees depending on the investment. These costs are borne by the client separately from the Firm's
advisory fee.
Custodial Fees
While the client is under no obligation to custody assets with the custodian recommended by Causey Wealth LLC, if the
client chooses to do so, there may be additional fees assessed by the custodian for the custody of assets or to effect
transactions. Alternative investments held through custodial alternative investment services may be subject to an annual
custody fee charged by the account custodian for maintaining and servicing those positions. See Item 12, Brokerage
Practices for more information on fees assessed by our custodians.
Margin Accounts and Pledged Asset Lines of Credit
‑
Client accounts may be established with margin capability to provide additional flexibility, such as helping ensure checks
and wire transfers clear in a timely manner accommodating short
term settlement timing needs. Margin availability is not
intended to be used as a strategy for leveraged investing. Clients should be aware that if a debit balance is carried in a
margin account, the account custodian will charge interest on the outstanding balance, and the securities in the account
will serve as collateral for the borrowing.
From time to time, clients may also establish pledged asset lines of credit to address liquidity needs. In these
arrangements, securities held in the client’s advisory account may serve as collateral for the line of credit. All interest
charges and other costs associated with margin borrowing or a pledged asset line are assessed by the lending institution
and are borne by the client.
Tax Considerations
Our management of client accounts may result in taxable events, including capital gains from the sale or exchange of
securities, taxable income from dividends and interest, and taxable income from retirement account distributions.
Additionally, tactical changes to a client's asset allocation, general portfolio rebalancing, liquidations to meet client cash
needs, and transitions of accounts into the Firm's management may each generate tax consequences. While the Firm
seeks to be mindful of tax implications in the management of client portfolios, investment decisions are driven primarily
by each client's investment objectives and overall financial plan, and the Firm does not manage accounts on a tax-
minimization basis. Clients are encouraged to consult with their tax professional regarding the tax implications of
investment decisions.
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
ITEM 6
Causey Wealth LLC does not accept performance-based fees.
Causey Wealth LLC is only compensated for its Investment Advisory services on a flat-fee retainer, hourly basis, or in the
form of an advisory fee based on a percentage of the assets under management.
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TYPES OF CLIENTS
ITEM 7
Causey Wealth LLC focuses on providing financial planning and investment advisory services to individuals, trusts, estates,
corporations and other business entities, pension and profit-sharing plans.
Causey Wealth LLC does not have any minimum requirements for opening or maintaining an account. However, as stated
in Item 5, the minimum annual investment advisory fee for individuals, trusts, estates, corporations and other business
entities, as well as pension and profit-sharing plans is $15,000 annually.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
ITEM 8
Causey Wealth LLC develops a unique and customized Investment Strategy for each Investment Advisory client. The
cornerstone of the client’s investment strategy is the Investment Policy Statement, which serves as the foundation for an
asset allocation which is believed to best permit the client to attain the long-term targeted rate of return necessary to
achieve their identified near-term and/or long-term investment growth and stated income goals.
Causey Wealth believes that asset class allocation, rather than individual security selection, is the primary determinant of
a portfolio's long-term risk and return. We seek to manage portfolio risk through broad global diversification and the use
of multiple investment managers and vehicles across asset classes. Based upon research into the historical performance,
behavior, and inter-relationships between asset classes, a strategic asset allocation is developed that we believe provides
a high probability of attainment of the rate of return goal established in the Investment Policy Statement.
We believe that the broad diversification inherent in our strategy and represented throughout our client portfolios
mitigates the risk of loss over the long term. However, no assurance can be given that any one security (or multiple
securities) could ultimately become worthless. Nor is there any guarantee that any Investment Policy developed for a
client will be successful.
We primarily utilize widely traded and regularly priced securities in the implementation of our investment strategy. In our
portfolios. This includes open-ended mutual funds, exchange-traded funds (ETFs), individual stocks, fixed income (bond)
investments (directly owned and through mutual funds), and cash or cash equivalents.
Where consistent with a client's investment objectives, risk tolerance, and liquidity needs, Causey Wealth LLC may also
utilize semi-liquid securities, including interval funds and tender offer funds, as part of the overall investment strategy.
These funds typically limit redemptions to periodic intervals (generally quarterly) and may further limit the amount
redeemed to a percentage of fund assets in any given period. As a result, a client's ability to liquidate a position may be
delayed or only partially fulfilled, particularly during periods of market stress when redemption requests may exceed the
fund's repurchase limits. Clients should understand that capital invested in these securities may not be fully accessible on
demand.
Clients may also choose to retain, or invest in, closely held securities which are brought to our management. In these
instances, we make a best effort to appropriately value these securities, which may be traded only on a limited basis, or
which may be completely illiquid, based on information provided to the client by the investment manager. In instances
such as these, we make an effort to incorporate the objectives and risks associated with said investments into our overall
strategy. The client should understand that any investment involves the risk of substantial volatility and the potential for
total loss. This may be further compounded by assets which are thinly traded or completely illiquid.
Investment Strategy and economic outlook is formulated by our Investment Committee, which meets on a regular basis
to develop a plan for each of our asset allocation models. Although each client is unique, each client portfolio is aligned
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with an asset allocation model that closely resembles their own asset allocation. The Investment Committee, whose
membership is the Firm’s investment adviser representatives, meets regularly to discuss economic data, market data,
asset class relative valuation, and other pertinent topics. The Investment Committee formulates an outlook from which
tactical changes are made to each of the strategic asset allocation models based on a near-term outlook of three to five
years. Our research process is both top-down (macro-economic oriented) and bottom- up (asset class based).
Clients may impose restrictions on investment in certain securities or certain types of securities. In such instances, it is
requested that the client provide such notification in writing. To the extent that such constraints present a conflict with
potentially achieving the goals as set forth in the financial plan, these will be discussed and documented.
Clients who borrow against their investment portfolios, whether through a pledged asset line of credit or a margin
account, should understand that such borrowing involves additional risk. If the value of the pledged or margined securities
declines, the client may be required to deposit additional securities or cash to satisfy a margin call or collateral
maintenance requirement. If such a requirement is not met, the lender or broker may liquidate some or all of the securities
in the account without prior notice to the Firm, which may result in the realization of capital gains and disrupt the client's
investment strategy and financial planning objectives.
Cybersecurity Risk. Investment Advisory firms, such as Causey Wealth LLC, rely in part on digital and network technologies
to conduct business. Such networks may be at risk of cyber-attacks that could potentially seek unauthorized access to digital
systems for purposes such as misappropriating sensitive client information, corruption of that data, or operational
disruption. Causey Wealth LLC. has policies and procedures in place to protect sensitive client information and evolves
these policies over time to protect against an ever-evolving threat landscape. Nevertheless, cyber incidents could
potentially occur and might, in some circumstances, result in unauthorized access to sensitive information about Causey
Wealth LLC and/or its clients.
Key Person Risk. Causey Wealth LLC is a small firm, and its investment management, financial planning, and client service
functions are carried out by a limited number of professionals. The loss or extended absence of one or more of these
individuals could affect the Firm's ability to manage client portfolios, execute investment decisions, or maintain its current
level of service. While the Firm maintains documented investment and operational processes and shared access to its
portfolio management and trading systems, clients should be aware that the Firm's size means individual personnel
changes may have a more pronounced effect on operations than at a larger organization.
Third-Party Service Provider Risk. Causey Wealth LLC relies on third-party service providers for functions that are critical
to the management of client accounts, including trade execution and asset custody (Charles Schwab & Co., Inc.), portfolio
rebalancing and trade management (Envestnet | Tamarac), and performance reporting and data services. A disruption in
service, system outage, data error, or security breach at any third-party provider could delay trade execution, produce
inaccurate account or performance information, or temporarily prevent the Firm from managing or monitoring client
portfolios. The Firm does not control the operations, technology infrastructure, or security practices of its third-party
service providers. While we evaluate our vendors, including periodic review of their data security and privacy practices,
and conduct regular audits of data within our portfolio accounting system, we cannot guarantee uninterrupted access to
these services, and events outside the Firm's control could adversely affect the management or reporting of client
accounts.
DISCIPLINARY INFORMATION
ITEM 9
Causey Wealth LLC has no disciplinary events.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
ITEM 10
Causey Wealth LLC is primarily engaged in providing investment advisory services as described in Item 4 of this brochure.
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The Firm is not registered as, and does not have a material relationship with, a broker-dealer, futures commission
merchant, banking institution, insurance company, or any other entity, other than as described below.
Certain of the Firm’s supervised persons engage in the following additional activities in connection with the Firm's advisory
business:
1. Trustee and Fiduciary Services. Certain investment adviser representatives and/or supervised persons of the Firm
may serve as trustee, co-trustee, executor, or personal representative for clients, their family members, or other
parties. These fiduciary appointments are made independently and do not require that the trust or estate also
maintain an investment advisory relationship with the Firm.
When a supervised person serves as trustee for a trust whose assets are also managed by the Firm, a conflict of
interest exists in that the Firm earns advisory fees on assets over which the supervised person also holds fiduciary
control, including authority over distributions and other transactions that could affect the value of assets under
management.
The Firm mitigates this conflict by requiring that the investment adviser representative and portfolio manager
assigned to the trust's advisory relationship be supervised persons who are not affiliated with the trust in a
fiduciary capacity. This separation ensures that the individuals providing investment advice and making portfolio
management decisions for the trust are independent of the individual exercising trustee authority.
Additional strategies to mitigate conflict include oversight by the Chief Compliance Officer, documentation and
approval of all trustee appointments as described in the Firm's compliance policies, and the use of an independent
qualified custodian (Charles Schwab) to hold trust assets.
2. Litigation Consulting and Expert Witness Services. The Firm and certain of its supervised persons may provide
litigation consulting, expert analysis, or expert testimony services in connection with legal matters involving
financial, investment, or marital dissolution issues. These engagements are conducted pursuant to separate
agreements and are billed at agreed-upon hourly or flat fee rates independent of an investment advisory
relationship.
Litigation consulting engagements do not affect the Firm's investment advisory recommendations or portfolio
management decisions for other clients. Time spent on litigation engagements is managed to ensure that advisory
clients continue to receive the level of service contemplated by their Investment Advisory Agreements.
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING
ITEM 11
As an SEC-registered investment adviser, Causey Wealth LLC owes a fiduciary duty to its clients. Causey Wealth LLC and
its employees have a duty of utmost good faith to act solely in the best interests of every client. Our clients entrust us with
the management of their assets which places a high standard on our conduct and integrity. Our fiduciary duty compels all
employees to act with the utmost integrity in all our dealings. This fiduciary duty is the core principle underlying our Code
of Ethics and Personal Trading Policy and represents the expectations for all interactions with our clients.
Our Code of Ethics consists of the following core principles:
1. The interests of clients will be placed ahead of the firm’s or any employee’s own interests.
2. Employees are expected to conduct their personal securities transactions in accordance with the firm’s Personal
Securities Trading Policy and will strive to avoid any actual or perceived conflict of interest with the client.
3. Employees will not take inappropriate advantage of their position with the firm.
4. Employees are expected to act in the best interest of each client.
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Investment adviser representative employees are subject to annual continuing education requirements.
5. Employees are expected to comply with all Federal Securities Laws and Regulations.
6.
Upon request, Causey Wealth LLC will provide a copy of the firm’s Code of Ethics and Compliance Program to any current
or prospective client.
The supervised employees of Causey Wealth LLC may purchase and/or sell the same securities as those recommended to
our clients. This may present a conflict. To mitigate any conflict, the firm maintains a strict written trading policy to ensure
that client interests are placed ahead of those of its employees. Supervised persons are required to report securities
transactions and holdings for all accounts in which the employee has a direct or indirect beneficial ownership interest.
This includes personal securities information of any family member living within the same household as the employee. All
supervised personnel are required to disclose trades placed in their accounts on quarterly basis and to provide a
comprehensive list of holdings initially at hire and annually thereafter.
BROKERAGE PRACTICES
ITEM 12
The Custodians and Brokers We Use
Causey Wealth does not maintain custody of your assets that we manage/advise on your behalf, although we may be
deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—
Custody). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We
recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the
qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage
account and buy and sell securities when we (or you) instruct them to do so. While we recommend that you use Schwab
as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account
agreement directly with them.
We do not open accounts for you, although we may assist you in doing so. Even though your account(s) is/are maintained
at Schwab, we can still use other brokers to execute trades for your account as described below (see “your brokerage and
custody costs”).
If you direct us to use a custodian or broker other than Schwab, we may be unable to aggregate your trades with those of
other clients, which may result in less favorable execution prices or higher transaction costs than would otherwise be
obtainable. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals
and other compensation). You should consider these conflicts of interest when selecting a custodian.
How We Select Brokers and Custodians
We select/recommend a custodian/broker that will hold your assets and execute transactions. When considering whether
the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers
and their services, we consider a wide range of factors, including:
1. Combination of execution services and asset custody services (generally without a separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for your account)
3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)
5. Availability of investment research and tools that assist us in making investment decisions
6. Quality of services including a “client-first” mentality
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7. Competitiveness of the price of those services (commission/margin rates, etc.) and willingness to negotiate.
8. Reputation, financial strength, security, and stability
9. Prior service to us and our clients
10. Availability of products and services that benefit us (see “Products and services available to us from Schwab”)
We do not consider client referrals in our selection of custodians or brokers.
Your Brokerage and Trading Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services
but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab
account. Certain trades (for example, many mutual funds, and U.S. exchange-listed equities and ETFs) may not incur
Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your
account in Schwab’s Cash Features Program. In rare cases where we choose to execute a trade with a different broker-
dealer, but where the securities bought, or the funds from the securities sold, are deposited (settled) into your Schwab
account, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade. These fees are
in addition to commission or other compensation you pay the executing broker-dealer. Because of this, to minimize your
trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides
execution quality comparable to other brokers or dealers. Although we are not required to execute all trade through
Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution”
of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above (see “How we select brokers/custodians”). By using another broker or dealer you may potentially pay
lower transaction costs.
Trade Aggregation
A significant portion of the Firm's trading activity involves open-end mutual funds and non-traded closed-end funds (such
as interval funds and tender offer funds) that transact at net asset value. Because these instruments execute at a single
published price regardless of order size or timing, trade aggregation is neither necessary nor applicable.
For exchange-traded securities, such as ETFs and individual equities, or for fixed income securities, the Firm may aggregate
purchase or sale orders into a single block trade when implementing a broad allocation change or coordinated activity
such as tax-loss harvesting across multiple client accounts. The decision to aggregate is based on the size of the combined
order relative to the security's average daily trading volume and prevailing market volatility. Aggregation is used when the
Firm believes that executing a single block order is more likely to achieve favorable execution than placing separate orders
that could move the market or result in meaningfully different fill prices across accounts. When orders are aggregated,
each participating account receives the same average execution price, and transaction costs are allocated proportionally
based on each account's participation in the trade. No account receives preferential treatment in the allocation of
aggregated trades.
Recognizing that each client portfolio is unique and managed in accordance with the client's individual Investment Policy
Statement, there are times when a trade is driven by a specific client's objectives, tax situation, or cash flow needs. In
those cases, we place a standalone order for that client's account rather than aggregating. The decision to aggregate or
place individually is made by the Firm's Co-Chief Investment Officers based on the number of accounts affected, whether
the trade is model-driven or client-specific, the liquidity profile of the security, and current market conditions.
Supervised Persons' personal accounts are never included in an aggregated client order.
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Products and Services Available to Us from Our Custodian
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us
and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services),
many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get
institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support
services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and
grow our business. Schwab’s support services are generally available at no charge to us. Following is a more detailed
description of Schwab’s support services:
1. Services that primarily benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment products
available through Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph
generally benefit you and your account.
2. Services that do not directly benefit you. Schwab also makes available to us other products and services that
benefit us but do not directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own
and that of third parties. We use this research to service all or a substantial number of our clients’ accounts,
including accounts not maintained at Schwab.
In addition to investment research, Schwab also makes available software and other technology that:
a. Provide access to client account data (such as duplicate trade confirmations and account statements)
b. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
c. Provide pricing and other market data
d. Facilitate payment of our fees from our clients’ accounts
e. Assist with back-office functions, record keeping, client reporting, and compliance
3. Services that generally benefit only us.
Schwab also offers other services intended to help us manage and further develop our business enterprise. These
services include:
a. Educational conferences and events
b. Consulting on technology and business needs
c. Providing compliance guidance and resources.
d. Publications and conferences on practice management and business succession
e. Access to employee benefits providers, human capital consultants, and insurance providers
f. Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services
to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party’s fees. Schwab
also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain
your account with Schwab, we would be required to pay for these services from our own resources.
We periodically utilize some or all of the services described above in the preceding three sections. We acknowledge that
these benefits present a potential conflict while simultaneously enhancing our ability to provide services to our clients.
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Our Interest in the Services Provided by Our Custodian
The availability of these services from Schwab benefits us because we do not have to produce or purchase them.
We do not pay directly for Schwab’s services. (These services are not contingent upon us committing any specific amount
of business to Schwab in trading commissions or assets in custody.) The fact that we receive these benefits from Schwab
is an incentive for us to recommend the use of Schwab rather than making such decision based exclusively on your interest
in receiving the best value in custody services and/or the most favorable execution of your transactions. This is a conflict
of interest.
We believe, however, that taken in the aggregate, our selection/recommendation of Schwab as custodian and broker is
in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services
(see “How we select brokers/custodians”) and not Schwab’s services that benefit only us.
REVIEW OF ACCOUNTS
ITEM 13
Client accounts are reviewed on a regular basis, no less than annually, based on the predetermined reporting period
agreed upon between the client and the investment adviser representative and as stipulated in the Investment Advisory
Agreement. Reviews are conducted by the client's assigned investment adviser representative and client service team,
under the supervision of the Co-Chief Investment Officers and the Chief Compliance Officer. The account is reviewed to
determine whether changes to the asset allocation are necessary based on changing market and economic conditions,
and to ensure that adequate liquidity is available to meet the client's expected cash flow needs.
Accounts are also reviewed in connection with periodic updates to the client's financial plan, which may address changes
in income, tax situation, estate planning, retirement projections, or other factors that affect the client's overall investment
strategy.
In addition to regularly scheduled reviews, accounts may be reviewed on a non-periodic basis when triggered by financial
planning updates, significant market events, material changes to a client's financial situation or investment objectives,
changes to tax law or regulatory requirements affecting the client's portfolio, or a specific client request.
Investment performance reports are generated for each client on a quarterly or semi-annual basis as specified in the
client's Investment Advisory Agreement and delivered concurrent with an Advisory Fee Statement detailing the fees
accrued during the period. Each delivery includes an invitation for the client to schedule a review meeting with their
assigned investment adviser representative to discuss the report, the account's performance, and any changes to the
client's financial circumstances or objectives. Clients may also request access to the Firm's Client Portal, which provides
on-demand access to account holdings, performance information, and related reporting.
All clients receive account statements directly from the independent qualified custodian (Charles Schwab & Co., Inc.) no
less than quarterly. These statements provide a detailed accounting of current holdings and all transactions that have
occurred since the prior statement. Clients should carefully review these custodian statements and compare them to any
performance reports received from the Firm.
CLIENT REFERRALS AND OTHER COMPENSATION
ITEM 14
Causey Wealth LLC nor any related person of the Firm directly or indirectly compensates any person or firm for client
referrals.
The firm's supervised persons and firm employees are compensated in different ways depending on their role:
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1. Firm owners receive a base salary and additional compensation through their ownership interest in the firm, the
value of which is derived primarily from firm revenue.
2. Salaried supervised persons receive a base salary and bonus compensation tied to firm revenue.
3. Certain supervised persons who directly manage client relationships may be compensated primarily through
revenue-sharing arrangements in which their compensation is directly linked to the advisory fees generated by
the clients they oversee.
These arrangements create a conflict of interest in that supervised persons have a financial incentive to grow or retain
client assets under management. This incentive is most direct for the firm's owners and for supervised persons. The firm
mitigates these conflicts through its fiduciary obligations, the use of client-specific Investment Policy Statements, and
oversight by our Investment Committee and Compliance Committee.
We receive an economic benefit from Schwab in the form of the support products and services it makes available to us
and other independent investment advisers whose clients maintain their accounts at Schwab. We benefit from the
products and services provided because the cost of these services would otherwise be borne directly by us. This creates
a conflict of which you should be aware. You should consider these conflicts of interest when selecting a custodian. These
products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12—
Brokerage Practices).
From time to time, representatives of third-party asset management firms whose investment products are recommended
or held in client portfolios may provide Causey Wealth LLC or its personnel with non-monetary benefits such as meals,
entertainment, event tickets, or access to investment conferences. These benefits are provided on a limited and periodic
basis and are not soft dollar arrangements. Such arrangements create a potential conflict of interest but do not influence
the Firm's investment recommendations. Investment decisions are made by the Investment Committee through a process
of quantitative and qualitative analysis conducted independently of any manager relationship, and the Firm maintains a
gifts and entertainment policy overseen by the Chief Compliance Officer that limits the value and frequency of benefits
personnel may accept.
CUSTODY
ITEM 15
Causey Wealth LLC believes that an understanding of whether a registered investment adviser has custody of client assets
is an important concept for all clients to understand. The Securities & Exchange Commission defines custody as “holding,
directly or indirectly, client funds or securities, or having any authority to obtain possession of them.” The SEC rules require
Investment Advisers with custody of client securities or funds to implement a set of controls designed to protect client
assets from being lost, misused, or misappropriated. Causey Wealth LLC has implemented such controls which are
summarized herein. Upon request, Causey Wealth LLC will provide a copy of the firm’s Custody Policies to any client or
prospective client. Under securities regulations, we are deemed to have custody of your assets if, for example, you
authorize us to instruct Schwab to deduct our advisory fees directly from your account or if you grant us authority to move
your money to another individual’s/business’ account.
Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least
quarterly, sent to the email or postal address you provided to Schwab. Because Causey Wealth LLC also provides periodic
performance reports, we urge you to compare those reports to the account statements you receive directly from
Schwab and to contact us immediately if you identify any discrepancies.
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For non-Schwab accounts (“Outside Assets”) that you have placed under our investment advisory services, statements will
be provided directly by the applicable third-party custodian or holding institution. You should review those statements
with the same care and promptly notify us of any discrepancies between statements you receive from outside
custodians and any performance reporting you receive from us.
It is our practice to require that client assets be held by an independent third-party custodian. By insisting on operational
independence at the custodial level and periodically requesting confirmation that account statements are being sent
directly to clients on a no-less-than-quarterly basis, we believe we have instilled meaningful safeguards against the
misappropriation of client assets.
Based on the definition of custody as defined by the Securities & Exchange Commission, we have determined that we may
have custody of client assets in the following situations:
1. Fee Deduction Authority. Clients may authorize Causey Wealth LLC to deduct advisory fees directly from their
investment accounts, which constitutes custody under the Custody Rule. The Firm's authority under this
arrangement is limited solely to the deduction of agreed-upon advisory fees as described in the client's Investment
Advisory Agreement. An Advisory Fee Statement detailing the fee calculation and amount incurred during the
reporting period is provided to each client concurrent with the Firm's performance reporting cycle. Fee deductions
are processed in the quarter following the applicable fee period. Clients may revoke fee deduction authorization
at any time.
2. Trustee and Fiduciary Appointments. Certain investment adviser representatives and/or related persons of
Causey Wealth LLC are periodically named in clients' estate planning documents and may be asked to serve as
executor/personal representative of a client's estate and/or to serve as a trustee/co-trustee of a testamentary
trust created upon the death of a client. A client may also ask that we serve as trustee/co- trustee of a living or
irrevocable trust. In these situations, Causey Wealth LLC is deemed to have custody of client assets.
3. Outside Assets Account Access. As part of its holistic approach to investment management, Causey Wealth LLC
may maintain electronic login credentials to client accounts held at institutions other than the Firm's primary
custodian. These may include employer-sponsored retirement plans, education savings accounts (e.g., 529s),
health savings accounts, or other accounts that fall within the scope of the Firm's management of the client's
overall investment portfolio. This access enables the Firm to monitor holdings, execute rebalancing transactions,
and coordinate asset allocation across the client's full range of investment accounts. Where this access permits
the Firm to initiate transactions or direct the movement of assets, it constitutes custody under the Custody Rule.
4. Standing Letters of Authorization. Certain clients have established Standing Letters of Authorization (SLOAs) that
permit Causey Wealth LLC to direct the transfer of funds or securities from the client's custodial account to a
designated third party. These instructions are provided by the client directly to the qualified custodian and include
the third party's name, account number, and address. The client may terminate or modify the SLOA at any time.
Because an SLOA grants the Firm authority to direct disbursements from a client account, it constitutes custody
under the Custody Rule. The Firm has implemented procedures consistent with SEC guidance governing SLOAs,
including confirmation by the custodian directly to the client and custodian reporting of all transfers made
pursuant to each authorization.
In any one of these situations, Causey Wealth LLC and its related persons are deemed to have custody because the adviser
has direct or indirect access to client funds or securities. Causey Wealth LLC has taken the necessary steps to assure
compliance with SEC Rules and Regulations related to the safeguarding of client assets of which we have custody. These
steps include:
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1. Requiring that all client assets be held in accounts titled in the name of the client(s) at an independent qualified
custodian.
2. Maintaining required records of client assets over which we have custody.
3. Assuring that the client/beneficiaries receive a statement no less often than quarterly from the operationally
independent third-party custodian of the assets detailing values and activity.
4. Engaging the services of an independent accountant to conduct a surprise examination of accounts where we
have custody (as required under rule 206(4)-2).
5. Maintaining accurate and current custody disclosures in the Firm's Form ADV as filed with the SEC.
INVESTMENT DISCRETION
ITEM 16
Causey Wealth LLC accepts discretionary authority to manage investment advisory client accounts as granted through
each client's Discretionary Authority Agreement, which is executed as an attachment to the client's Investment Advisory
Agreement. Clients also execute custodial account documentation with Charles Schwab & Co., Inc. authorizing the Firm to
effect transactions on their behalf. Discretionary authority is limited to the purchase, sale, and exchange of securities in
accordance with the client's Investment Policy Statement. Clients may impose limitations on this discretionary authority
at any time by providing written notice to the Firm.
VOTING CLIENT SECURITIES
ITEM 17
Without exception, Causey Wealth LLC does not vote proxies on behalf of clients. Discretionary authority does not extend
to proxy voting. All proxy materials received on behalf of a client account are to be sent directly to our client or a
designated representative of the client, who is responsible for voting the proxy.
Causey Wealth LLC personnel may answer client questions regarding proxy-voting matters in an effort to assist the client
in determining how to vote the proxy. However, the final decision of how to vote the proxy rests with the client.
FINANCIAL INFORMATION
ITEM 18
Causey Wealth LLC does not require or solicit prepayment of fees as our advisory fees are billed in arrears.
Causey Wealth LLC does not have any financial condition that is reasonably likely to impair the firm's ability to meet
contractual commitments to clients.
Causey Wealth LLC has not been the subject of a bankruptcy petition at any time during the past ten years.
REQUIREMENTS FOR STATE-REGISTERED ADVISERS
ITEM 19
Causey Wealth LLC is registered with the Securities and Exchange Commission. Causey Wealth LLC is not registered with
any State Securities or State Regulatory Authority as we are not required to be so registered (we may make notice filings to
State Regulators when obligated).
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Causey Wealth LLC | Form ADV: Part 2A (Firm Brochure) – 03.30.2026
Additional Brochure: CAUSEY WEALTH LLC - ADV PART 2B DATED MARCH 30, 2026 (2026-03-30)
View Document Text
Causey Wealth LLC | CRD No. 331134 | Form ADV: Part 2B (Brochure Supplement) | Dated: March 30, 2026
Causey Wealth LLC
6400 S Fiddlers Green Circle, Suite 975
Greenwood Village, Colorado 80111
Form ADV: Part 2B
Brochure Supplement
March 30, 2026
Additional information about Causey Wealth LLC's supervised persons is available online at www.adviserinfo.sec.gov.
This brochure provides information about the qualifications and business practices of Causey Wealth LLC. If you have any questions
about the contents of this brochure, please contact our office by email at info@causeywealth.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.
Our Form ADV Part 2B may be updated with immaterial changes between annual SEC filings. To obtain our latest filing or for
additional information, please visit https://adviserinfo.sec.gov/firm/summary/331134.
Causey Wealth LLC is registered as an investment adviser with the Securities and Exchange Commission. Registration with the SEC
does not imply a certain level of skill or training.
Page 1 of 5
Causey Wealth LLC | Form ADV: Part 2B (Brochure Supplement) – 03.30.2026
Causey Wealth LLC | CRD No. 331134 | Form ADV: Part 2B (Brochure Supplement) | Dated: March 30, 2026
Nathanael A. Koch
Educational Background and Business Experience
Title:
Owner, Member & Chief Compliance Officer
CRD No.:
3142229
Year of Birth: 1976
Education:
MBA Finance & Investment Management
University of Colorado, Denver, Colorado
BA Political Science,
University of Colorado, Boulder, Colorado
Background: Owner, Member, Chief Compliance Officer of Causey Wealth LLC
Managing Member of Causey Wealth since 2024. Mr. Koch joined the predecessor firm in 2007 as an
Investment Adviser Representative and Senior Manager where he ascended to Shareholder and
President for a period of 10 years. Prior to joining Causey, Mr. Koch spent nine years with a Denver,
Colorado-based Registered Investment Advisory firm. Mr. Koch provides services to clients in the
financial planning, investment advisory, trust and litigation support areas.
Additional information about Mr. Koch is available on the SEC's website at:
www.adviserinfo.sec.gov/individual/summary/3142229.
Disciplinary Information
None
Other Business Activities
Mr. Koch may serve as a trustee, co-trustee, executor, or personal representative for certain clients, and may provide
litigation consulting or expert witness services. These activities and the conflicts they present are described in Item 10
of the Firm's Form ADV Part 2A.
Additional Compensation
Mr. Koch receives compensation from the Firm that is based, in part, on the Firm's revenue. This arrangement and the
conflicts it presents are described in Item 14 of the Firm's Form ADV Part 2A.
Supervision
Mr. Koch is an Owner and Member of Causey Wealth LLC and is the Chief Compliance Officer and a member of the
Compliance Committee. Mr. Koch has direct supervisory authority over all of Causey Wealth LLC’s investment adviser
representatives and supervised persons, including himself.
Robb A. Stone, Co-Chief Investment Officer and member of the Compliance Committee, independently reviews Mr.
Koch's advisory activities from a compliance perspective.
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Robb A. Stone
Educational Background and Business Experience
Title:
Owner, Member & Co-Chief Investment Officer
CRD No.:
4035700
Year of Birth: 1975
Education:
BSBA Finance
University of Denver, Denver, Colorado
Background: Owner, Member, Co-Chief Investment Officer of Causey Wealth LLC
Managing Member of Causey Wealth since 2024. Mr. Stone joined the predecessor firm in 2013 as an
Investment Adviser Representative and Senior Manager where he ascended to Shareholder for a
period of 8 years. Prior to joining Causey, Mr. Stone was a Director with Credit Suisse where he
worked for fourteen years working with institutional asset managers. Mr. Stone provides services to
clients in financial planning, investment advisory, trust and litigation support areas.
Additional information about Mr. Stone is available on the SEC's website at:
https://adviserinfo.sec.gov/individual/summary/4035700.
Disciplinary Information
None
Other Business Activities
Mr. Stone may serve as a trustee, co-trustee, executor, or personal representative for certain clients, and may provide
litigation consulting or expert witness services. These activities and the conflicts they present are described in Item 10
of the Firm's Form ADV Part 2A.
Additional Compensation
Mr. Stone receives compensation from the Firm that is based, in part, on the Firm's revenue. This arrangement and
the conflicts it presents are described in Item 14 of the Firm's Form ADV Part 2A.
Supervision
Mr. Stone is an Owner and Member of Causey Wealth LLC and is a member of the Compliance Committee. As an
investment adviser representative and supervised person, his activities are supervised by the Chief Compliance
Officer.
Nathanael A. Koch, Chief Compliance Officer, reviews Mr. Stone’s advisory activities from a compliance perspective.
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Causey Wealth LLC | Form ADV: Part 2B (Brochure Supplement) – 03.30.2026
Causey Wealth LLC | CRD No. 331134 | Form ADV: Part 2B (Brochure Supplement) | Dated: March 30, 2026
Stephen T. Warren
Educational Background and Business Experience
Title:
Director of Investments & Co-Chief Investment Officer
CRD No.:
7709993
Year of Birth: 1993
Education:
BABA Finance
Washington State University, Pullman, Washington
Background: Director of Investments & Co-Chief Investment Officer
Mr. Warren began his career at the predecessor firm in 2016 as a Management Consultant,
transitioned to the Wealth Management group in 2019 as a Senior Analyst, and advanced to the role
of Manager in 2021. Upon the formation of Causey Wealth LLC in 2024, he assumed his current role
as Director of Investments and Co-Chief Investment Officer. His career experience includes working
with high-net-worth individuals and families, financial institutions, non-profit foundations, and state
and local governments in a variety of areas including investment advisory and fixed income
consulting. He is a member of the Firm's Investment Committee and provides investment advisory,
portfolio management and financial planning services to our client base.
Additional information about Mr. Warren is available on the SEC's website at:
https://adviserinfo.sec.gov/individual/summary/7709993.
Disciplinary Information
None
Other Business Activities
Not Applicable
Additional Compensation
Mr. Warren receives compensation from the Firm that is based, in part, on the Firm's revenue. This arrangement and
the conflicts it presents are described in Item 14 of the Firm's Form ADV Part 2A.
Supervision
Mr. Warren is an investment adviser representative and supervised person. As such his activities are supervised by the
Chief Compliance Officer.
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Causey Wealth LLC | Form ADV: Part 2B (Brochure Supplement) – 03.30.2026
Causey Wealth LLC | CRD No. 331134 | Form ADV: Part 2B (Brochure Supplement) | Dated: March 30, 2026
Timothy S. Itin, CFA
Educational Background and Business Experience
Title:
Regional Director – Mountain West
CRD No.:
1157867
Year of Birth: 1958
Education:
Bachelor of Arts, Economics Major
Dartmouth College
Background:
Regional Director – Mountain West with Causey Wealth since July 2025.
Mr. Itin joined Causey Wealth in July 2025 as an Investment Adviser Representative and as Regional
Director – Mountain West. He is a member of the Firm’s Investment Committee and provides
investment advisory, portfolio management and financial planning services to our client base. Prior to
joining Causey, Mr. Itin was Principal with Northside Capital Management where he spent twelve
years on the Investment Committee, handling portfolio management, asset allocation, and client
relationships. Prior to that, he was a Managing Director and a Founding Partner at Thomas Weisel
Partners, a growth-focused, full-service investment bank in San Francisco.
Additional information about Mr. Itin is available on the SEC's website at:
https://adviserinfo.sec.gov/individual/summary/1157867.
Disciplinary Information
None
Other Business Activities
Mr. Itin may serve as a trustee, co-trustee, executor, or personal representative for certain clients. These activities
and the conflicts they present are described in Item 10 of the Firm's Form ADV Part 2A.
Additional Compensation
Mr. Itin receives compensation from the Firm that is based, in part, on the Firm's revenue. This arrangement and the
conflicts it presents are described in Item 14 of the Firm's Form ADV Part 2A.
Supervision
Mr. Itin is an investment adviser representative and supervised person. As such his activities are supervised by the
Chief Compliance Officer.
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