Overview
- Headquarters
- Claremont, CA
- Total Firm Assets
- $140 million
- Average High-Net-Worth Client Portfolio Size
- $1.9 million
- Minimum Account Size
- $5,000
Fee Structure
Primary Fee Schedule (CLAREMONT FINANCIAL DISCLOSURE BROCHURE AND SUPPLEMENTS)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | $2,000,000 | 0.75% |
| $2,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,875 | 1.19% |
| $5 million | $34,375 | 0.69% |
| $10 million | $59,375 | 0.59% |
| $50 million | $259,375 | 0.52% |
| $100 million | $509,375 | 0.51% |
Clients
- High-Net-Worth Share of Firm Assets
- 47.58%
- Number of High-Net-Worth Clients
- 35
- Total Client Accounts
- 540
- Discretionary Accounts
- 510
- Non-Discretionary Accounts
- 30
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 107806
Primary Brochure: CLAREMONT FINANCIAL DISCLOSURE BROCHURE AND SUPPLEMENTS (2026-07-21)
View Document Text
ITEM 1 – COVER PAGE
Claremont Financial Group, Inc.
464 North Indian Hill Blvd.
Claremont, CA 91711
909-624-9200
WWW.CLAREMONTFINANCIAL.COM
Form ADV, Part 2A Brochure
July 21, 2026
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Claremont Financial Group, Inc. (“CFG or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at 909-624-9200. The information in this
Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission
(“SEC”) or by any state securities authority.
Any reference to or use of the terms “registered investment advisor” or “registered,” does not imply
that CFG or any person associated with CFG has achieved a certain level of skill or training.
Additional information about Claremont Financial Group, Inc. is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 107806.
ITEM 2 – MATERIAL CHANGES
The purpose of this page is to inform you of any material changes since the previous version of this
Disclosure Brochure. If you are receiving this Disclosure Brochure for the first time this section may not
be relevant to you.
Material Changes
The following material changes have been made to this disclosure brochure since the last annual
amendment filing on February 26, 2025:
● Effective July 1, 2025, the Advisor is owned by Gaetano H. Scalzo.
● The Advisor has amended its fee schedule to reflect that financial services provided by Gaetano
Scalzo are charged at a rate of $250 per hour. Please see Item 5 for additional information.
● The Advisor has disclosed its practices regarding standing letters of authorization for money
movement. Please see Item 15 for more information.
● The Advisor no longer compensates promoters for professional referrals. Please see Item 14 for
more information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and
if a material change occurs in the business practices of CFG.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#
107806. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor
at 909-624-9200.
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ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE
1
ITEM 2 – MATERIAL CHANGES
2
ITEM 3 – TABLE OF CONTENTS
3
ITEM 4 – ADVISORY BUSINESS
5
Description of Advisory Firm
5
Advisory Services Offered
5
Tailored Services and Client Imposed Restrictions
7
Wrap Fee Program
8
Assets Under Management
8
ITEM 5 – FEES AND COMPENSATION
8
Fee Schedule
8
Other Fees and Expenses
10
Termination
10
Other Compensation
11
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
11
ITEM 7 – TYPES OF CLIENTS
11
Account Requirements
12
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
12
Financial Planning
12
Methods of Analysis and Investment Strategies
12
Investing Involves Risk
13
Specific Security Risks
14
ITEM 9 – DISCIPLINARY INFORMATION
14
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
15
Registered Representative of Unaffiliated Broker-Dealer
15
Insurance Agency Affiliations
15
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
15
Code of Ethics
15
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ITEM 12 – BROKERAGE PRACTICES
16
Factors Considered in Selecting Broker-Dealers for Client Transactions
16
Aggregation and Allocation of Transactions
17
ITEM 13 – REVIEW OF ACCOUNTS
17
Managed Account Reviews & Reports
17
Financial Plan Reviews & Reports
18
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
18
ITEM 15 – CUSTODY
19
ITEM 16 – INVESTMENT DISCRETION
19
ITEM 17 – VOTING CLIENT SECURITIES
20
ITEM 18 – FINANCIAL INFORMATION
20
Form ADV, Part 2B (“Brochure Supplements”)
21
Privacy Policy
24
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ITEM 4 – ADVISORY BUSINESS
Description of Advisory Firm
Claremont Financial Group, Inc. (“CFG” or the “Advisor and also “we”, “our” or “us”) is a privately-
owned corporation headquartered in Claremont, California. CFG is registered as an investment advisor
with the U.S. Securities and Exchange Commission (“SEC”). CFG was founded in January 1994 and has
been registered as an investment advisor since February 2006. Gaetano H. Scalzo is the owner of CFG.
Advisory Services Offered
CFG offers personal financial planning and investment management services to individuals, high net
worth individuals, trusts, estates and charitable organizations (each a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest. CFG’s fiduciary commitment is further described in the Advisor’s
Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
Personal Financial Planning Services
CFG offers personal financial planning services for a fee. We specialize in providing advice to
professionals, pre-retirees and those who are retired. CFG uses financial strategies consistent with the
Client's financial condition, tax status, and risk/reward objectives. Strategies may focus on investments,
insurance, taxes, and/or estate plans.
Over the series of planning meetings, we compile written information and analysis, which may include
one or more of the following areas:
1. the Client's objectives and financial goals,
2. a review of the Client's assets, liabilities, income and expenses,
3. a review, analysis and recommendations regarding one or more of the subject planning areas
previously listed,
4. a summary of findings, and
5. an action guide or "To Do" list.
Personal financial planning (the analysis, written report, and subsequent modifications and services) is a
service separate from our investment management services. Clients have full discretion as to how they
choose to implement the recommendations discussed in the financial planning phase. CFG will generally
recommend implementation of financial plans, using CFG or an affiliate as the investment advisor. There
are no requirements to use us, or our affiliate, for investment management services.
The investment management services, described below, are part of the implementation process that
occurs once the initial planning has been accomplished. Use of our investment management services is
not required. Some Clients may use the services of CFG only for the financial planning; others may
choose to use CFG only for investment management services. Many Clients engage CFG for both of
these services.
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Our personal financial planning services do not include preparation of any kind of income tax, gift, or
estate tax returns nor preparation of any legal documents, including wills or trusts. We do not provide
Clients with any legal or accounting advice.
We describe fees charged for personal financial planning services in Item 5 below.
Investment Management Services
CFG offers asset allocation systems through third-party providers (“Investment Platforms”) including
Envestnet Asset Management, Inc. (“Envestnet”), and Orion Platform Services, LLC (“Orion”). We will
use a sub-advisor to manage portfolios for Clients where an asset allocation system is not suitable for a
Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the
overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client."
Third-Party Managed Account Programs
CFG, pursuant to separate agreements with Envestnet and Orion, offers asset allocation programs.
These programs allow Advisory Persons to choose from a selection of advisory programs and related
services that Envestnet and Orion provide. These programs allow Clients; in conjunction with Advisory
Persons; to independently select the discretionary investment advisory services of certain professional
portfolio management firms for the individual management of Client accounts and utilize third party
models including automated rebalancing of portfolios.
Use of Independent Managers
CFG may recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio,
based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and
due diligence over each Independent Manager to ensure the strategy remains aligned with Clients
investment objectives and overall best interests. The Advisor will also assist the Client in the
development of the initial policy recommendations and managing the ongoing Client relationship. The
Client, prior to appointment with an Independent Manager, will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate
disclosures).
Through these Investment Platforms, we advise Clients as to the selection of asset allocation models and
provide continuous monitoring of the models. We describe the material investment risks under the
heading Specific Security Risks in Methods of Analysis, Investment Strategies, and Risk of Loss.
We discuss our discretionary authority below under Item 16 – Investment Discretion. For more
information about the restrictions Clients can put on their account[s], see Tailored Services and Client
Imposed Restrictions in this item below.
We describe the fees charged for investment management services in Item 5 below.
Limitations on Investments – In some circumstances, CFG’s advice may be limited to certain types
of securities.
Limitation by Issuer – In the event CFG is managing assets within an annuity, CFG is limited to
those investment options chosen by the insurance agency.
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No Load Mutual Funds – The vast majority of mutual fund investments we recommend are in the form
of no load or load waived mutual funds.
Limitation by Client – CFG may also limit advice based on certain Client-imposed restrictions. For more
information about the restrictions Clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this Item below.
Non-Managed Assets – CFG may offer securities trading activities for non-managed positions in a
Client’s managed account[s], acting as an intermediary between the Client and the custodian. We do not
provide investment advice regarding that portion of the Client’s managed account designated as non-
managed assets nor do we provide opinions as to the merits of any non-managed asset held in the
account[s]. We also do not make any judgments as to the appropriateness of assumed risk or suitability
of any non-managed investment given the Client’s situation. CFG offers this service at no charge and at
our discretion, in consideration of the Client’s other accounts that we manage.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA
retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the
meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to
be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a
distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a
similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based
account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase
its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will CFG accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional
information, please see Item 12 – Brokerage Practices.
Tailored Services and Client Imposed Restrictions
CFG manages Client accounts based on the investment strategy the Client chooses, as discussed below
under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss. CFG applies the selected
strategy for each Client based on the Client’s individual circumstances and financial situation. We make
investment decisions for Clients based on information the Client supplies about their financial situation,
goals, and risk tolerance. Our recommendations may not be suitable if the Client does not provide us
with accurate and complete information. It is the Client’s responsibility to keep CFG informed of any
changes to their investment objectives or restrictions.
Generally, CFG does not allow Clients to impose restrictions on investing in certain securities or types of
securities in the accounts. CFG reserves the right to not accept and/or terminate management of a
Client’s account[s] if we feel that a Client wants to put a restriction that limits or prevents us from
meeting or maintaining the Client’s investment strategy.
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Wrap Fee Program
CFG does not sponsor a wrap fee program in connection with their investment management services. A
wrap fee program is defined as any advisory program under which a specified fee or fees not based
directly upon transactions in a Client’s account is charged for investment advisory services (which may
include portfolio management or advice concerning the selection of other investment advisers) and the
execution of Client transactions. Whenever a fee is charged to a Client for services described in this
brochure (whether wrap fee or non-wrap fee), we will receive all or a portion of the fee charged.
A complete description of these programs and related fees, charges, when due and termination
procedures are described in the respective manager’s disclosure brochures, which you receive at or
prior to the time a third-party managed account is established.
Assets Under Management
As of December 31, 2025, CFG manages $139,962,948 in Client assets, $136,024,550 of which are
managed on a discretionary basis and $3,938,398 on a non-discretionary basis. Clients may request
more current information at any time by contacting the Advisor.
ITEM 5 – FEES AND COMPENSATION
Fee Schedule
Personal Financial Planning Services
CFG offers personal financial planning services at the hourly rates describe below, which are negotiable
depending on the nature and complexity of each Client’s circumstances. In these instances, we will
provide an estimate of the total hours required at the start of the relationship. CFG may also provide
services at a reduced rate or waive fees for certain Clients (such as employees and their immediate
family members). The current hourly rates charged to Clients are:
● Gaetano Scalzo – $250 / hour
● Senior Associate – $100 / hour
● Paraplanner – $75 / hour
● Clerical – $30 / hour
We believe that financial planning is an on-going process that should last a lifetime. After we conduct
the initial risk analysis, we present the recommendations to the Client. The on-going planning is an
important service as well. We may incorporate the cost of financial planning services into the
investment advisory fees for those Clients making use of CFG’s investment management services; see
below for description of services. For such Clients, there will be no additional charge for normal planning
services over and above the investment fees. Additional analysis may require additional charges and are
negotiable on a client-by-client basis.
We send an invoice to Clients for services provided under our hourly rates at the completion of each key
planning task for time incurred. The invoice is payable upon receipt and will include the fee calculation
and amount due. We typically do not collect fees in advance for financial planning services.
Investment Management Services
CFG charges an investment advisory fee for its investment management services. For Clients making use
of the investment management services provided by CFG, the amount of the investment advisory fee is
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based upon the total assets under management and billed quarterly, in advance of each calendar
quarter, based on the following schedule:
Assets Under Management
First $250,000
Next $250,000
Next $500,000
Next $1,000,000
Next $2,000,000
Annual Fee
1.50%
1.25%
1.00%
0.75%
0.50%
* In addition to CFG’s fee schedule noted above, all managed accounts are
subject to a 0.05% fee for broker-dealer oversight.
The investment advisory fee in the first quarter of service is prorated from the inception date of the
account[s] to the end of the first quarter. The Client’s fees will take into consideration the aggregate
assets under management with the Advisor. All securities held in accounts managed by CFG will be
independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
Third-Party Managed Account Programs - Orion
Clients making use of the investment management services provided by CFG and the asset allocation
services of Orion Investment Platform will be charged an investment advisory fee based upon the total
assets under management, at an annual rate of 1.50% for AUM of up to $250,000 payable to CFG.
In addition to CFG’s advisory fee, clients making use of the asset allocation services of Orion will be
charged an Administrative Fee of 0.45% annually; an annual Strategist Fee of 0.10% to 0.20%; and an
annual Custodian Fee of 0.20%, all of which are calculated by Orion, billed monthly, and payable to
Orion.
Third-Party Managed Account Programs - Envestnet
Fees charged for Third-Party Managed Account Programs shall be in addition to CFG’s investment
management fee. Envestnet’s Managed Account Program fees range from 0.04% to 0.12% based on the
dollar amount of the individual account with a platform fee minimum ranging from $40 to $50 per
account. The Investor Fee charged is calculated as an annual percentage of assets based on the market
value of the account at the end of month and is charged on a quarterly basis in advance and prorated to
the end of the month upon inception of the account. Fees are outlined in the Statement of Investment
Selection that is provided to Clients prior to investing. The combined fee with CFG shall not exceed 2% in
total. Clients will receive a copy of the managers Form ADV Part 2A, which provides greater detail
regarding the Third-Party Managed Account Program. Upon termination of any Account in a Third-Party
Managed Account Program, any prepaid, unearned fees will be promptly refunded on a pro-rata basis,
and any earned, unpaid fees will be due and payable.
Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a
Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of
interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will
only earn its investment advisory fee as described above. Independent Managers typically do not offer
any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level
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of assets placed under management with an Independent Manager. The terms of such fee arrangements
are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the
Independent Manager. The total blended fee, including the Advisor’s fee and the Independent
Manager’s fee, will not exceed 2.00% annually.
For Client accounts implemented through an Independent Manager, the Client’s overall fees will include
CFG’s investment advisory fee (as noted above) plus investment management fees and/or platform fees
charged by the Independent Manager. The Independent Manager will assume the responsibility for
calculating the Client’s fees and deducting all fees from the Client’s account[s].
In the event that a Client should wish to terminate their relationship with the Independent Manager, the
terms for the termination will be set forth in the respective agreements between the Client and that
Independent Manager. CFG will assist the Client with the termination and transition as appropriate.
Billing Method
With Client authorization, each Investment Platform will automatically calculate and withdraw the
Platform fee and CFG’s investment advisory fee from the Client’s account[s] held by an independent
custodian. The fees are calculated according to the method outlined in each Investment Platform’s Form
ADV 2A – Disclosure Brochure. Typically, the custodian withdraws these fees from the Client’s account[s]
during the first month of each quarter based on the Investment Platform’s instruction. All Clients will
receive brokerage statements from the custodian no less frequently than quarterly. The custodian
statement will show the deduction of the investment advisory fee and the Investment Platform fee. It is
the Client’s responsibility to verify the accuracy of the fee calculation. The custodian will not determine
whether the fee is properly calculated.
Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than CFG, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities
execution and custody fees charged by the Custodian, if applicable. The fees charged by CFG are
separate and distinct from these custody and execution fees.
In addition, all fees paid to CFG for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and
expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay
management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage
and account reporting), and a possible distribution fee. A Client may be able to invest in these products
directly, without the services of CFG but would not receive the services provided by CFG which are
designed, among other things, to assist the Client in determining which products or services are most
appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review
both the fees charged by the fund[s] and the fees charged by CFG to fully understand the total fees to
be paid. Please refer to Item 12 – Brokerage Practices for additional information.
Termination
Investment Management Services
Either party may terminate the advisory agreement, at any time, by providing written notice to the
other party. Upon termination, CFG will refund any prepaid, unearned advisory fees based on the
effective date of termination. Upon termination of the agreement, we will send the Client a prorated
refund of unearned advisory fees using the following formula: (Fees Paid) x (Days Remaining in
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Quarter)/(Total Number of Days in Quarter). The Client’s investment advisory agreement with the
Advisor is non-transferable without the Client’s prior consent.
Personal Financial Planning Services
In the event that either the Client or CFG wishes to terminate the financial planning agreement before
completion of the plan, either party may terminate the agreement, at any time, by providing written
notice to the other party. Upon notice of termination, CFG will provide you with an invoice for services
provided through the date of termination. If you paid fees in advance that were more than the amount
due for services, CFG will refund any unearned fees to you. The Client’s financial planning agreement
with the Advisor is non-transferable without the Client’s prior consent.
Other Compensation
CFG does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Certain Associated Persons are also registered representatives of Capital Investment Group, Inc. (“CIG”).
CIG is a registered broker-dealer (CRD No. 14752), member FINRA, SIPC. In one’s separate capacity as a
registered representative of CIG, an Associated Person will implement securities transactions under CIG
and not through CFG. In such instances, an Associated Person will receive commission-based
compensation in connection with the purchase and sale of securities. Compensation earned by the
Associated Person in one’s capacity as a registered representative is separate from the Advisor’s fees.
This practice presents a conflict of interest because an Associated Person who is a registered
representative has an incentive to effect securities transactions for the purpose of generating
commissions rather than solely based on the Client’s needs. Clients are not obligated to implement any
recommendation provided by the Advisor nor Associated Persons. Neither the Advisor nor Associated
Persons will earn ongoing investment advisory fees in connection with any products or services
implemented in an Associated Person’s separate capacity as a registered representative. Please see Item
10 – Other Financial Industry Activities and Affiliations.
Certain Advisory Persons are licensed as independent insurance professionals. As an independent
insurance professional, an Advisory Person may earn commission-based compensation for selling
insurance products, including insurance products offered to Clients. Insurance commissions earned by
the Advisory Person are separate and in addition to investment advisory fees. This practice presents a
conflict of interest as an Advisory Person who is also an insurance professional will have an incentive to
recommend insurance products to the Client for the purpose of generating commissions rather than
solely based on the Client’s needs. Clients are under no obligation, contractual or otherwise, to purchase
insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
CFG does not charge performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a Client. CFG does not manage any proprietary investment funds or
limited partnerships (for example, a mutual fund or a hedge fund).
ITEM 7 – TYPES OF CLIENTS
CFG offers personal financial planning and investment management services to individuals, high net
worth individuals, trusts and charitable organizations. The amount of each type of Client is available on
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the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least
annually by the Advisor.
Account Requirements
For clients participating in the Envestnet third-party managed account programs, CFG requires the
following minimum account sizes:
Advisor as a Portfolio Manager Program: Minimum account size of $5,000
Unified Managed Account Program: Minimum account size of $10,000
Fund Strategist Portfolios Program: Minimum account size of $25,000
We generally combine family accounts to meet the account size minimum. We may reduce or waive the
account minimum requirements at our discretion.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Financial Planning
The financial planning tools CFG uses to create financial plans for Clients rely on various assumptions,
such as estimates of inflation, risk, economic conditions, and rates of return on security asset classes. All
return assumptions use asset class returns, not returns of actual investments, and do not include fees or
expenses that Clients would pay if they invested in specific products.
Financial planning software is only a tool used to help guide CFG and the Client in developing an
appropriate plan. CFG cannot guarantee that Clients will achieve the results shown in the plan. Results
will vary based on the information provided by the Client regarding the Client’s assets, risk tolerance,
and personal information. Changes to the underlying assumptions or differences in actual personal,
economic, or market outcomes may result in materially different results for the Client. Clients should
carefully consider the assumptions and limitations of the financial planning software as disclosed on the
financial planning reports. The Client should then discuss the results of the plan with a qualified
investment professional before making any changes in their investment or financial planning program.
We do not recommend individual securities to Clients. However, we may make a general
recommendation in the financial plan about investing a portion of your financial assets in securities. If
the financial plan includes recommendations for investing in securities, you should understand that
investing in securities involves risk of loss, and you should be prepared to bear that risk.
Methods of Analysis and Investment Strategies
CFG’s general investment strategy is to seek real capital growth proportionate with the level of risk the
Client is willing to take. CFG treats each Client account uniquely. Generally, CFG assists Clients to
develop an investment policy statement. Topics addressed in a typical investment policy statement may
include the investment goals, time horizon, risk tolerance, tax considerations, frequency and type of
monitoring and reporting, criteria for investment selection and overall investment strategy.
We design the investment recommendations to satisfy a hierarchy of needs, the first of which is the
Client's need for short-term cash flow and liquidity. To meet this requirement CFG recommends a level
of short-term reserve funds and suggest appropriate investment vehicles. We then generally make
recommendations geared to towards the long-term with emphasis placed on liquidity. We select
investments for long-term growth or income potential. However, ones that are readily converted to
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cash, should warrant unforeseen circumstances. After these first two needs appear satisfied, we place
the emphasis for the Client's remaining funds on long-term investments without regard to liquidity. Tax
reduction strategies may also play an important role in these recommendations.
We typically recommend Clients invest through various Investment Platforms. The Investment Platforms
offer model portfolios of mutual funds, exchange traded funds (ETF's), bonds, and variable annuity sub-
accounts which are provided by a number of institutional investment strategists and based on the
information, research, asset allocation methodology and investment strategies of these institutional
strategists.
With respect to Clients investing through an Investment Platform, CFG introduces Clients to investment
managers or retains sub-advisors who provide discretionary management of individual portfolios.
Investment Platform providers use a variety of methods of analysis, sources of information, and
investment strategies in the management of Client accounts. Details of their methods, sources, and
investment strategies are outlined in the Investment Platform’s ADV 2A – Disclosure Brochure, which
are provided to Clients engaging those services.
Investment Strategies for Managing Portfolios
CFG may use strategic asset allocation, tactical asset allocation, cash as a strategic asset, and/or long-
term holding in the construction and management of Client portfolios.
Strategic Asset Allocation – Strategic asset allocation involves periodically rebalancing portfolio in order
to maintain a long-term goal for asset allocation regardless of the market conditions.
Tactical Asset Allocation – Tactical asset allocation is an active management portfolio strategy that re-
balances the percentage of assets held in various asset categories in an effort to take advantage of
market pricing anomalies or strong market sectors. This strategy provides an opportunity for CFG to
create extra value by taking advantage of certain situations in the marketplace. CFG considers this a
moderately active strategy since we return the portfolio to its original strategic asset mix if we achieve
desired short-term profits or the perceived opportunity ends.
Cash as a Strategic Asset – CFG may use cash as a strategic asset and may at times move or keep Client’s
assets in cash or cash equivalents. While high cash levels can help protect a Client’s assets during
periods of market decline, there is a risk that our timing in moving to cash is bad either upon exit or re-
entry into the market and we miss positive market moves.
Long-term Holding – CFG’s strategy consists of investing through an Investment Platform where the
model of the Investment Platform generally is purchasing, holding, and rebalancing a diversified
portfolio of securities. We typically intend to hold these investments for the long term except when
sales are necessary to rebalance the portfolio or to fund replacement acquisitions.
Sources of Information – We may consult with specialists in financial planning, mutual funds, variable
annuities, and insurance products. We may also consult with the due diligence/investment research
staff who reviews the products of various companies.
Investing Involves Risk
Investing in securities involves risk of loss, and Clients should be prepared to bear that risk.
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Specific Security Risks
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as
well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance
of the overall financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of
the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition,
ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity
risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based
upon the market movements and may dissociate from the index being tracked by the ETF or the price of
the underlying investments. An ETF purchased or sold at one point in the day may have a different price
than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The
price of the mutual funds will fluctuate with the value of the underlying securities that make up the
funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in
the day will typically have the same price as a mutual fund purchased later that same day.
General Risks of Owning Securities
The prices of securities held in Client accounts and the income they generate may decline in response to
certain events taking place around the world. These include events directly involving the issuers of
securities in a Client’s account, conditions affecting the general economy, and overall market changes.
Other contributing factors include local, regional, or global political, social, or economic instability and
governmental or governmental agency responses to economic conditions. Finally, currency, interest
rate, and commodity price fluctuations may also affect security prices and income.
Third-Party Investment Advisors and Sub-Advisors Strategies and Risks
The independent third-party investment advisors that we select to be sub-advisors to Client’s portfolio
will use their own investment process and methods of analysis. The strategies and securities these
managers invest in may have different or additional risks than those described in this brochure. Clients
can find more information about the strategies and related risks of the sub-advisors in Item 8 – Methods
of Analysis, Investment Strategies and Risk of Loss in each manager’s Form ADV 2 Brochure.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded
to discuss these risks with the Advisor.
ITEM 9 – DISCIPLINARY INFORMATION
CFG and our Associated Persons seek to maintain the highest level of business professionalism, integrity,
and ethics. CFG does not have any disciplinary information to disclose. CFG values the trust you place in
us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or
service provider with whom you partner. Our backgrounds are available on the Investment Adviser
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Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#
107806.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Registered Representative of Unaffiliated Broker-Dealer
As noted in Item 5, certain Associated Persons are also registered representatives of CIG. In one’s
separate capacity as a registered representative, an Associated Person will receive commissions for the
implementation of recommendations for commissionable transactions. This practice presents a conflict
of interest because an Associated Person who is a registered representative has an incentive to effect
securities transactions for the purpose of generating commissions rather than solely based on the
Client’s needs. Clients are not obligated to implement any recommendation provided by an Associated
Person. Neither the Advisor nor an Associated Person will earn ongoing investment advisory fees in
connection with any services implemented in an Associated Person’s separate capacity as a registered
representative. Client advisory accounts of CFG are maintained separately from client brokerage
accounts of CIG.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from one’s role with the Advisor. As an insurance
professional, the Advisory Person will receive customary commissions and other related revenues from
the various insurance companies whose products are sold. Advisory Persons are not required to offer
the products of any particular insurance company. Commissions generated by insurance sales do not
offset investment advisory fees. This presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by
the Advisor or Advisory Persons.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
CFG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with CFG ( “Associated Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties
to the Client. CFG and its Associated Persons owe a duty of loyalty, fairness and good faith towards each
Client. It is the obligation of CFG associates to adhere not only to the specific provisions of the Code, but
also to the general principles that guide the Code. The Code covers a range of topics that address
employee ethics and conflicts of interest.
CFG’s Code attempts to address specific conflicts of interest that either we have identified or that could
likely arise. CFG’s Associated Persons are required to follow clear guidelines from the Code such as areas
of prohibitions of insider trading and adherence to applicable federal securities laws. Additionally,
individuals who make investment decisions/securities recommendations to Clients, or who have access
to nonpublic information regarding any Clients’ purchase or sale of securities, are subject to personal
trading policies governed by the Code (see below).
CFG will provide a complete copy of the Code to any Client or prospective Client upon request.
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Personal Trading Practices
CFG and our Associated Persons may purchase or sell securities for themselves, regardless of whether
the transaction would be appropriate for a Client’s account. CFG and our Associated Persons may
purchase or sell securities for themselves that we also recommend for Clients. This includes related
securities (e.g., warrants, options, or futures). This presents a potential conflict of interest as we may
have an incentive to take investment opportunities from Clients for our own benefit, favor our personal
trades over Client transactions when allocating trades, or to use the information about the transactions
we intend to make for Clients to our personal benefit by trading ahead of Clients.
Our policies to address these conflicts include the following:
1. We use third-party Investment Platforms and/or sub-advisors for management of all Client
accounts. Therefore, we are not aware of the timing of when trades are placed.
2. Our Associated Persons are required to submit quarterly and annual reports regarding
transactions and securities holdings in their personal accounts.
ITEM 12 – BROKERAGE PRACTICES
CFG requires Clients to open one or more custodian accounts in their own name at a third-party
custodian. We require Clients open such accounts at Charles Schwab & Co., Inc. (“Schwab”). We are
independently owned, operated, and are not affiliated with Schwab. Schwab will hold Client assets in a
brokerage account, and buy and sell securities when the third-party platform provider or we instruct
them to.
Factors Considered in Selecting Broker-Dealers for Client Transactions
CFG considers several factors in recommending a Custodian/Broker to a Client. We first determine which
platform or sub-advisor will be used to service the Clients account. Each Investment Platform has
relationships with one or more Custodian/Brokers and will require the Client to select a
Custodian/Broker that they have an arrangement with. Other factors that we may consider include ease
of use, reputation, service execution, pricing and financial strength of the Custodian/Brokers. CFG may
also take into consideration the availability of the products and services received or offered (detailed
below) by Custodian/Brokers.
Research and other Soft Dollar Benefits
CFG may receive from particular Custodian/Brokers, without cost (or at a discount), support services
and/or products that benefit CFG but may not directly benefit our Clients’ accounts. Custodian/Brokers
make available products and services that may be used to service all or some substantial number of
CFG’s accounts, including accounts not maintained with these brokers. Custodian/Brokers make these
products and services available to us on an unsolicited basis.
Custodian/Brokers may make available products and services that assist CFG in managing and
administering Clients’ accounts including software and other technology that:
1. provide access to Client account data (such as trade confirmations and account statements);
2. facilitate trade execution and allocate aggregated trade orders for multiple Client accounts;
3. provide research, pricing and other market data;
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4. facilitate payment of CFG’s fees from our Clients’ accounts; and
5. assist with back-office functions, recordkeeping, and Client reporting.
Custodian/Brokers may also offer other services intended to help CFG manage and further develop our
business enterprise. These services may include:
1. compliance, legal and business consulting;
2. publications and conferences on practice management and business succession; and
3. access to employee benefits providers, human capital consultants, and insurance providers.
Custodian/Brokers may make available, arrange, and/or pay third-party vendors for the types of services
provided to CFG. Custodian/Brokers 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 CFG.
Custodian/Brokers may also provide other benefits such as educational events.
As part of our fiduciary duty to Clients, CFG endeavors at all times to put the interests of our Clients first.
Clients should be aware, however, that the receipt of economic benefits by CFG or our Associated
Person in and of itself creates a potential conflict of interest and may indirectly influence CFG's
recommendation of Custodian/Brokers for custody and brokerage services.
Directed Brokerage
CFG will not allow Clients to direct CFG to use a specific broker-dealer to execute transactions other
than Charles Schwab. Clients must use the broker-dealers that CFG or platform provider recommends.
Not all investment advisors require their Clients to trade through specific brokerage firms. By requiring
Clients to use the broker-dealers that the Investment Platforms require, CFG believes we may be able to
more effectively manage the Client’s portfolio, achieve favorable execution of Client transactions and
lower the overall costs to the portfolio.
Aggregation and Allocation of Transactions
Either third-party Investment Platforms will implement transactions for each Client or a sub-advisor.
Clients should review the platform’s or the sub-advisor’s Form ADV 2 Brochure for information regarding
order aggregation and allocation of transactions.
ITEM 13 – REVIEW OF ACCOUNTS
Managed Account Reviews & Reports
Generally, each portfolio is reviewed every quarter by the Investment Platforms to evaluate the extent
to which the actual allocation matches the target allocation. We offer account reviews to Clients on a
quarterly basis. Clients may choose to receive reviews in person, by telephone, or in writing. Gaetano H.
Scalzo, ChFC®, Owner and Investment Advisor Representative, generally conducts all reviews based on a
variety of factors. These factors may include but are not limited to stated changes in the model,
investment objectives, economic environment, outlook for the securities markets, and the merits of the
securities in the accounts. Other members of CFG’s team might be involved in the review of accounts
from time to time.
In addition, we may conduct a special review of an account based on one or more of the following:
1. A change in the Client’s investment objectives, guidelines and/or financial situation;
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2. Changes in diversification;
3. Tax considerations; or
4. Material cash deposits or withdrawals.
Each Client receives a written statement from the custodian that includes an accounting of all holdings
and transactions in the account for the reporting period. In addition, certain platform providers may
provide written reports depending on platform the Client is working with. Details of the account
reporting that the third-party platform providers make available to Clients are outlined in each
provider’s Form ADV 2 Brochure. Applicable disclosure brochures are provided to Clients engaging those
services.
Financial Plan Reviews & Reports
Gaetano H. Scalzo, ChFC® (Owner and Investment Advisor Representative) is responsible for reviewing
Clients’ financial plans. Other members of CFG’s team might be involved in the review of financial plans
from time to time. CFG will generally contact Clients at least annually to discuss any changes in the
Client’s circumstances and necessary updates to the financial plan. We also work with Clients on an
ongoing basis to review the plan as needed or as requested by the Client. Clients receive a copy of all
written documents that are developed and discussed during the time we work together. Personal
financial planning generally includes the analysis, written report, and subsequent modifications and
services. The personal financial planning is a service separate from our investment management
services.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Participation in Institutional Advisor Platform – Schwab
CFG has established an institutional relationship with Schwab through its “Schwab Advisor Services”
unit, a division of Schwab dedicated to serving independent advisory firms like CFG. As a registered
investment advisor participating on the Schwab Advisor Services platform, CFG receives access to
software and related support without cost because the Advisor renders investment management
services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit
the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties
to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be
aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of
interest since these benefits may influence the Advisor's recommendation of this custodian over one
that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of Client’s funds and
securities. Through Schwab, the Advisor may be able to access certain investments and asset classes
that the Client would not be able to obtain directly or through other sources. Further, the Advisor may
be able to invest in certain mutual funds and other investments without having to adhere to investment
minimums that might be required if the Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate
statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support
services as part of its relationship with Schwab. These services are intended to assist the Advisor in
effectively managing accounts for its Clients but may not directly benefit all Clients.
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Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
CFG that may not benefit the Client, including: educational conferences and events, financial start-up
support, consulting services and discounts for various service providers. Access to these services creates
a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of
interest. CFG believes, however, that the selection of Schwab as Custodian is in the best interests of its
Clients.
Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised
persons, for Client referrals.
ITEM 15 – CUSTODY
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client
must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to
retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in
the account[s]. The Client should review statements provided by the Custodian, as the Custodian does
not perform this review. For more information about custodians and brokerage practices, see Item 12 –
Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the
Advisor may have custody of those assets. In order to avoid additional regulatory requirements, the
Custodian and the Advisor have adopted safeguards to ensure that the money movements are
completed in accordance with the Client’s instructions.
ITEM 16 – INVESTMENT DISCRETION
Clients electing to participate in the Investment Platforms offered by Envestnet or Orion will be required
to execute an investment advisory agreement with CFG granting CFG discretionary authority and limited
power of attorney with respect to the investment of the Client’s assets. With this discretionary
authority, we retain Envestnet as a sub-advisor or Orion as co-advisor to serve as discretionary money
manager with respect to the assets of Clients’ accounts and to perform the following services:
● buy, sell, invest, reinvest, convey, exchange, convert, transfer, redeem, liquidate or
otherwise dispose of securities in the assets of the Clients’ accounts in the platform without
notice to, or approval of, CFG or Clients, which are consistent with the model portfolios
selected by CFG on behalf of Clients;
● allocate investments within the chosen model portfolios, without distinction between
principal and income; and
● enter into agreements with Strategists and/or third-party managers to provide manage
model portfolios for the platform.
Clients who do not participate in the Investment Platforms will be required to execute an investment
advisory agreement with CFG granting CFG discretionary authority and limited power of attorney with
respect to the investment of the Client’s assets. With this discretionary authority, we retain Envestnet as
a sub-advisor.
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ITEM 17 – VOTING CLIENT SECURITIES
Proxy Voting and Class Actions
CFG does not accept or have the authority to vote Client securities. However, Clients may call us if they
have questions about a particular solicitation. CFG will not be deemed have proxy voting authority solely
because of providing advice or information about a particular proxy vote to a Client. Clients will receive
their proxies or other solicitations directly from their custodian or a transfer agent.
CFG does not instruct or give advice to Clients on whether or not to participate as a member of class
action lawsuits and will not automatically file claims on the Client’s behalf. However, if a Client notifies
us that they wish to participate in a class action, we will provide the Client with any transaction
information pertaining to the Client’s account[s] needed for the Client to file a proof of claim in a class
action.
ITEM 18 – FINANCIAL INFORMATION
Registered investment advisors are required in this item to provide Clients with certain financial
information or disclosures about the Advisor’s financial condition. CFG does not require the prepayment
of more than $1,200 in fees per Client, six months or more in advance, and does not foresee any
financial condition that is reasonably likely to impair our ability to meet contractual commitments to
Clients.
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Form ADV, Part 2B (“Brochure Supplement”)
Gaetano Henry Scalzo, ChFC®
Claremont Financial Group, Inc.
464 North Indian Hill Blvd.
Claremont, CA 91711
909-624-9200
July 21, 2026
This combined Form ADV2B (“Brochure Supplement”) provides information about Gaetano Henry Scalzo
and supplements the Claremont Financial Group, Inc. (“CFG” or the “Advisor”) Disclosure Brochure. You
should have already received a copy of that Disclosure Brochure. Please contact our office at 909-624-
9200 if you did not receive our Disclosure Brochure or if you have any questions about the contents of
this Brochure Supplement.
Additional information about Gaetano Henry Scalzo (CRD #7046528) is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with either individual’s full name or Individual CRD#.
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Gaetano Henry Scalzo, ChFC®
ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Gaetano Henry Scalzo, Owner and Investment Advisor Representative, b. 1996
Education:
Attended California State University Fullerton 2015-2020
Attended Orange Coast College 2017 to 2017
Business Background:
Claremont Financial Group, Inc. – Owner and Investment Advisor Representative, 11/2018 to Present
California State University Fullerton – Student, 08/2015 to 05/2020
Professional Designations
Gaetano Scalzo holds the following professional designation:
Chartered Financial Consultant™
The Chartered Financial Consultant™ (ChFC®) program prepares you to meet the advanced financial
planning needs of individuals, professionals, and small business owners. You'll gain a sustainable
advantage in this competitive field with in-depth coverage of the key financial planning disciplines,
including insurance, income taxation, retirement planning, investments, and estate planning. The ChFC®
requires three years of full-time, relevant business experience, nine two-hour course-specific proctored
exams, and 30 hours of continuing education every two years. Holders of the ChFC® designation must
adhere to The American College’s Code of Ethics.
Program Objectives:
● Function as an ethical, competent and articulate practitioner in the field of financial planning
● Utilize the intellectual tools and framework needed to maintain relevant and current financial
planning knowledge and strategies.
● Apply financial planning theory and techniques through the development of case studies and
solutions.
● Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate
planning, retirement planning, or non-qualified deferred compensation.
ITEM 3 – DISCIPLINARY INFORMATION
The Advisor values the trust you place in us. As we advise all Clients, we encourage you to perform the
requisite due diligence on anyone providing services to you. There are no legal or disciplinary events to
disclose regarding Gaetano H. Scalzo.
However, we do encourage you to independently view the background of Gaetano H. Scalzo on the
Investment Adviser Public Disclosure website at http://adviserinfo.sec.gov by searching with his full
name or Individual CRD# 7046528.
ITEM 4 – OTHER BUSINESS ACTIVITIES
Mr. Scalzo is also a registered representative with Capital Investment Group, Inc. (“CIG”). CIG is a non-
affiliated dually registered broker-dealer and a member of the Financial Industry Regulation Authority
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("FINRA"). In his own capacity as a registered representative of CIG, Mr. Scalzo will receive commissions
for the implementation of recommendations for commissionable transactions. This practice presents a
conflict of interest because Mr. Scalzo, as a registered representative, has an incentive to effect
securities transactions for the purpose of generating commissions rather than solely based on the
Client’s needs. Clients are not obligated to implement any recommendation provided by Mr. Scalzo.
Neither CFG nor Mr. Scalzo will earn ongoing investment advisory fees in connection with any services
implemented by Mr. Scalzo in his separate capacity as a registered representative. Client advisory
accounts of CFG are maintained separately from client brokerage accounts of CIG.
ITEM 5 – ADDITIONAL COMPENSATION
The additional compensation that Gaetano H. Scalzo may receive is outlined above in Item 4 above.
ITEM 6 – SUPERVISION
Mr. Scalzo is supervised by Bruce Davidson, Chief Compliance Officer. Mr. Davidson can be reached at
909-624-9200.
CFG has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of CFG. Further, CFG is subject to regulatory
oversight by various agencies. These agencies require registration by CFG and its Supervised Persons. As
a registered entity, CFG is subject to examinations by regulators, which may be announced or
unannounced. CFG is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
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Claremont Financial Group, Inc.
Privacy Policy
Effective: July 21, 2026
Claremont Financial Group, Inc.
CRD No: 107806
464 North Indian Hill Blvd
Claremont, CA 91711-4650
Phone: (909) 624-9200
www.claremontfinancial.com
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Our Commitment to You
Claremont Financial Group, Inc. (“CFG” or the “Advisor”) is committed to safeguarding the use of your
personal information that we have as your Investment Advisor.
CFG (also referred to as "we", "our" and "us" throughout this notice) protects the security and
confidentiality of the personal information we have and implements controls to ensure that such
information is used for proper business purposes in connection with the management or servicing of our
relationship with you. Our relationship with you is our most important asset. We understand that you
have entrusted us with your private information, and we do everything that we can to maintain that
trust.
CFG does not sell your non-public personal information to anyone. Nor do we provide such information
to others except for discrete and proper business purposes in connection with the servicing and
management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used
are set forth in this Privacy Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) share some of your personal information. Federal and State
laws give you the right to limit some of this sharing. Federal and State laws require RIAs to disclose how
we collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number
Name, address and phone number[s]
E-mail address[es]
Account information (including other institutions)
Assets and liabilities
Income and expenses
Investment activity
Investment experience and goals
What sources do we collect information from in addition to you?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical,
procedural and electronic safeguards. These include computer safeguards such as passwords, as well as
secured files and buildings. Our employees are advised about CFG's need to respect the confidentiality
of each client’s non-public personal information. We train our employees on their responsibilities
We require third parties that assist in providing our services to you to protect the personal information
they receive. This includes contractual language in our third-party agreements.
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How we share your information?
RIAs do need to share personal information regarding its clients to effectively implement the RIA’s
services. In the section below, we list some reasons we may share your personal information.
Sharing
Limitations
Basis For Sharing
Servicing our Clients
We may share non-public personal information with non-affiliated
third parties (such as brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law,
including but not limited to: processing transactions; general
account maintenance; responding to regulators or legal
investigations; and credit reporting.
CFG may share
this
information.
Clients
cannot limit
the Advisor’s
ability to
share.
CFG may share
this
information.
Clients
cannot limit
the Advisor’s
ability to
share.
CFG does not
share personal
information.
Clients
cannot limit
the Advisor’s
ability to
share.
CFG shares Client information with Capital Investment Group, Inc.
(“CIG”) due to the oversight CIG has over Supervised Persons of the
Advisor. You may also contact us at any time for a copy of the CIG
Privacy Policy.
Administrators
We may disclose your non-public personal information to
companies we hire to help administer our business. Companies that
we hire to provide services of this nature are not allowed to use
your personal information for their own purposes and are
contractually obligated to maintain strict confidentiality. We limit
their use of your personal information to the performance of the
specific service we have requested.
Marketing Purposes
CFG does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal
information with financial institutions where you are a customer
and where CFG or the client has a formal agreement with the
financial institution. We will only share information for purposes of
servicing your accounts, not for marketing purposes.
CFG does
share personal
information.
Authorized Users
In addition, your non-public personal information may also be
disclosed to you and persons that we believe to be your authorized
agent or representative.
Information About Former Clients
CFG does not disclose, and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to
persons who are no longer our clients.
CFG does not
share personal
information
regarding
former clients
Clients can
limit the
Advisor’s
ability to
share.
Clients can
limit the
Advisor’s
ability to
share.
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State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California
addresses do not want us to disclose personal information about you to non-affiliated third
parties, except as permitted by California law. We also limit the sharing of personal information
about you with our affiliates to ensure compliance with California privacy laws.
Changes to our Privacy Policy
We will send you a notice of our Privacy Policy annually for as long as you maintain an ongoing
relationship with us.
Periodically, we may revise our Privacy Policy, and will provide you with a revised policy if the changes
materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the
sharing of non-public personal information other than as described in this notice unless we first notify
you and provide you with an opportunity to prevent the information sharing.
Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current
Privacy Policy by contacting us at (909) 624-9200.
27
CFG Disclosure Brochure
Revised: July 21, 2026