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Item 1: Cover Page for Part 2A
of Form ADV: Firm Brochure
March 23, 2026
16810 Kenton Drive, Suite 200
Huntersville, NC 28078
704-987-3410
Firm Contact:
Rachel L. Posner, Chief Compliance Officer
Firm Website Address:
www.cwgadvisors.com
This Brochure provides information about the qualifications and business practices of Cornerstone Wealth
Group, LLC dba Cornerstone Wealth. If you have any questions about the contents of this Brochure, please
contact us by telephone at (704)987-3410 or email at compliance@cwgadvisors.com. The information in
this Form ADV 2A brochure (“Brochure”) has not been approved or verified by the United States Securities
and Exchange Commission or by any State Securities Authority. Additional information about Cornerstone
Wealth is available on the SEC’s website at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of Cornerstone Wealth
and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged
to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more
information on the qualifications of our firm and our employees.
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Item 2: Material Changes
SEC-registered investment advisers are required to provide their clients with a summary of material
changes to their Brochure since the time of their last annual updating amendment and offer to provide the
entire brochure free of charge. Our most recent prior annual updating amendment was filed in March 2025.
Since that time, we have revised our brochure as follows:
• We had no material changes to our business
We have made other stylistic revisions to the brochure. Clients are encouraged to review the Brochure in
its entirety. A free copy of our Brochure can be obtained by contacting us by telephone at (704)987-3410
or email at compliance@cwgadvisors.com. Additional information about Cornerstone Wealth is available
on the SEC’s website at www.adviserinfo.gov.
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Item 3: Table of Contents
Section:
Item 1
Item 2
Item 3
Item 4
Item 5
Item 6
Item 7
Item 8
Item 9
Item 10
Item 11
Page
1
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3
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Item
Cover Page for Part 2A of Form ADV: Firm Brochure
Material Changes
Table of Contents
Advisory Business
Fees & Compensation
Performance-Based Fees & Side-by-Side Management
Types of Clients
Methods of Analysis, Investment Strategy & Risk of Loss
Disciplinary Information
Other Financial Industry Activities & Affiliations
Code of Ethics, Participation, or Interest in Client Transactions
& Personal Trading
Brokerage Practices
Review of Accounts
Client Referrals & Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
Item 12
Item 13
Item 14
Item 15
Item 16
Item 17
Item 18
Supplement ADV Part 2B - Chief Investment Officer
Supplement Privacy Notice
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Item 4: Advisory Business
Introduction
Cornerstone Wealth Group, LLC (“Cornerstone Wealth,” the “Firm,” “we,” “us” or “our”) is an SEC Registered
Investment Adviser that is dedicated to providing individuals and other types of clients with a wide array
of investment advisory services.
Ownership
FOCUS FINANCIAL PARTNERS
Cornerstone Wealth is a part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically,
Cornerstone Wealth is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is
the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board
of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and
collectively, by investment vehicles affiliated with Clayton, Dubilier, & Rice, LLC (“CD&R”). Investment
vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because
Cornerstone Wealth is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point
investment vehicles are indirect owners of Cornerstone Wealth.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers, and
institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment
companies as disclosed on their respective Form ADVs.
CWG MANAGEMENT GROUP, LLC
Cornerstone Wealth is managed by Craig Rubrecht, Jeffrey Carbone, Clifford Hodge, Jonathan Brown,
Andrew Smith, and Joe Sweeney (“Cornerstone Wealth Principals”), pursuant to a management agreement
between CWG Management Group, LLC and Cornerstone Wealth. The Cornerstone Wealth Principals serve
as leaders and officers of Cornerstone Wealth and are responsible for the management, supervision and
oversight of Cornerstone Wealth.
Description of the Types of Advisory Services We Offer
Comprehensive Portfolio Management:
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We offer clients comprehensive portfolio management and financial planning/financial consulting
services. Our services are designed to assist clients in meeting their financial goals through the use of
financial investments. We conduct at least one, but sometimes more than one meeting (in person, if
possible, otherwise via telephone conference) with clients in order to understand their current
financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn,
we propose an investment approach to the client. We typically recommend that clients invest in
exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Where we deem
it appropriate, we also recommend that a portion of clients’ portfolios be invested by external managers
of separately managed accounts. Upon the client’s agreement to the proposed investment plan, we work
with the client to establish or transfer investment accounts so that we can manage the client’s portfolio
on a discretionary or non-discretionary basis. We invest client assets in accordance with a range of
models we have designed to meet our clients’ needs and risk tolerance. We usually do not allow clients
to impose restrictions on investing in certain securities or types of securities due to the level of difficulty
this would entail in managing their account. We review the accounts we manage for clients on a regular
basis. We may periodically rebalance or adjust client accounts under our management. If the client
experiences any significant changes to his/her financial or personal circumstances, the client must
notify us so that we can consider such information in managing the client’s investments.
We implement investment advice on behalf of certain clients in certain held-away accounts that are
maintained at independent third party custodians. These held-away accounts are often 401(k)
accounts, 529 plan and other assets that are not held at our primary custodians.
Th order management system that we use for held-away accounts is provided by Pontera Solutions, Inc.
We review, monitor, and manage these held-way accounts in an integrated way with client accounts
held at our clients’ primary custodian(s). Further information about this service is available in Item 5.
Managed 529s or Annuities:
We also offer management services to subaccounts of RIA based 529 plans, equity indexed annuities,
fixed annuities, or variable annuities. The investment services we can provide are limited to allowable
products and can be billed separately in accordance with the fee schedule listed below. The client on
these accounts will provide our firm with trading authorization; and, on a discretionary basis we will
reallocate the subaccounts within the client’s plan or annuity pursuant to investment objectives chosen
by the client. Our management fees are explained in the schedule listed below in Item 5, Fees &
Compensation.
Retirement Plan Consulting:
We provide retirement plan consulting services to employer plan sponsors on an ongoing basis.
Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising could include: sponsor services, investment services, plan
design, vendor management and/or participant services.
Cornerstone Wealth is a fiduciary under the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”) with respect to investment management services and investment advice provided
to ERISA plans, including ERISA plan participants. Cornerstone Wealth is also a fiduciary under section
4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment
management services and investment advice provided to individual retirement accounts (“IRAs”),
ERISA plans, and ERISA plan participants. As such, Cornerstone Wealth is subject to specific duties and
obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited
transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us
by the federal and state securities laws. As a result, you have certain rights that you cannot waive or
limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our
obligations under the federal and state securities laws or as a waiver of any non-waivable rights you
possess.
Financial Planning & Consulting:
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We provide a variety of financial planning and consulting services to individuals, families, and other
clients regarding the management of their financial resources based upon an analysis of the client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s financial
goals and objectives. This planning or consulting may encompass one or more of the following areas:
Asset Allocation, Education/College Savings Plans, Investment Planning, Business/Corporate Planning,
Employee Benefit Plan Consulting, Non-securities related Investments, Business Succession, Estate
Planning, Personal Financial Planning, Charitable Planning, Financial Consultation, Real Estate Analysis,
Corporate Structure, Financial Planning, Retirement Planning, Debt/Cash Flow Analysis, and/or
Insurance Analysis/Policy Review.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create, or revise
wills or trusts, obtain, or revise insurance coverage, commence, or alter retirement savings, or establish
education or charitable giving programs. It should also be noted that we refer clients to an accountant,
attorney, or other specialist, as necessary for non-advisory related services. For written financial
planning engagements, we provide our clients with a verbal or written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do not
provide our clients with a written summary of our observations and recommendations as the process
is less formal than our planning service. Plans or consultations are typically completed within six (6)
months of the client signing a contract with us, assuming that all the information and documents we
request from the client are provided to us promptly. Implementation of the recommendations will be
at the discretion of the client.
Other Types of Services We Offer__________________________________________________________________________
Tax Preparation (and related) Services
Focus Subsidiary Affiliate
We help our clients obtain tax return preparation and consulting services to clients who receive
portfolio management services and/or financial planning services. The fee for tax preparation and
consulting service generally depends on the complexity of the engagement and scope of the work.
We have a business arrangement with SCS Capital Management LLC (“SCS”), who is an indirect, wholly
owned subsidiary of Focus LLC and Focus Inc., under which certain clients of Cornerstone Wealth have the
option of investing in certain private investment vehicles managed by SCS. Cornerstone Wealth is an affiliate
of SCS by virtue of being under common control with it. Please see Items 5, 10 and 11 of this Brochure for
further details.
We have executed a subadvisory agreement with Williams Jones Wealth Management, LLC (“Williams
Jones”), which is an indirect, wholly-owned subsidiary of Focus LLC, and which provides investment
subadvisory services to certain of our clients. We are an affiliate of Williams Jones by virtue of being under
common control with it. Please see Items 5 and 10 of this Brochure for further details.
We have a business arrangement with a subsidiary or subsidiaries of Origin Investments Group, LLC
(“Origin”), who are each an indirect, wholly owned subsidiary of Focus LLC, under which certain clients of
Cornerstone Wealth have the option of investing in certain private investment vehicle managed by Origin.
Cornerstone Wealth is an affiliate of Origin by virtue of being under common control with it. Please see Items
5, 10, and 11 of this Brochure for further details.
We have a subadvisory agreement with Kovitz Investment Group Partners, LLC d/b/a NorthCoast Asset
Management (“Kovitz”), which is an indirect, wholly owned subsidiary of Focus LLC, and which provides
investment subadvisory services to certain of our clients. We are an affiliate of Kovitz by virtue of being
under common control with it. Please see Items 5 and 10 of this Brochure for further details.
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UPTIQ Treasury & Credit Solutions
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information.
Focus Risk Solutions
We help our clients obtain certain insurance by introducing clients to our affiliate, Focus Risk Solutions,
LLC (“FRS”). FRS does not receive any compensation from serving our clients. Please see Items 5 and
10 for a fuller discussion of these services and other important information.
Information Received from Clients
Cornerstone Wealth will not assume any responsibility for the accuracy of the information provided by the
client. We are not obligated to verify any information received from the client or other professionals (e.g.,
attorney, accountant, etc.) designated by the client, and Cornerstone Wealth is expressly authorized by the
client to rely on such information provided. Under all circumstances, clients are responsible for promptly
notifying Cornerstone Wealth in writing of any material changes to the client’s financial situation,
investment objectives, time horizon, or risk tolerance. In the event that a client notifies Cornerstone Wealth
of changes in the client’s financial circumstances or investment objectives, we will review such changes and
recommend any necessary revisions to the client’s portfolio.
Assets Under Management
As of December 31, 2025, Cornerstone Wealth has $2,487,042,824 in discretionary assets and
$231,012,148 in assets under advisement. The assets under advisement are not included in the regulatory
assets under management of Cornerstone Wealth.
Item 5: Fees & Compensation
How We Are Compensated for Our Advisory Services
Comprehensive Portfolio Management:
Comprehensive portfolio management services are charged a quarterly fee based on the account’s
assets under management as of the last day of the preceding quarter cycle. Cash (including cash
invested in a cash management program arranged through UPTIQ) and accrued interest and accrued
dividends will be included in an account’s assets under management in calculating the comprehensive
portfolio management fee unless Cornerstone Wealth determines otherwise, in its discretion. For
accounts with a margin balance, the account’s assets under management for purposes of calculating the
comprehensive portfolio management fee will be reduced by the margin balance. Comprehensive
portfolio management fees are calculated on a pro-rata annualized basis and payable in advance, on a
rolling three-month quarterly basis (billing quarters, rather than calendar quarters).
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Our fee schedule for portfolio management of new clients will be as follows:
ADVISORY TIERED FEE SCHEDULE
Market Value of Assets
Tiered Rate*
Under $499,999
1.25%
$500,000 to $999,999
1.10%
$1,000,000 to $1,499,999
0.95%
$1,500,000 to $1,999,999
0.85%
$2,000,000 to $2,999,999
0.70%
$3,000,000 to $3,999,999
0.65%
$4,000,000 to $4,999,999
0.55%
$5,000,000 to $9,999,999
0.50%
$10,000,000 to $24,999,999
0.40%
$25,000,000 to $49,999,999
0.35%
$50,000,000 to $99,999,999
0.30%
*Specified rate applies only to assets in that tier. Accounts for which we charge a fee of 0.25% or less
will no longer be included in the value of your assets when we are determining the fee rate applied to
your other accounts.
Tier Billing Example: Client has assets under management of $1,100,000 and are billed according to the
schedule listed above:
$0 to $499,999 is billed at 1.25% = $6249.99
$500,000 to $999,999 is billed at 1.10% = 5499.99
$1,000,000 to $1,100,000 is billed at .95% = $950
Total Fee Billed = 12,699.98
Clients who engaged us prior to July 1, 2021, are subject to legacy fee schedules that differ from the fee
schedule set forth above. In some instances, we use these legacy fees for new clients. In some instances,
the use of a legacy fee schedule may include a fee schedule that requires clients to pay us a minimum
fee of $3,000 per annum.
Our fees are based on the market value of your assets under our management, including cash, accrued
interest, accrued dividends, and securities purchased on margin.
Our fees are potentially negotiable and may vary from client to client based on a variety of factors,
including, but not limited to, the unique objectives of the client, complexity of the investment plan and
anticipated future assets from the client. We also reserve the right to waive our minimum fee.
Unless otherwise arranged by the client, our comprehensive portfolio management fees are
automatically deducted from a client’s account by the custodian of the account as soon as reasonably
practicable after the end of each calendar cycle.
For certain clients, we charge an advisory fee for services provided with respect to the held-away
accounts mentioned in Item 4 above, just as we do with client accounts that are not held away. The fees
charged by us for managing held-away accounts are identical to the fees we charge for managing
accounts that are not held away. The specific fee schedule charged by us is provided in the client’s
investment management agreement with us.
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Management of Annuities and 529s at Companies with an Advisory Option:
Annuities and 529s at Companies with an Advisory Option may be charged a quarterly fee based on the
last day of the preceding quarter cycle or based on the last day of the preceding quarter payable in
arrears. The specific billing conditions will be available in the Product Company’s Documentation.
We charge the following advisory fee when offering Variable Annuities and 529s that are managed by
Cornerstone.
Fee Schedule for Managed 529s or Annuities:
Maximum Rate
1.00%
0.75%
0.75%
Asset Type
529
Equity Index
Annuity
Fixed Index
Annuity
Variable
Annuity
Client Fee Schedule
(as listed above)
We charge different fee rates for assets invested in variable annuities than other managed account
assets. Charging different rates creates an incentive to invest client accounts in accounts that pay
Cornerstone Wealth a higher fee.
Retirement Plan Consulting:
Fees for retirement plan consulting services are typically based on a percentage of plan assets,
according to the schedule below.
Fee Schedule for 401(k) and 403(b) plans:
Value of Plan Assets
Fee Ranges
Up to $1,000,000
$1,000,000 to $2,500,0000
$2,500,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $25,000,000
$25,000,001 to $50,000,000
$50,000,001 +
50 – 65 bps
40 – 50 bps
30 – 40 bps
25 – 30 bps
20 – 25 bps
15 – 20 bps
Negotiable
Minimum annual fee of $5,000
Cash Balance Plans
Clients opening
(Defined Benefit Plans) will have a fee of 75 bps
The negotiated rate may vary due to multiple locations or additional services rendered.
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In addition to the fees above, Client will pay a negotiated fee (“Transition Expense Fee”) for the first
year after the Plan transitions to cover additional services required during set up of a new
platform/product provider. The Transition Expense Fee is intended to cover the additional services
(fund mapping, assistance with enrollment, additional education to committee members and
participants, etc.) that will be provided as a result of the transition. Our firm’s fees are billed on an
annualized basis monthly/quarterly in advance based on the value of plan assets on the last day of the
previous month/quarter. Fees are negotiable and are deducted from your account. On rare occasions,
we allow direct billing. 401(k) and 403(b) (non-profit) plans may be charged a start-up or installation
fee of up to $5,000.
Our fee arrangements for consulting services will be determined on a case-by-case basis and will be
detailed in the signed Retirement Plan Consulting Agreement.
Financial Planning & Consulting:
We charge either on an hourly or flat fee basis for financial planning and consulting services. The
ultimate fee that we charge you is based on the scope and complexity of our engagement with you.
Our fees are generally negotiable.
For financial planning services we require a retainer of fifty percent (50%) of the estimated total
financial planning fee with the remainder of the fee due to us upon delivery of your financial plan.
If the entirety of the retainer is not earned within six months of engagement, any excess fees will
be returned to the client, along with an explanation of fees earned.
For consulting services, the fee will be paid as ¼ (25%) of the total fee paid on a quarterly basis.
Planning/consulting services will automatically renew on an annual basis unless Client
terminates the service. For ongoing services, the annual flat fee will be due on the anniversary
date of this agreement.
Fees for Tax Preparation (and related) Services
CWG offers tax return preparation and consulting services to its clients who receive portfolio
management services and/or financial planning services. The fee for tax preparation and consulting
services generally depends on the complexity of the engagement and scope of the work. If the fee for
tax preparation and consulting services is not included in a client’s portfolio management services fee
or financial planning fee, then the fee generally is directly billed to the client upon completion of the
services, for example, upon the filing of a tax return. A client may, in writing. grant CWG the authority
to deduct the tax preparation and related service fee from their investment account.
Focus Subsidiary Affiliate
We do not receive any compensation from SCS in connection with the assets that our clients place in
SCS’s pooled investment vehicles. Cornerstone Wealth’s clients are not advisory clients of and do not
pay advisory fees to SCS. However, our clients bear the costs of SCS’s investment vehicle or vehicles in
which they are invested, including any management fees and performance fees payable to SCS.
The allocation of Cornerstone Wealth client assets to SCS’s pooled investment vehicles, rather than to
an unaffiliated investment manager, increases SCS’s compensation and the revenue to Focus LLC
relative to a situation in which our clients are excluded from SCS’s pooled investment vehicles of in an
unaffiliated third party’s pooled investment vehicles. As a consequence, Focus LLC has a financial
incentive to encourage us to recommend that our clients invest in SCS’s pooled investment vehicles.
We do not receive any compensation from Wiliam Jones in connection with Williams Jones’ subadvisory
services to our clients. However, our clients bear the costs of any investments recommended by
Williams Jones and are responsible for any management fees payable to Williams Jones, which are in
addition to our advisory fee. The allocation of our client assets to Williams Jones for subadvisory
services, rather than to an unaffiliated investment management, increases Williams Jones’
compensation and the revenue to Focus LLC relative to a situation in which our clients’ assets are
managed by an unaffiliated manager. As a consequence, Focus LLC has a financial incentive to
encourage us to recommend that a portion of our clients’ assets be subadvised by Williams Jones.
Please see Item 10 of this Brochure for further details.
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We do not receive any compensation from Origin in connection with assets that our clients place in
Origin’s pooled investment vehicles. Cornerstone Wealth’s clients are not advisory clients of and do
not pay advisory fees to Origin. However, our clients bear the costs of Origin’s Investment vehicle or
vehicles in which they are invested, including any management fees and performance fees payable to
Origin. The allocation of our client assets to Origin’s pooled investment vehicles, rather than to an
unaffiliated investment management, increases Origin’s compensation and the revenue to Focus LLC
relative to a situation in which our clients are excluded from Origin’s polled investment vehicles or in
an unaffiliated third party’s pooled investment vehicles. As a consequence, Focus LLC has a financial
incentive to encourage us to recommend that our clients invest in Origin’s pooled investment vehicles.
UPTIQ Treasury & Credit Solutions (“UPTIQ”)
We do not receive any compensation from Kovitz in connection with Kovitz’s subadvisory services to
our clients. However, our clients bear the costs of any investments recommended by Kovitz and are
responsible for any management fees payable to Kovitz, which are in addition to our advisory fee. The
allocation of our client asset to Kovitz for subadvisory services, rather than to an unaffiliated
investment management, increases Kovitz’s compensation and the revenue to Focus LLC relative to a
situation in which our clients’ assets are managed by an unaffiliated manager. As a consequence, Focus
LLC has a financial incentive to encourage us to recommend that a portion of our clients’ assets be
subadvised by Kovitz. Please see Item 10 of this Brochure for further details.
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is
compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients.
The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus, our parent company.
When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus
Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients,
UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions.
For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to
25% of all revenue it receives from such third-party financial institutions. For cash management products and
services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the
third-party financial institutions and other intermediaries that provide administrative and settlement services
in connection with this program. Although the amount of these revenue-sharing payments to FSH is not
charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ
or the yield earned by clients on cash management solutions facilitated by UPTIQ, the compensation earned
by UPTIQ is an expense of the third-party financial institutions that informs the interest rate paid by clients
on credit solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue
to us when we are licensed to receive such revenue (or when no such license is required) and the distribution
is not otherwise legally prohibited. Further information on this conflict of interest is available in Item 10 of
this Brochure.
Focus Risk Solutions (“FRS”)
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We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk
Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners,
LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance
matters and placing insurance products for them and/or referring our clients to certain third-party
insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together
with FRS place insurance products for them. If FRS places an insurance product or refers one of our
clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will
receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance
carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these
insurance products will vary over time in response to market conditions and will also differ based on
the type of insurance product sold and which Broker placed the policy. The amount of insurance
commission revenue earned by FRS is considered for purposes of determining the amount of additional
compensation that certain of our financial professionals are entitled to receive. Additionally, in
exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer
their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the “Platform
Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are
revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such
revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use
incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees
to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future.
Further information on this conflict of interest is available in Item 10 of this Brochure.
Negotiability of Fees
Although Cornerstone Wealth believes that its fees are competitive, clients should understand that
lower fees for comparable services may be available from other sources and firms. Cornerstone Wealth
reserves the right to negotiate fees under certain circumstances and at our sole discretion.
Additional Fees & Expenses
In addition to the fees charged by Cornerstone Wealth, clients that we provide portfolio management
services to are responsible for the fees and expenses charged by third parties in connection with the
investment of their assets. These fees and expenses could potentially include brokerage and other
transaction costs, and fees and taxes, related to the purchase and sale of securities for their accounts, and
any fees charged by custodians for holding their assets. Certain investments we select for clients that are
managed or sponsored by third parties, such as mutual funds, Exchange Traded Funds, private
partnerships, and securities managed by external managers of separately managed accounts, bear fees and
expenses for their management and operation. Please ask us to point you to the prospectus, offering
memorandum, Form ADV or other document which details these fees and expenses. In many cases, clients
could invest in these investment vehicles directly, but they would not have the benefit of our professional
experience in selecting and allocating their assets. The foregoing fees are exclusive of and in addition to the
fees charged by Cornerstone Wealth. Please refer to Item 12 of this Brochure entitled “Brokerage Practices”
for additional important information.
Termination & Refunds
You may terminate our services at any time by providing us with written notice of your desire to do so.
Upon receipt of your termination request, we will initiate the process to close out your account, and we will
refund any prepaid but un unearned portion of our advisory fee to you. For fees charged in arrears, we will
instruct the custodian to deduct any unpaid fees we are owed from your account, or otherwise seek
payment of our fees from you in accordance with previous fee billing practices.
Termination of services from external managers of separately managed accounts will be governed by the
agreement with the external manager.
Commissionable Securities and Insurance Sales
Certain supervised persons of Cornerstone Wealth are also registered representatives of Mutual Securities,
Inc., member FINRA/SIPC and accept compensation for the sale of securities or other investment products,
including distribution or service (“trail”) fees from the sale of mutual funds, variable annuities and 529
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plans held in non-advisory accounts. In addition, certain supervised persons are also, in their individual
capacities, licensed insurance agents appointed with various insurance companies. Clients should be aware
that the practice of accepting commissions for the sale of securities or insurance creates an incentive to
recommend products based on compensation received rather than based on a client’s needs. We seek to
mitigate this conflict of interest through disclosure and are required to recommend only investments we
reasonably believe to be in the best interest of our clients. Supervised persons of Cornerstone Wealth do
not receive commissions, distribution or service fees relating to the sale of securities or investment
products held in advisory accounts (e.g., they do not “double dip.”) Please refer to Item 10 below for
additional information regarding these arrangements.
Item 6: Performance-Based Fees & Side-By-Side Management
We do not charge performance fees (a fee that is based on gains in client accounts), and so we have nothing
to disclose in response to this item.
Item 7: Types of Clients
We provide services to the following types of clients:
•
•
•
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Retirement Plans;
Other Advisers; and
Corporations, limited liability companies and/or other business types.
Cornerstone Wealth does not have minimum asset requirements for opening and maintaining accounts or
otherwise engaging us. Regardless, the client understands that asset withdrawals may impair the
achievement of the client’s investment objectives. In addition, Cornerstone Wealth retains the right to
accept or decline a potential client, or terminate an advisory agreement with a current client, for any reason
in its sole discretion.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
We typically invest client portfolios in accordance with models constructed to align with clients’ investment
objectives and risk tolerance. Client assets are typically invested in equity securities of individual
companies, mutual funds, ETFs, and bond funds. Where appropriate, sleeves of client portfolios are
managed and/or the management models are provided by third-party managers. For clients who meet
financial qualification standards, are interested and are able to bear the risk, we may allocate some of their
assets to alternative investments. Our investment committee typically meets on a bi-weekly basis to
discuss macroeconomic themes, asset allocation decisions, performance outliers, and changes to our
investment models.
Risk of Loss
Investing involves a significant risk of loss which clients should be prepared to bear. Cornerstone Wealth’s
investment recommendations are subject to various market, currency, economic, political, and business
risks, and such investment decisions may not always be profitable. Clients should be aware that there may
be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s
investment objectives will be obtained and no inference to the contrary should be made.
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Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock prices
generally will fluctuate more than large-stock prices. The market value of fixed income securities will
generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed
income securities are obligations of the issuer to make payments of principal and/or interest on future
dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt
securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a
non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed
and asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may
include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration
fixed income securities will generally fluctuate more than shorter duration fixed income securities.
Investments in overseas markets also pose special risks, including currency fluctuation and political risks,
and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for
investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve
its investment objective.
Past performance of investments is no guarantee of future results. Clients are advised that they should
only commit assets for management that can be invested for the long term, that volatility from investing
can occur, and that all investing is subject to risk. Cornerstone Wealth does not guarantee the future
performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be
prepared to bear.
Additional risks involved in the securities recommended by Cornerstone Wealth may include, among
others:
Stock market risk
•
, which is the chance that stock prices overall will decline. The market value of
equity securities will generally fluctuate with market conditions. Stock markets tend to move in
cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend
to fluctuate over the short term as a result of factors affecting the individual companies,
industries, or the securities market as a whole. Equity securities generally have greater price
volatility than fixed income securities.
Sector risk
•
, which is the chance that significant problems will affect a particular sector, or that
returns from that sector will trail returns from the overall stock market. Daily fluctuations in
specific market sectors are often more extreme than fluctuations in the overall market.
Issuer risk
•
, which is the risk that the value of a security may decline for reasons directly related
to the issuer, such as management performance, financial leverage, and reduced demand for the
issuer's goods or services.
Non-diversification risk
•
, which is the risk of focusing investments on a small number of issuers,
industries, or foreign currencies, including being more susceptible to risks associated with a
single economic, political or regulatory occurrence than a more diversified portfolio might be.
Value investing risk
•
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, which is the risk that value stocks may not increase in price, may not issue
the anticipated stock dividends, or may decline in price, either because the market fails to
recognize the stock’s intrinsic value, or because the expected value was mis-gauged. If the market
does not recognize that the securities are undervalued, the prices of those securities might not
appreciate as anticipated. They also may decline in price even though in theory they are already
undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind
growth stocks in an up market.
Smaller company risk
•
, which is the risk that the value of securities issued by a smaller company
may go up or down, sometimes rapidly and unpredictably as compared to more widely held
securities. Investments in smaller companies are subject to greater levels of credit, market, and
issuer risk.
Foreign (non-U.S.) investment risk
•
, which is the risk that investing in foreign securities may
result in the portfolio experiencing more rapid and extreme changes in value than a portfolio
that invests exclusively in securities of U.S. companies. Risks associated with investing in
foreign securities include fluctuations in the exchange rates of foreign currencies that may
affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result
of political and economic instability in the foreign country, less public information about
issuers of securities, different securities regulation, different accounting, auditing and financial
reporting standards and less liquidity than in the U.S. markets.
• Liquidity risk,
which is the risk stemming from the lack of marketability of an investment that
cannot be bought or sold quickly enough to prevent or minimize a loss.
Interest rate risk
•
, which is the chance that prices of fixed income securities will decline because
of rising interest rates. Similarly, the income from fixed income securities may decline because
of falling interest rates.
Credit risk,
•
which is the chance that an issuer of a fixed income security will fail to pay interest
and principal in a timely manner, or that negative perceptions of the issuer’s ability to make
such payments will cause the price of that fixed income security to decline.
Exchange Traded Fund (ETF) risk
•
, which is the risk of an investment in an ETF, including the
possible loss of principal. ETFs typically trade on a securities exchange and the prices of their
shares fluctuate throughout the day based on supply and demand, which may not correlate
to their net asset values. Although ETF shares will be listed on an exchange, there can be no
guarantee that an active trading market will develop or continue. Owning an ETF generally
reflects the risks of owning the underlying securities it is designed to track. ETFs are also
subject to secondary market trading risks. In addition, an ETF may not replicate exactly the
performance of the index it seeks to track for a number of reasons, including transaction costs
incurred by the ETF, the temporary unavailability of certain securities in the secondary
market, or discrepancies between the ETF and the index with respect to weighting of
securities or number of securities held.
Management risk
•
, which is the risk that the investment techniques and risk analyses applied
by Cornerstone Wealth may not produce the desired results and that legislative, regulatory, or
tax developments, may affect the investment techniques available to Cornerstone Wealth.
There is no guarantee that a client’s investment objectives will be achieved.
Real Estate risk
•
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, which is the risk that an investor’s investments in Real Estate Investment Trusts
(“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to
those associated with direct ownership of real estate, including losses from casualty or
condemnation, and changes in local and general economic conditions, supply and demand,
interest rates, zoning laws, regulatory limitations on rents, property taxes and operating
expenses. An investment in REITs or real estate-linked derivative instruments subject the
investor to management and tax risks.
Investment Companies (“Mutual Funds”) risk
•
, when an investor invests in mutual funds, the
investor will bear additional expenses based on his/her pro rata share of the mutual fund’s
operating expenses, including the management fees. The risk of owning a mutual fund generally
reflects the risks of owning the underlying investments the mutual fund holds.
Commodity risk
•
, generally commodity prices fluctuate for many reasons, including changes in
market and economic conditions or political circumstances (especially of key energy-producing
and consuming countries), the impact of weather on demand, levels of domestic production and
imported commodities, energy conservation, domestic and foreign governmental regulation
(agricultural, trade, fiscal, monetary and exchange control), international politics, policies of
OPEC, taxation and the availability of local, intrastate and interstate transportation systems and
the emotions of the marketplace. The risk of loss in trading commodities can be substantial.
Private Investment Funds:
We recommend that certain clients invest their assets in private investment
funds, such as hedge funds or private equity funds. Private investment funds are generally illiquid, are less
regulated than publicly traded securities, can be leveraged and are only appropriate for financially
sophisticated investors with sufficient risk tolerance to withstand the loss of their investment in the fund.
Clients are encouraged to carefully review the risk factors contained in the private offering memorandum
for the relevant funds before they invest.
Insurance Products:
There also are risks surrounding various insurance products that are recommended
to Cornerstone Wealth clients from time to time. Such risks include, but are not limited to, loss of
premiums. Prior to purchasing any insurance product, clients should carefully read the policy and
applicable disclosure documents.
Structured Notes:
We recommend that certain clients invest their assets in structured notes. Structured
notes are retail products designed or “structured” to meet specific investment objectives, such as growth,
income or risk management. They do so by combining a traditional security, like a bond, with a derivative
component. A structured note doesn’t hold an actual underlying portfolio of investments. Instead, the
issuer of the note promises to pay a return based on a formula that incorporates the performance of one
or more referenced assets.
Most structured notes don’t offer any principal protection, meaning that an investor could lose the entire
amount invested as a result of the performance of the reference asset or assets to which the note provides
exposure. Any guarantee that your principal will be protected is only as good as the financial strength of
the company making the promise. You could lose your investment if the issuer of your note is unable to
pay its obligations.
Structed products, including notes with principal protection, are primarily designed to be buy-and-hold
investments. While some notes may have relatively short maturities, while others might extend out for 10
years or more. Structured notes with principal protection tend to have longer maturities.
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Cybersecurity
The computer system, networks and devices used by Cornerstone Wealth and service providers to us and
our clients to carry out routine business operations employ a variety of protections designed to prevent
damage or interruption from computer viruses, network failures, computer and telecommunication
failures, infiltration by unauthorized persons and security breaches. Despite the various protections
utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted
as a result of a cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from
computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise
disrupt operation, business processes, or website access or functionality. Cybersecurity breaches may
cause disruptions and impact business operations, potentially resulting in financial losses to a client;
impediments to trading; the inability by us and other service providers to transact business; violations of
applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or
other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential
information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in
which a client invest; governmental and other regulatory authorities; exchange and other financial market
operators or institutions; and other parties. In addition, substantial costs may be incurred by these entities
in order to prevent any cybersecurity breaches in the future.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of
our advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Some of our supervised persons are registered representatives of Mutual Securities, Inc., member
FINRA/SIPC. They offer securities and receive normal and customary commissions as a result of securities
transactions. This presents a conflict of interest to the extent that the supervised person recommends that
a client invest in a security which results in a commission being paid to the supervised person. As a result
of this relationship, Mutual Securities, Inc. may have access to certain confidential information (e.g.,
financial information, investment objectives, transactions and holdings) about clients, even if client does
not establish an account through Mutual Securities, Inc. If you would like a copy of the Mutual Securities,
Inc. privacy policy, please contact our Chief Compliance Officer as described on the cover page of this
Brochure. Clients should be aware that the receipt of additional compensation itself creates an inherent
conflict of interest and may affect the judgment of these individuals when making recommendations.
Cornerstone Wealth and Mutual Securities, Inc. are separate, nonaffiliated entities. Nevertheless, to the
extent that a Cornerstone Wealth supervised person recommends the purchase of securities or other
investment products where the supervised person receives commissions for doing so, a conflict of interest
exists because the supervised person may be incentivized to make recommendations based on the
compensation received rather than on a client’s needs.
Certain of our supervised persons, in their individual capacities, are also licensed insurance agents with
various insurance companies, and in such capacity, may recommend, on a fully disclosed commission basis,
the purchase of certain insurance products. While the Firm does not sell such insurance products to our
investment advisory clients, we permit our supervised persons, in their individual capacities as licensed
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insurance agents, to sell insurance products to our investment advisory clients. A conflict of interest exists
to the extent that the Firm recommends the purchase of insurance products where our supervised persons
receive insurance commissions or other additional compensation.
Cornerstone Wealth has also adopted certain procedures designed to mitigate the effects of these conflicts.
As part of our fiduciary duty to clients, the Firm and our supervised persons always endeavor to put the
interests of the clients first and recommendations will only be made to the extent that they are reasonably
believed to be in the best interests of the client. Additionally, the conflicts presented by these practices are
disclosed to clients through this Brochure, client agreement and/or verbally prior to or at the time of
entering into an Agreement. Clients are not obligated to implement recommended transactions through any
Cornerstone Wealth supervised person or any particular broker-dealer or insurance carrier. Clients have
the option to purchase any recommended investment and insurance products or services through brokers,
carriers, or agents other than Mutual Securities, Inc. and/or any Cornerstone Wealth supervised person.
Supervised persons of Cornerstone Wealth do not receive commissions, distribution or service fees relating
to the sale of securities or investment products held in advisory accounts (e.g., they do not “double dip.”)
Focus Financial Partners
As noted above in Item 4, certain funds affiliated with CD&R collectively are indirect majority owners of
Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC.
Because Cornerstone Wealth is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point
investment vehicles are indirect owners of Cornerstone Wealth.
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
UPTIQ Credit and Cash Management Solutions
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”). These third-party financial institutions are banks and non-banks that offer credit and cash management
solutions to our clients, as well as certain other unaffiliated third parties that provide administrative and settlement
services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’
access to these credit and cash management solutions.
We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in
UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for
serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus. When
legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions
Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share
with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except
residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives
from such third-party financial institutions. For cash management products and services provided to our clients,
UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and
other intermediaries that provide administrative and settlement services in connection with this program.
Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the
interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash
management solutions facilitated by UPTIQ, the compensation earned by UPTIQ is an expense of the third-party
financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients
on cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue
(or when no such license is required) and the distribution is not otherwise legally prohibited. This revenue is also
revenue for FSH’s and our common parent company, Focus. Additionally, the volume generated by our clients’
transactions allows Focus to negotiate better terms with UPTIQ, which benefits Focus and us. Accordingly, we
have a conflict of interest when recommending UPTIQ’s services to clients because of the compensation to us and
to our affiliates, FSH and Focus, and the transaction volume to UPTIQ. We mitigate this conflict by: (1) fully
and fairly disclosing the material facts concerning the above arrangements to our clients, including in this
Brochure; and (2) offering UPTIQ’s solutions to clients on a strictly nondiscretionary and fully disclosed basis,
and not as part of any discretionary investment services. Additionally, we note that clients who use UPTIQ’s
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services will receive product-specific disclosures from the third-party financial institutions and other unaffiliated
third-party intermediaries that provide services to our clients.
We have an additional conflict of interest when we recommend credit solutions to our clients because our interest
in continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend
that clients borrow money rather than liquidate some or all of the assets we manage.
Credit Solutions
Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’
custodians. While credit solution programs that we offer facilitate secured loans through third-party financial
institutions, clients are free instead to work directly with institutions outside such programs. Because of the
limited number of participating third-party financial institutions, clients may be limited in their ability to obtain
as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms or obtain
other financial arrangements.
Clients should also understand that pledging assets in an account to secure a loan involves additional risk and
restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at
any time, without prior notice to clients and without their consent, to maintain required collateral levels. The
third-party financial institution also has the right to call client loans and require repayment within a short period
of time; if the client cannot repay the loan within the specified time period, the third-party financial institution
will have the right to force the sale of pledged assets to repay those loans. Selling assets to maintain collateral
levels or calling loans may result in asset sales and realized losses in a declining market, leading to the permanent
loss of capital. These sales also may have adverse tax consequences. Interest payments and any other loan-related
fees are borne by clients and are in addition to the advisory fees that clients pay us for managing assets, including
assets that are pledged as collateral. The returns on pledged assets may be less than the account fees and interest
paid by the account. Clients should consider carefully and skeptically any recommendation to pursue a more
aggressive investment strategy in order to support the cost of borrowing, particularly the risks and costs of any
such strategy. More generally, before borrowing funds, a client should carefully review the loan agreement, loan
application, and other forms and determine that the loan is consistent with the client’s long-term financial goals
and presents risks consistent with the client’s financial circumstances and risk tolerance.
We use UPTIQ to facilitate credit solutions for our clients.
Cash Management Solutions
For cash management programs, certain third-party intermediaries provide administrative and settlement services
to our clients. Engaging third-party financial institutions and other intermediaries to provide cash management
solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in
rare circumstances, depending on interest rates and other economic and market factors, the yields on cash
management solutions could be lower than the aggregate fees and expenses charged by the third-party financial
institutions, the intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could
experience a negative overall investment return with respect to those cash investments. Nonetheless, it might still
be reasonable for a client to participate in a cash management program if the client prefers to hold cash at the
third-party financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC
insurance).
We use UPTIQ to facilitate cash management solutions for our clients.
Focus Risk Solutions
We help clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk
Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC
(“Focus”).
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FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters
and placing insurance products for them and/or referring our clients to certain third-party insurance
brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS
place insurance products for them. If FRS places an insurance product or refers one of our clients to a
Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion
of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which
the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will
vary over time in response to market conditions and will also differ based on the type of insurance product
sold and which Broker placed the policy. The amount of insurance commission revenue earned by FRS is
considered for purposes of determining the amount of additional compensation that certain of our financial
professionals are entitled to receive. This revenue is also revenue for our and FRS’s common parent
company, Focus.
Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby,
to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the
“Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform
Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in
such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use
incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to
FRS, which could also support increases in the overall amount of the Platform Fee rates in the future.
Accordingly, we have a conflict of interest when recommending FRS’s services to clients because of the
compensation to certain of our financial professionals and to our affiliates, FRS and Focus. We address this
conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our
clients, including in this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and
fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any
portion of the Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-
specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party
intermediaries that provide services to our clients.
The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the
Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy.
The final rate may be higher or lower than the prevailing market rate, and may be higher than if the policy
was purchased directly through the Broker without the assistance of FRS. We can offer no assurances that
the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace.
SCS Private Funds
We have a business relationship with other Focus firms that is material to our advisory business or to our
clients. As stated earlier in Items 4 and 5 of this Brochure, under certain circumstances we offer our clients
the opportunity to invest in pooled investment vehicles managed by SCS. SCS provides these services to
such clients pursuant to limited liability company agreement or limited partnership agreement documents
and in exchange for a fund-level management fee and performance fee paid by our clients and not by us.
SCS, like Cornerstone Wealth, is an indirect wholly owned subsidiary of Focus LLC and is therefore under
common control with Cornerstone Wealth. The allocation of our clients’ assets to SCS’s pooled investment
vehicles, rather than to an unaffiliated investment manager, increases SCS’s compensation and indirectly,
Focus LLC’s compensation and revenue. As a consequence, Focus LLC has a financial incentive to cause
Cornerstone Wealth to recommend that our clients invest in SCS’s pooled investment vehicles, which
creates a conflict of interest with those Cornerstone Wealth clients who invest in SCS’s pooled investment
vehicles. More information about Focus LLC can be found at www.focusfinancialpartners.com.
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We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our
reasonable belief that investing a portion of Cornerstone Wealth clients’ assets in SCS’s investment vehicles
is in the best interests of the affected clients; (2) SCS and its investment vehicles have met the due diligence
and performance standards that we apply to outside, unaffiliated investment managers; (3) clients will
invest in the pooled investment vehicles on a nondiscretionary basis through the completion of subscription
documentation; (4) subject to redemption restrictions, we are willing and able to reallocate Cornerstone
Wealth client assets to other unaffiliated investment vehicles, in part or in whole, if SCS’s services become
unsatisfactory in our judgment and at our sole discretion; and (5) we have fully and fairly disclosed the
material facts regarding this relationship to you, including in this Brochure, and Cornerstone Wealth clients
who invest in SCS’s pooled investment vehicles have given their informed consent to those investments.
Williams Jones
As stated earlier in Items 4 and 5 of this Brochure, we have retained our affiliate, Williams Jones, through a
subsidiary agreement to provide investment sub advisory services to certain of our clients. Williams Jones
provides these services to such clients pursuant to a sub advisory agreement and in exchange for a sub
advisory fee paid by our clients. Williams Jones, like us, is an indirect wholly owned subsidiary of Focus
LLC and therefore under common control with us. The allocation of our clients’ assets to Williams Jones
pursuant to a sub advisory arrangement, rather than to an unaffiliated investment manager, increases
Williams Jones’ compensation and the revenue to Focus LLC, relative to a situation in which our clients’’
assets are managed by an unaffiliated manager. As a consequence, Focus LLC has a financial incentive to
encourage us to recommend that a portion of our clients’ assets be sub advised by Williams Jones, which
creates a conflict of interest with those clients who are sub advised by Williams Jones.
More information about Focus LLC can be found at www.focusfinancialpartners.com. We believe this
conflict is mitigated because of the following factors: (1) the retention of Williams Jones as a subadvisor is
based on our judgement that such retention is in the best interest of our affected clients; (2) Williams Jones
has met the due diligence standards that we apply to outside investment managers; (3) we are willing and
able to terminate Williams Jones’ services, in part or in whole, if Williams Jones’ services become
unsatisfactory in the judgement of, and at the sole discretion of, us; and (4) we have fully and fairly disclosed
the material facts regarding this relationship, including in this Brochure, to our clients for whom we
recommend that Williams Jones serve as subadvisor, and such clients have therefore given their informed
consent to this conflict.
Origin
Cornerstone Wealth has a business relationship with other Focus firms that is material to our advisory
business or to our clients. Under certain circumstances we offer our clients the opportunity to invest in
pooled investment vehicles managed by Origin. Origin provides these services to such clients pursuant to
limited liability company agreement or limited partnership agreement documents and in exchange for a
fund-level management fee and performance fee paid by our clients and not by us. Origin, like Cornerstone
Wealth, is an indirectly wholly owned subsidiary of Focus LLC and is therefore under common control with
Cornerstone Wealth. The allocation of our clients’ assets to Origin’s pooled investment vehicles, rather than
to an unaffiliated investment manager, increases Origin’s and indirectly, Focus LLC’s compensation and
revenue. As a consequence, Focus LLC has a financial incentive to encourage Cornerstone Wealth to
recommend that our clients invest in Origin’s pooled investment vehicles, which creates a conflict of
interest with Cornerstone Wealth clients who invest, or are eligible to invest, in Origin’s pooled investment
vehicles. More information about Focus LLC can be found at www.focusfinancialpartners.com.
We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our
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reasonable belief that investing a portion of Cornerstone Wealth’s clients’ assets in Origin’s investment
vehicles is in the best interest of the clients; (2) Origin and its investment vehicles have met the due
diligence standards and performance standards that we apply to outside, unaffiliated investment managers;
(3) clients will invest in the pooled investment vehicles on a nondiscretionary basis through the completion
of subscription documentation (4) subject to redemption restrictions, we are willing and able to reallocate
Cornerstone Wealth client assets to other unaffiliated or affiliated investment vehicles, in part or in whole,
if Origin’s services become unsatisfactory in our judgment and at our sole discretion; and (5) we have fully
and fairly disclosed the material facts regarding this relationship to you, including in this Brochure, to our
clients for whom invest in Origin’s pooled investment vehicles have given their informed consent to those
investments.
Kovitz
As stated earlier in Items 4 and 5 of this Brochure, we have an agreement with our affiliate, Kovitz, to
provide investment subadvisory services to certain of our clients. Kovitz provides these services to such
clients pursuant to a subadvisory agreement and in exchange for a subadvisory fee paid by our clients.
Kovitz, like us, is an indirect and wholly owned subsidiary of Focus LLC and therefore under common
control with us. The allocation of our clients’ assets to Kovitz pursuant to a subadvisory arrangement, rather
than to an unaffiliated investment manager, increases Kovitz’s compensation and the revenue to Focus LLC,
relative to a situation in which our clients’ assets are managed by an unaffiliated manager. Consequently,
Focus LLC has a financial incentive to encourage us to recommend a portion of our clients’ assets be
subadvised by Kovitz, which creates a conflict of interest with those clients who are subadvised by Kovitz.
More information about Focus LLC can be found at www.focusfinancialpartners.com. We believe this
conflict is mitigated because of the following factors: (1) the retention of Kovitz as a subadvisor is based on
our judgment that such retention is in the best interest of our affected clients; (2) Kovitz has met the due
diligence standards that we apply to outside investment managers; (3) we are willing and able to terminate
Kovitz’s services, in part or in whole, if Kovitz’s’ services become unsatisfactory in the judgement of, and at
the sole discretion of, us; and (4) we have fully and fairly disclosed the material facts regarding this
relationship, including in this Brochure, to our clients for whom we recommend that Kovitz serve as
subadvisor, and such clients have therefore given their informed consent to this conflict.
Item 11: Code of Ethics, Participation, or Interest in Client Transactions &
Personal Trading
Code of Ethics Summary
Cornerstone Wealth has adopted a Code of Ethics (“Code”) which establishes standards of conduct for our
supervised persons and includes general requirements that such supervised persons comply with their
fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among
other things, personal trading, insider trading, conflicts of interest and confidentiality of client information.
It contains written policies reasonably designed to prevent the unlawful use of material non-public
information by the Firm or any of our associated persons. The Code also requires that certain of
Cornerstone Wealth personnel (called “Access Persons”) report their personal securities holdings and
transactions and obtain pre- approval of certain investments such as initial public offerings and limited
offerings.
The Code also requires supervised persons to report any violations of the Code promptly to the Firm’s Chief
Compliance Officer. Each supervised person receives a copy of the Code and any amendments to it and must
22
acknowledge in writing having received the materials. Annually, each supervised person must certify that
he or she complied with the Code during that year.
Cornerstone Wealth will provide a copy of its Code of Ethics to any client or prospective client upon request
by contacting us at (704) 987-3410.
Participation or Interest in Client Transactions
It is Cornerstone Wealth’s policy not to enter into any principal transactions or agency cross transactions
on behalf of client accounts. Principal transactions occur where an adviser, acting as principal for its own
account, buys securities from or sells securities to any advisory client. Agency cross transactions occur
where a person acts as an investment adviser in relation to a transaction in which the adviser, or an affiliate
of the adviser, acts as broker for both the advisory client and for another person on the other side of the
transaction.
Employee
Cornerstone Wealth or individuals associated with Cornerstone Wealth may buy or sell for their personal
personal securities trading implies potential conflicts of interest with our clients. We have adopted a Code of
account(s) securities or investment products that Cornerstone Wealth recommends to clients.
Ethics designed to mitigate the potential conflicts through reporting, monitoring and, under certain circumstances,
requiring preclearance of employee securities transactions. A copy of our Code of Ethics is available to clients
upon request.
Cornerstone Wealth recommends that certain of our clients invest in private investment funds managed by an
affiliated Focus partner firm. Please refer to Items 4, 5, and 10 for additional information.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Cornerstone Wealth generally recommends that investment management accounts be maintained
at National Financial Services LLC and Fidelity Brokerage Services LLC (“Fidelity”), as well as
Charles Schwab & Co., Inc. (“Schwab”). Prior to engaging the Firm to provide investment
management services, the client will be required to enter into a formal investment advisory
agreement with Cornerstone Wealth setting forth the terms and conditions under which the Firm
will manage the client's assets, and a separate custodial/clearing agreement with each designated
broker-dealer/custodian.
Factors that the Firm considers in recommending Fidelity and/or Schwab (or any other broker-
dealer/custodian to clients) include historical relationship with Cornerstone Wealth, financial
strength, reputation, execution capabilities, pricing, research, and service. Although the
commissions and/or transaction fees paid by the Firm's clients will comply with the Firm's duty to
obtain best execution, a client may pay a commission that is higher than another qualified broker-
dealer might charge to effect the same transaction where Cornerstone Wealth determines, in good
faith, that the commission/transaction fee is reasonable in relation to the value of the brokerage
and research services received. In seeking best execution, the determinative factor is not the lowest
possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a broker-dealer’s services, including the value of research provided,
execution capability, commission rates, and responsiveness. Accordingly, although Cornerstone
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Wealth will seek competitive rates, it may not necessarily obtain the lowest possible commission
rates for client account transactions. The brokerage commissions or transaction fees charged by
the designated broker-dealer/custodian are exclusive of, and in addition to, Cornerstone Wealth’s
investment management fee. The Firm’s best execution responsibility is fulfilled if securities that it
purchases for client accounts are mutual funds that trade at net asset value as determined at the
Custodian Benefits
daily market close.
Cornerstone Wealth receives from Fidelity and/or Schwab (or another broker-dealer/custodian)
without cost (and/or at a discount) support services and/or products, certain of which assist
Cornerstone Wealth to better monitor and service client accounts maintained at such institutions.
Included within the support services that may be obtained by the Firm may be investment-related
research, pricing information and market data, software and other technology that provide access
to client account data, compliance and/or practice management-related publications, discounted or
gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other
educational and/or social events, marketing support, computer hardware and/or software and/or
other products used by Cornerstone Wealth in furtherance of its investment advisory business
operations.
As indicated above, certain of the support services and/or products that may be received may assist
the Firm in managing and administering client accounts. Others do not directly provide such
assistance, but rather assist the Firm to manage and further develop its business enterprise and
offset costs that Cornerstone Wealth would otherwise be required to bear. In addition, the support
services and/or products provided by a broker-dealer/custodian may be used to service all or a
substantial number of the Firm’s client accounts, including accounts not maintained at the broker-
dealer/custodian providing the services and/or products.
•
Cornerstone Wealth receives the following benefits from Fidelity:
•
•
•
•
Free trading for transaction-based accounts (with e-delivery) for the first 45-days the accounts
are opened;
Receipt of duplicate client confirmations and bundled duplicate statements;
Access to a trading desk that exclusively services its institutional traders;
Access to block trading which provides the ability to aggregate securities transactions and
then allocate the appropriate shares to client accounts; and
Access to an electronic communication network for client order entry and account
information.
Cornerstone Wealth does not consider whether it will receive client referrals in connection with
selecting or recommending broker-dealers.
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Cornerstone Wealth’s clients do not pay more for investment transactions effected and/or assets
maintained at Fidelity and/or Schwab as a result of this arrangement. There is no
corresponding commitment made by Cornerstone Wealth to Fidelity and/or Schwab or any
other entity to invest any specific amount or percentage of client assets in any specific mutual
funds, securities, or other investment products as result of the above arrangement. Also, any
benefits received by Cornerstone Wealth from Fidelity and/or Schwab do not depend on the
amount of brokerage transactions directed to Fidelity and/or Schwab. As part of its fiduciary
duty to clients, Cornerstone Wealth endeavors at all times to put the interests of clients first.
Clients and future clients should be aware, however, that the receipt of economic benefits by
Cornerstone Wealth in and of itself creates a potential conflict of interest and may indirectly
influence the Firm’s recommendation to clients to utilize Fidelity and/or Schwab for custody
and brokerage services.
Brokerage for Client Referrals
The Firm does not direct brokerage for client referrals.
Permissibility of Client-Directed Brokerage
We do not allow client-directed brokerage outside our custodial recommendations.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a
specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is
permitted provided that the goods and services provided are reasonable expenses of the plan incurred in
the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA
prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive
benefit of the plan. Consequently, we request that plan sponsors who direct plan brokerage provide us with
a letter documenting that this arrangement will be for the exclusive benefit of the plan.
Trade Aggregation and Allocation
From time-to-time Cornerstone may determine, based on a variety of reasons, that the purchase or sale of a
particular security, including initial or secondary public offerings (“Public Offerings”), is appropriate for multiple
client accounts. When this happens, Cornerstone may also determine that it is appropriate in the interest of efficient
and effective execution to attempt to execute the trade orders as one or more block trades (i.e. aggregate the
securities to be traded for each such account into one or more trade orders).
Under this process, transactions
will be averaged as to price and will be allocated among clients in proportion to the purchase and sale
orders placed for each client account on any given day. Cornerstone Wealth does not receive any additional
compensation or remuneration as a result of such aggregation.
Trade Errors
Cornerstone’s goal is to execute trades seamlessly and in the best interests of the client. In the event a trade
error by Cornerstone occurs, Cornerstone endeavors to identify the error in a timely manner, correct the
error so that the client’s account is in the same position than it would have been had the error not occurred.
For trade errors for clients custodied with Fidelity, a trade correction account is maintained. If a trade error
is processed through the account, Cornerstone is required to submit, in a timely fashion, a trade correction
request and attestation form. Through such corrective action, the client’s account is placed in the position
than it would have been had there been no error. A trade correction account statement is provided by
Fidelity for periods in which a trade errors occur. The statement lists trade corrections made through the
account during the period. Corrections generally have a gain or loss resulting from market movement
between the time of the error and time of correction. At the end of the month, gains and losses are netted.
A net gain will be sent to a charity of Fidelity’s choice. A net loss is the responsibility of Cornerstone.
Conflicts of interest in maintaining a trade correction account are mitigated by Cornerstone’s policies and
procedures designed to prevent and promptly correct trade errors and the requirement that Fidelity
approve the trade error correction.
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Item 13: Review of Accounts
We review accounts on at least a regular basis, no less than at least annually, but likely more often, for our
clients for whom we manage assets. The nature of these reviews is to learn whether clients’ accounts are
in line with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Financial Planning clients who receive ongoing planning services will
receive annual reviews. Only our Financial Advisors or Portfolio Managers will conduct reviews. We do not
provide written reports to clients, unless asked to do so. Oral reports to clients take place on at least an
annual basis when we contact our clients for whom we manage assets.
We may review client accounts more frequently than described above. Among the factors which may trigger
an off-cycle review are major market or economic events, the client’s life events or requests by the client.
Clients are encouraged to notify the Firm of any changes to his/her personal financial situation that might
affect his/her investment needs, objectives, or time horizon.
Item 14: Client Referrals & Other Compensation
Economic Benefits Received
As noted above in Item 12, Cornerstone Wealth receives certain support services and/or products from
Fidelity and/or Schwab. See Item 12 above for information regarding these support services and/or
products.
Referral Fees
Cornerstone Wealth has arrangements in place with certain third parties, called promoters, under which
such promoters refer clients to us in exchange for a percentage of the advisory fees we collect from such
referred clients. Such compensation creates an incentive for the promoters to refer clients to us, which is a
conflict of interest for the promoters. Rule 206(4)-1 of the Advisers Act addresses this conflict of interest
by, among other things, requiring disclosure of whether the promoter is a client or a non-client and a
description of the material conflicts of interest and material terms of the compensation arrangement with
the promoter. Accordingly, we require promoters to disclose to referred clients, in writing: whether the
promoter is a client or a non-client; that the promoter will be compensated for the referral; the material
conflicts of interest arising from the relationship and/or compensation arrangement; and the material
terms of the compensation arrangement, including a description of the compensation to be provided for
the referral.
Fidelity Wealth Advisor Solutions®
We participate in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which
we receive referrals from Strategic Advisers LLC (Strategic Advisers), a registered investment advisor and
Fidelity Investment company. Cornerstone Wealth is independent and not affiliated with Strategic Advisers
or any Fidelity Investments company. Strategic Advisers does not supervise or control Cornerstone Wealth,
and Strategic Advisers has no responsibility or oversight for Cornerstone Wealth’s provision of investment
management or other advisory services.
Under the WAS Program, Strategic Advisers acts as a promoter for Cornerstone Wealth, and Cornerstone
Wealth pays referral fees to Strategic Advisers for each referral received based on Cornerstone Wealth’s
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assets under management attributable to each client referred by Strategic Advisers or members of each
client’s household. The WAS Program is designed to help investors find an independent investment advisor,
and any referral from Strategic Advisers to us does not constitute a recommendation by Strategic Advisers
of our particular investment management services or strategies. More specifically, we pay the following
amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all
assets in client accounts where such assets are identified as “fixed income” assets by Strategic Advisers and
(ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, Cornerstone
Wealth has agreed to pay Strategic Advisers an annual program fee of $50,000 to participate in the WAS
Program. These referral fees are paid by Cornerstone Wealth and not the client.
To receive referrals from the WAS Program, we must meet certain minimum participation criteria, but we
have been selected for participation in the WAS Program as a result of its other business relationships with
Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its
participation in the WAS Program, Cornerstone Wealth has a conflict of interest with respect to its decision
to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain
client accounts, and we could have an incentive to suggest the use of FBS and its affiliates to its advisory
clients, whether or not those clients were referred to Cornerstone Wealth as part of the WAS Program.
Under an agreement with Strategic Advisers, we have agreed that we will not charge clients more than the
standard range of advisory fees disclosed in our Form ADV 2A Brochure, items 5, Fees & Compensation, to
cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these
arrangements, we have agreed to not to solicit clients to transfer their brokerage accounts from affiliates
of Strategic Advisers or establish brokerage accounts at other custodians for referred client other than
when our fiduciary duties would so require, and we have agreed to pay Strategic Advisers a one-time fee
equal to 0.75% of the assets in a client account that is transferred from Strategic Adviser’s affiliates to
another custodian; therefore, we have an incentive to suggest that referred clients and their household
members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in
the WAS Program does not limit Cornerstone Wealth’s duty to select brokers based on the basis of best
execution.
Other Compensation
Cornerstone Wealth’s parent company Focus, from time to time, holds partnership meetings and other industry
and best-practices conferences, which typically include Cornerstone Wealth, other Focus firms and external
attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus
firms, including Cornerstone Wealth. However, the meetings do provide sponsorship opportunities for asset
managers, asset custodians, vendors, and other third-party service providers. Sponsorship fees allow these
companies to advertise their products and services to Focus firms, including Cornerstone Wealth. Although the
participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target
for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education
activities conducted, and the access granted, at such meetings and conferences could cause Cornerstone Wealth
to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by
allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for
placed with any specific provider or revenue generated by such asset placement.
The following entities have provided conference sponsorship to Focus from January 1, 2025, to February 1,
2026:
• Addepar, Inc.
• AQR Capital Management, LLC
• Bigelow LLC
• BlackRock, Inc.
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• BOWS Administrator LLC (Brookfield Oaktree Wealth Solutiosn)
• Capital Integration Systems LLC (CAIS)
• Charles Schwab & Co., Inc.
• Cliffwater LLC
• Dimensional Fund Advisors LP
• Dinsmore Compliance Services, LLC (DCS)
• Eaton Vance Distributors, Inc (includes Parametric Portfolio Associates)
• Edgewood Partners Insurance Center (EPIC) (includes Vanbridge)
• Fidelity Brokerage Services LLC (includes FIAM and Wealthscape)
• Flourish Financial LLC
• Franklin Templeton Distributors LLC (includes O’Shaughnessy Asset Management L.L.C. (OSAM)
and CANVAS)
Jackson National Life Distributors LLC
•
• K&L Gates, LLP
• Lord, Abbett & Co. LLC
• Nuveen Securities, LLC
• Orion Advisor Solutions, Inc.
• Pacific Investment Management Company LLC (PIMCO)
• Pinnacle Insurance & Financial Servies, LLC
• Practific, Inc.
• Quantinno Capital Management LP (includes TaxEdge and DEALS (Direct Equity Active Long
Short))
• RedBlack Software, LLC (includes intelliflo)
• SmartAsset Advisors, LLC
• Stone Ridge Asset Management LLC
• The Vanguard Marketing Corporation, Inc.
• T. Rowe Price Investment Services, Inc.
• TriState Capital Bank
• VRGL Inc.
https://focusfinancialpartners.com/conference-sponsors/
You can access a more recently updated list of recent conference sponsors on Focus’ website through the
following link:
Certain Cornerstone Wealth supervised persons have outside business activities that provide additional
compensation. Please refer to Item 10 above for detailed information regarding the business activities, the
compensation received, the related conflicts and how Cornerstone Wealth mitigates such conflicts.
Item 15: Custody
We encourage our clients to raise any questions with us about custody, safety, or security of their assets.
All of our clients receive account statements directly from their custodians. Upon opening an account with
a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's
contact information.
We have legal custody over client accounts when we have the authority to debit our fees from client
accounts and when we have authority through standing letters of authorization (“SLOAs”) to direct
transfers to third parties.
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Additional Information Regarding Custody:
Fidelity and Schwab are qualified custodians and maintain custody of client funds and securities in a
separate account for each client under the client’s name. On at least a quarterly basis, your qualified
custodian sends account statements showing all transactions, positions, and all deposits and withdrawals
of principal and income. Clients should carefully review those statements promptly when they receive
them.
Although most securities available in program accounts are held at Fidelity and/or Schwab, there are
certain securities managed as part of the account that are held at third parties. For example, variable
annuities, hedge funds, private placements, managed futures, and other alternative investments are often
held directly with the investment sponsor. For those outside positions, client will receive confirmations and
statements directly from the investment sponsor.
Additional Information for clients regarding custody for accounts utilizing our Advisory Managed
and/or Sub-Adviser of Variable Annuities:
Variable annuity subaccount assets are maintained by the insurance company issuing the variable annuity.
Therefore, the insurance company selects the custodian(s) for subaccounts assets, which are generally
mutual fund companies. Clients will receive confirmations and account statements relating to the variable
annuity directly from the variable annuity insurance company. Clients should advise the insurance
company or the Firm immediately if statements are not being received from the insurance company.
Client will not receive separate performance reports in connection with the investment advisory services
provided by the Firm. Therefore, the client should review the account statements provided by the insurance
company to determine the performance of the subaccount assets from one period to another, and over time.
Item 16: Investment Discretion
We accept discretionary authority to manage securities accounts on behalf of clients. Our clients need to
sign a discretionary investment advisory agreement with the Firm, which contains a limited power of
attorney authorizing discretionary trading of their assets, for the management of such accounts. This type
of agreement only applies to asset management clients. We do not take or exercise discretion with respect
to our other clients.
Item 17: Voting Client Securities
,
We do not accept the proxy authority to vote client securities. Clients will receive proxies or other
solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to the Firm,
we will forward them on to the client. Clients may call, write, or email us to discuss questions they may
have about particular proxy votes or other solicitations. In addition, clients maintain exclusive
including,
responsibility for all legal proceedings or other type events pertaining to their account assets
but not limited to, class action lawsuits.
Item 18: Financial Information
We do not require, nor do we solicit prepayment of more than $1,200 in fees per client, six months or more
in advance. Therefore, we have not included a balance sheet for our most recent fiscal year. Cornerstone
Wealth has never filed for bankruptcy and is not aware of any financial condition that is expected to affect
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its ability to manage client accounts.
Cover Page for Part 2B of Form ADV: Brochure Supplement –
Chief Investment Officer
May 2025
Cliff Hodge
718 Lady Street,
Columbia, SC 29201
704-987-3410
www.cwgadvisors.com
This brochure supplement provides information about Mr. Hodge that supplements our brochure. You should have received
a copy of that brochure. Please contact Rachel Posner, Chief Compliance Officer, if you did not receive our firm’s brochure
or if you have any questions about the contents of this supplement. Additional information about Mr. Hodge is available on
the SEC’s website at www.adviserinfo.sec.gov.
30
Item 2: Educational Background & Business Experience
Cliff Hodge, CFA®
Born 11/6/1985
Educational Background:
• Clemson University, BA Economics; 2008
• MBA University of South Carolina; 2014
Business Background:
•
•
•
•
•
•
04/2018 – Present; Cornerstone Wealth Group, LLC; Chief Investment Officer, Partner
07/2015 – 04/2018; FinTrust Capital Partners, INC; Portfolio Manager
08/2013 – 07/2015; Vanguard; Financial Analyst
06/2011 – 08/2013; Vanguard; HNW Relationship Manager
08/2010 – 05/2011; Vanguard; Client Service Specialist
06/2008 – 08/2010; Vanguard; Client Relationship Associate
Examinations and Designations:
•
CFA® Charterholder
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential
established in 1962 and awarded by CFA Institute – the largest global association of investment professionals. To
earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years
of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and
annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. The
CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn
the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the
dynamic and complex nature of the profession. To learn more about the CFA charter, visit www.cfainstitute.org.
Item 3: Disciplinary Information
For a review of Mr. Hodge’s disclosure or disciplinary history you can go BrokerCheck.finra.org and
https://adviserinfo.sec.gov/IARD/IARDsearch.aspx
Item 4: Other Business Activities
Mr. Hodge is on the board at the American Funds RIA Advisory Board.
Item 5: Additional Compensation
Mr. Hodge does not receive any other economic benefit outside of his salary and bonus structure.
Item 6: Supervision
We have implemented a compliance program designed to monitor the investment activities of the Firm’s
personnel. Any questions about the compliance program should be directed to Rachel Posner, Chief Compliance
Officer, who can be reached at (704) 987-3410. As Chief Executive Officer, Craig Rubrecht is responsible for the
supervision of the Firm’s personnel. Mr. Rubrecht can be reached by calling the number above.
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PRIVACY NOTICE REGARDING CLIENT PRIVACY AS REQUIRED BY
REGULATION S-P & REGULATION S-AM
WHAT DOES CORNERSTONE WEALTH GROUP, LLC
(“CORNERSTONE WEALTH”) DO WITH YOUR
PERSONAL INFORMATION?
FACT
Why?
Financial companies choose how they share your personal information. Federal
law gives consumers the right to limit some but not all sharing. Federal law also
requires us to tell you how we collect, share, and protect your personal
information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect, and share depends on the
product or service you have with us. This information can include:
Social Security number, name, address, and income
Assets, account balances and account transactions
Investment experience and risk tolerance
When you are no longer a customer, we continue to share your information as
described in this notice.
How?
All financial companies need to share customers’ personal information to run their
everyday business. In the section below, we list the reasons financial companies
can share their customers’ personal information; the reasons Cornerstone Wealth
chooses to share; and whether you can limit this sharing.
Reasons we can share your personal
Does Cornerstone
Can you limit this
Yes
No
For our everyday business purposes
such as to process your transactions, maintain
your account(s), respond to court orders and
legal investigations, or report to credit bureaus
Yes
No
For our marketing purposes
to offer our products and services to you
No
We do not share
For joint marketing with other financial
companies
Yes
No
For our affiliates’ everyday business purposes
information about your transactions and experiences
No
We do not share
For our affiliates’ everyday business purposes
information about your creditworthiness
For non-affiliates to market to you
We do not share
No
What we do
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How does Cornerstone
Wealth protect my
personal information?
To protect your personal information from unauthorized access
and use, we use security measures that comply with federal
law. These measures include computer safeguards and
secured files and buildings.
tell us about your portfolio or deposit money
How does Cornerstone
Wealth collect my
personal information?
We collect your personal information, for example, when you
open an account or give us your income information
enter into an investment advisory contract
We also collect your personal information from other companies.
Federal law gives you the right to limit only
sharing for affiliates’ everyday business purposes—
Why can’t I limit all
sharing?
information about your creditworthiness
affiliates from using your information to market to you
sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights
to limit sharing.
Definitions
Affiliates
Companies related by common ownership or control. They can be
financial and nonfinancial companies.
Our affiliates include Focus Operating, LLC, Focus Risk Solutions,
LLC, Williams Jones Wealth Management, LLC, and SCS Capital
Management, LLC.
Non-affiliates
Companies not related by common ownership or control. They can be
financial and nonfinancial companies. Cornerstone Wealth does not
share with nonaffiliates so they can market to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
Cornerstone Wealth does not jointly market.
Additional Information:
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