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PART 1 ITEM 1 – COVER PAGE
FORM ADV PART 2A – FIRM BROCHURE
FEBRUARY 20, 2026
CORRECT CAPITAL WEALTH MANAGEMENT, LLC.
130 SOUTH BEMISTON AVENUE, SUITE 602
CLAYTON, MO 63105
314-930-4015
WWW.CORRECTCAP.COM
This brochure provides information about the qualifications and business practices of Correct Capital Wealth
Management, LLC. (“Correct Capital”). If you have any questions about the contents of this brochure, please
contact us at 314-930-4015. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority. Correct Capital is a Registered
Investment Adviser. Registration as an Investment Adviser with the United States Securities and Exchange
Commission or any state securities authority does not imply a certain level of skill or training.
Additional information about Correct Capital is available on the SEC’s website at www.adviserinfo.sec.gov. You can search
this site by a unique identifying number, known as a IARD number. The IARD number for Correct Capital is 298774.
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been incorporated since
our
last delivery or posting of this document on the SEC’s public disclosure website (IAPD)
www.adviserinfo.sec.gov. Our last annual ADV amendment update was dated March 13, 2025. The
following material changes have been made:
-
Pintip Perdun was named Chief Compliance Officer.
Currently, a free copy of our Brochure may be requested by contacting Pintip Perdun at 314-930-4015, or
pintip@correctcap.com. We encourage you to read this document in its entirety.
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FEBRUARY 2026 | PAGE 2
ITEM 3 - TABLE OF CONTENTS
ITEM 1 – COVER PAGE ............................................................................................................................. 1
ITEM 2 – MATERIAL CHANGES .................................................................................................................. 2
ITEM 4 – ADVISORY BUSINESS ................................................................................................................. 4
ITEM 5 - FEES AND COMPENSATION ........................................................................................................ 9
ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................. 14
ITEM 7 - TYPES OF CLIENTS ..................................................................................................................... 14
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .................................. 14
ITEM 9 - DISCIPLINARY INFORMATION ................................................................................................... 20
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 20
ITEM 11 - CODE OF ETHICS ..................................................................................................................... 21
ITEM 12 - BROKERAGE PRACTICES .......................................................................................................... 22
ITEM 13 - REVIEW OF ACCOUNTS ........................................................................................................... 25
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 26
ITEM 15 – CUSTODY ............................................................................................................................... 26
ITEM 16 – INVESTMENT DISCRETION ..................................................................................................... 27
ITEM 17 – VOTING YOUR SECURITIES ..................................................................................................... 27
ITEM 18 – FINANCIAL INFORMATION ..................................................................................................... 27
CORRECT CAPITAL WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 3
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Correct Capital Wealth Management, LLC (“Correct
Capital” or “Firm”) about the investment advisory services we provide. It discloses information about our
services and the way those services are made available to you, the client.
We are an investment management firm located in Clayton, Missouri. We specialize in investment advisory
services for individuals, high net worth individuals, corporations and other businesses, pension and profit-
sharing plans, trusts, estates and charitable organizations. Our Firm was founded in 2018 as a registered
investment adviser and is majority owned by Brian I. Pultman.
We are committed to helping clients build, manage, and preserve their wealth, and provide clarity and
direction to help clients achieve their stated financial goals. We will offer an initial complimentary meeting
upon our discretion; however, investment advisory services are initiated only after you and Correct Capital
execute a signed Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts,
once we have determined a profile and investment plan with a client, we will execute the day-to-day
transactions without seeking prior client consent. Account supervision is guided by the written profile and
investment plan of the client. We may accept accounts with certain restrictions if circumstances warrant.
We primarily allocate client assets among various equities such as preferred stocks, commons stocks,
Exchanged Traded Funds (“ETFs”), CDs, no-load or load-waived mutual funds, cash and fixed income
positions in accordance with their stated investment objectives. All of which are considered asset allocation
categories for the client’s investment strategy.
During discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family
composition and background. Based on client needs, we develop a client’s personal profile and investment
plan. We then create and manage the client’s investments based on that policy and plan.
It is the client’s obligation to notify us immediately if circumstances have changed with respect to their
goals or changes in their personal financial condition.
Once we have determined the types of investments to be included in your portfolio and allocated them, we
will provide ongoing investment review and management services. This approach requires us to review
your portfolio periodically.
We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is
managed in a manner consistent with those needs and objectives. You will have the ability to leave standing
instructions with us to refrain from investing in particular industries or invest in limited amounts of
securities.
In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in
a pool of securities. We do have limited authority to direct the custodian to deduct our investment advisory
fees from your accounts, but only with the appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
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FEBRUARY 2026 | PAGE 4
such as variable life insurance, annuity contracts, 529 Plans and assets held in employer-sponsored
retirement plans. In these situations, Correct Capital directs or recommends the allocation of client assets
among the various investment options available with the product. These assets are generally maintained at
the underwriting insurance company or the custodian designated by the product’s provider.
You are advised and are expected to understand that our past performance is not a guarantee of future
results. Certain capital market and economic risks exist that adversely affect an account’s performance. This
could result in capital losses in your account.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the
family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated
effort of all parties toward the client’s stated goals. Such services include various reports on specific goals
and objectives or general investment and/or planning recommendations, guidance to outside assets, and
periodic updates.
Our specific services in preparing your plan may include:
● Review and clarification of your financial goals.
● Assessment of your overall financial position including cash flow, balance sheet, investment strat-
egy, risk management, and estate planning.
● Creation of a unique plan for each goal you have, including personal and business real estate, ed-
ucation, retirement or financial independence, charitable giving, estate planning, business succes-
sion, and other personal goals.
● Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention.
● Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
including liquidity as well as various insurance and possible company benefits; and
● Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax
advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the client. For younger
generational clients or clients in accumulation mode, on-going quarterly financial planning/coaching
services are offered. A quarterly review and summary of Financial Planning and coaching is delivered to
those who opt for this quarterly service. Services are agreed to between the Client and Correct Capital using
a separate Financial Planning Agreement.
Clients should be aware a conflict exists between the interests of the investment adviser and the interests
of the client. The client is under no obligation to act upon the investment adviser's recommendation, and
if the client elects to act on any of the recommendations, the client is under no obligation to affect the
transaction through the investment adviser.
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RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services includes providing participant enrollment meetings and assisting with
participant education. While the primary clients for these services will be pension, profit sharing and 401(k)
plans, we offer these services, where appropriate, to individuals and trusts and organizations.
When serving as an ERISA 3(21) investment advisor, the Plan Sponsor, and our Firm share fiduciary
responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may
accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor
Investment Management Agreement between our Firm and the Plan Sponsor. Under the 3(21) agreement,
Our Firm provides the following services to the Plan Sponsor:
Screen investments and make recommendations.
Provide a quarterly monitoring report.
Monitor the investments and suggests replacement investments when appropriate.
Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
Recommend QDIA alternatives.
Recommend non-discretionary model portfolios.
As a result of this a 3(38) fiduciary appointment, we are granted full trading authority over the Plan and
have the sole responsibility for the selection and monitoring of all investment options offered under the
Plan in accordance with the investment policy statement and its underlying investment objectives and
strategies for the Plan. Plan participants have the ability to exercise control over the assets in their account,
and we have no authority or discretion to direct the investment of assets of any participant’s account under
the Plan unless otherwise authorized in writing by the Participant in the Plan.
All retirement planning services are in compliance with any applicable State law(s) regulating the services
we provide. This section applies to an account that is a pension or other employee benefit plan (a “Plan”)
governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If your account
is part of a pension or other employee benefit plan (a “Plan”) governed by the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and we accept appointment to provide our services to Plan
accounts, we acknowledge that we are a fiduciary within the meaning of Section 3(21) or Section 3(38) of
ERISA as selected by each retirement plan client. You represent that (i) Our appointment and services are
consistent with the Plan documents, (ii) You have furnished us true and complete copies of all documents
establishing and governing the Plan and evidencing your authority to retain our firm. You further represent
that you will promptly furnish us with any amendments to the Plan, and you agree that, if any amendment
affects our rights or obligations, such amendment will be binding on us only with our prior written consent.
If your account contains only a part of the assets of the Plan, we will have no responsibilities for the
diversification of all the Plan’s investments, and we have no duty, responsibility or liability for the assets
that are not in the account.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial
education to Plan participants, participant seminars, benchmarking the Plan services, education to fiduciary
committee members, and monitoring the service provider. The scope of education provided to participants
will not constitute “investment advice” within the meaning of ERISA, and participant education will relate
to general principles for investing and information about the investment options currently in the Plan. We
may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for
new participants.
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THIRD PARTY MONEY MANAGERS
Our Firm may determine that engaging the expertise of an independent third-party money manager
(“TPMM’) is best suited for the client’s account. If deemed appropriate for the client, our Firm will
recommend utilizing an independent TPMM to aid in the implementation of investment strategies for the
client’s portfolio. In certain circumstances, we may allocate a portion of a portfolio to the TPMM for
separate account management based upon the client’s individual circumstances and objectives, including,
but not limited to, your account size and tax circumstances. Upon the recognition of such situations, in
coordination with the client, the client will engage directly with the TPMM for the management of those
assets. These TPMMs shall assist our Firm in managing the day‐to‐day investment operations of the
various allocations, shall determine the composition of the investments comprising the allocation, shall
determine what securities and other assets of the allocation will be acquired, held, disposed of or loaned
in conformity with the written investment objectives, policies, and restrictions and other statements of
each client comprising the allocation, or as instructed by our Firm.
TPMMs selected for your investments need to meet several quantitative and qualitative criteria established
by us. Among the criteria that may be considered are the TPMM’s experience, assets under management,
performance record, client retention, the level of client services provided, investment style, buy and sell
disciplines, capitalization level, and the general investment process.
The client is advised and should understand that:
A TPMM’s past performance is no guarantee of future results;
There is a certain market and/or interest rate risk which may adversely affect any TPMM’s
objectives and strategies, and could cause a loss in a client's account(s); and
Client risk parameters or comparative index selections provided to our Firm are guidelines only,
and there is no guarantee that they will be met or not be exceeded.
TPMMs take discretionary authority to determine the securities to be purchased and sold for the client. Our
Firm will work with the TPMM to communicate any trading restrictions or standing instructions to refrain
from a particular industry requested by the client. In all cases, trading restrictions will depend on the TPMM
and their ability to accommodate such restrictions.
We review the performance of our TPMMs on a periodic basis. More frequent reviews may be triggered by
changes in the TPMM’s management, performance or geopolitical and macroeconomic specific events.
Our Firm only enters into only a select number of relationships with TPMMs.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
(iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result,
our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client
or prospective client leave their plan assets with their previous employer or roll over the assets to a plan
sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has
an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which
presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm
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FEBRUARY 2026 | PAGE 7
will consider before recommending a rollover, including but not limited to: (i) the investment options
available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan
versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment
professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any.
All rollover recommendations are also reviewed by our Firm’s Chief Compliance Officer in a best effort to
determine that the recommendation to a client was reasonable or that the client has determined to make
the rollover after being provided ample information about their options. No client is under any obligation
to roll over plan assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the
account while maintained with the client's employer. Our Firm’s Chief Compliance Officer remains available
to address any questions that a client or prospective client has regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
ENVESTNET PRIVATE WEALTH MANAGEMENT
We offer separately managed account services through Envestnet’s Private Wealth Management program.
For all Programs, we will compile pertinent financial and demographic information to develop an
investment program that will meet your goals and objectives. Utilizing the Envestnet platform tools, your
assets will be allocated among the different options in the Program and determine the suitability of the
asset allocation and investment options, based on your needs and objectives, investment time horizon, risk
tolerance and any other pertinent factors.
Envestnet provide an extensive range of investment advisory services through their platform. We will
primarily be utilizing the Unified Management Account (“UMA”) program. For those clients selecting the
UMA program, you are offered access to an actively managed investment portfolio chosen from a roster of
independent asset managers from a variety of disciplines. Unlike a mutual fund, where the funds are
commingled, a separately managed account is a portfolio of individually owned securities that can be
tailored to fit your investing preferences.
Envestnet will assist Correct Capital in identifying individual asset managers and investment vehicles that
correspond to the proposed asset classes and styles Envestnet may independently identify asset managers
Envestnet retain the independent asset managers for portfolio management services in connection with
the UMA program through separate agreements entered into between Envestnet and these independent
managers on terms and conditions that Envestnet deems appropriate. Envestnet will additionally provide
account billing and reporting for all CCWM clients.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern.
Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance,
real estate, and/or advice. In these consultation engagements, you will be required to select your own
investment managers, custodian and/or insurance companies for the implementation of consulting
recommendations. If your needs include brokerage and/or other financial services, we will recommend the
CORRECT CAPITAL WEALTH MANAGEMENT, LLC
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use of one of several investment managers, brokers, banks, custodians, insurance companies or other
financial professionals. You must independently evaluate these firms before opening an account or
transacting business, and you have the right to effect business through any firm you choose.
WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions,
we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Avoid misleading statements about conflicts of interest, fees, and investments;
•
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
PERIODS OF INACTIVITY
Correct Capital has a fiduciary duty to provide services consistent with the client’s best interest. As part of
its investment advisory services, Correct Capital will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not limited to,
investment performance, fund manager tenure, style drift, and/or a change in the client’s investment
objective. Based upon these factors, there may be extended periods of time when Correct Capital
determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated
below, there can be no assurance that investment decisions made by Correct Capital will be profitable or
equal any specific performance level(s). Clients nonetheless remain subject to the fees described in Item 5
below during periods of account inactivity.
ASSETS
As of December 31, 2025, we have $889,349,810 in regulatory assets under management. We manage
$601,040,665 under discretionary management and $288,309,104 under non-discretionary management.
ITEM 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment Management services on your account.
These services include advisory services, trade entry, investment supervision, and other account
maintenance activities. Our Custodians charges transaction costs, custodial fees, redemption fees,
retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for
details.
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Our annual investment advisory fee varies between 65 and 150 basis points (0.65% - 1.50%). The specific
advisory fees are set forth in your Investment Advisory Agreement with our Firm. Fees may vary based on
the size of the account, complexity of the portfolio, extent of activity in the account, or other reasons agreed
upon by us and you as the client. In certain circumstances, our fees and the timing of the fee payments may
be negotiated. Our employees and their family-related accounts are charged a reduced fee for our services.
Fees are billed quarterly in advance based on the average daily balance of the account(s) during the
previous quarter. Fees are assessed on all assets under management, including securities, cash, and money
market balances. Margin account balances are not included in the fee billing. New accounts are billed at
the end of the quarter in which assets are transferred based on the quarter end balance. If assets in excess
of $10,000 are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is adjusted to reflect the interim change in portfolio value. Other
advisers may have higher or lower fees than Correct Capital. Dividends or trade date settlements may occur,
and our third-party billing software may report a slight difference in account valuation at quarter end
compared to what is reported on your Statement from the Custodian.
The independent and qualified custodian holding your funds and securities will debit your account directly
for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be
paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to
deliver an account statement to you at least a quarterly basis indicating all the amounts deducted from the
account including our advisory fees. Client can elect to be directly billed as an alternative.
Unless instructed by the client, we will aggregate asset amounts in accounts from the same household
together to determine the advisory fee for all accounts. We would do this, for example, where we also
service accounts on behalf of minor children, individual and joint accounts for a spouse, and/or other types
of related accounts. This consolidation practice is designed to allow the client to benefit from an increased
asset total, which could potentially cause the account(s) to be assessed a lower advisory fee. Either Correct
Capital, or you may terminate the management agreement immediately upon written notice to the other
party. The management fee will be pro-rated to the date of termination for the month in which the
cancellation notice was given and the refunded.
Upon termination, you are responsible for monitoring the securities in your account, and we will have no
further obligation to act or advise with respect to those assets. In the event of the client’s death or disability,
Correct Capital will continue the management of the account until we are notified of the client’s death or
disability and given alternative instructions by an authorized party. Mutual Funds and ETFs charge
additional fees not included in Correct Capital’s fee.
RETIREMENT PLAN CONSULTING SERVICES
For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client
and as disclosed in the Employer Sponsored Retirement Plans Investment Agreement (“Plan Investment
Advisory Agreement”).
Typically, the billing period for these fees are paid quarterly. This fee is generally negotiable, but terms and
advisory fee is agreed to in advance and acknowledged by the Plan Sponsor through the Plan Investment
Advisory Agreement and/or Plan Provider’s account agreement. Fee billing methods vary depending on the
Plan Provider.
Plan advisory services begin with the effective date of the Plan Investment Advisory Agreement. For Plans
where our fee is paid out of Plan assets, the fee is deducted directly from the participant accounts. Written
CORRECT CAPITAL WEALTH MANAGEMENT, LLC
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authorization permitting us to be paid directly from the custodial account is outlined in the Plan Investment
Advisory Agreement.
Either party may terminate the Plan Investment Advisory Agreement at any time upon immediate notice.
The client is responsible to pay for services rendered until the termination of the agreement.
THIRD PARTY MONEY MANAGER (“TPMM”) FEES AND SERVICES
Fees and billing methods are outlined in each respective TPMM’s Brochure and Advisory Contract. The client
pays an on-going fee directly to the TPMM based upon a percentage of your assets under management
with respect to each TPMM. You will receive disclosure of all fees by the TPMM, which include the terms
of the compensation arrangement and a description of the compensation paid, at the time of signing an
advisory agreement with the TPMM. The minimum account size will vary from TPMM to TPMM. All such
minimums will be disclosed in the respective TPMM’s Brochure. We may have the ability to negotiate such
minimums for you. The fee to Correct Capital is typically an added fee to the fee you pay the TPMM. Details
are discussed with you and are disclosed in the management agreements.
You may terminate your relationship in accordance with the respective TPMMs’ disclosure documents. We
may recommend you terminate the relationship with a TPMM. Factors involved in the termination of a
TPMM may include a failure to adhere to their stated management style or your objectives, a material
change in the professional staff of the TPMM, unexplained poor performance, unexplained inconsistency
of account performance, or our decision to no longer include the TPMM on our list of approved TPMMs.
Account custodial services may be provided by several account custodians depending on the investment
management program offered. Programs may have higher or lower fees than other programs available
through Correct Capital or available elsewhere. Investment management programs may differ in the
services provided, and method or type of management offered, and each may have different account
minimums. Client reports will depend upon the management program selected. Please see the complete
details in the program brochure and custodial account agreement for each program recommended and
offered.
FINANCIAL PLANNING FEES
Fees for financial planning services will vary based on the extent and complexity of your individual or family
circumstances, your financial situation, agreed upon deliverables, and whether or not you intend to
implement any recommendations through Correct Capital. Correct Capital offers one-time financial plans
for a fixed fee. Financial Planning fees range from $2,500 to $10,000.
For younger generational clients or clients
in accumulation mode, on-going quarterly financial
planning/coaching services range from $900- $2000. This fee is agreed to between the Client and Correct
Capital using a separate Agreement. Financial planning services can be terminated at any point by either
Correct Capital or the client.
Typically for a one-time financial plan, we complete and present a plan to you within 120 days of the
contract date, provided all information needed to prepare the financial plan is provided on a timely basis.
Your billing method is agreed to in advance of performing services and is agreed to and acknowledged in
the Financial Planning Agreement executed by you and our Firm. Fifty percent (50%) of the Financial
Planning Fee is collected upon signing the Financial Planning agreement and the other fifty percent is due
upon delivery of the Plan to you.
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For the ongoing financial planning services, we complete and present a financial planning status report to
you on a quarterly basis, provided all information needed to prepare a report is provided on a timely basis.
Your billing method is agreed to in advance of performing services and is agreed to and acknowledged in
the Financial Planning Agreement executed by you and our Firm. Ongoing financial planning fees are
typically billed quarterly in advance.
Financial Planning fees can be paid via check to Correct Capital or can be invoiced and processed through a
third-party nonaffiliated service, AdvicePay. With AdvicePay, Clients will be asked to set up their bank
account or credit card at AdvicePay to enable credit card or ACH payments. While AdvicePay allows firms
like Correct Capital to receive payments directly from the client’s credit card or bank account, it does not
give Correct Capital access to the bank account itself, nor to any of the client’s credit card or bank account
information. Correct Capital is not able to initiate any additional payments via AdvicePay as agreed upon
and outlined in the Agreement.
Financial planning services can be terminated at any point by either Correct Capital or the client. You may
terminate the Financial Planning Agreement by providing us with written notice. In the event you terminate
your Financial Planning Agreement before your Plan is delivered, we will bill you for the time spent in
preparing your Plan based on an hourly rate not to exceed $250/hr. Any prepaid fees will be refunded to
you for services that are not rendered. We will not require prepayment of more than $1,200 in fees per
client, six (6) or more months in advance of providing any services.
When both investment management or plan implementation and financial planning services are offered,
there is a conflict of interest since there is an incentive for us offering financial planning services to
recommend products or services for which Correct Capital receives compensation. However, Correct
Capital will make all recommendations independent of such considerations and based solely on our
obligations to consider your objectives and needs. As a financial-planning client, you have the right not to
act upon any of our recommendations and not affect the transaction(s) through us if you decide to follow
the recommendations.
ENVESTNET ADVISORY FEES
The fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account
on the last day of the previous quarter. Fees may be negotiated in rare instances. Fees will generally be
automatically deducted from your managed account. In rare cases, our firm agrees to direct invoice.
There is a program fee (each, a “Program Fee”) that will not exceed a combined rate of 1.5%. The level of
the Program Fee will vary with the amount of assets under management and the particular investment
styles and investment options chosen or recommended. Program Fees are calculated as an annual
percentage of the assets under management based on the market value of the account at the end of each
quarter. Unless otherwise agreed to by you, Program Fees are charged on a calendar quarter basis in advance
and prorated to the end of the quarter upon inception of the account. Since Envestnet bills clients
individually, they deduct the Program Fees from your accounts and make the appropriate disbursements.
CONSULTING FEES
We provide consulting services for clients who need advice on a limited scope of work. We will negotiate
consulting fees with the client. The range of fees for Consulting Services may vary based on the extent and
complexity of the consulting project. Fees will be billed as services are rendered. Either party may terminate
the agreement. Upon termination, fees will be prorated to the date of termination and any unearned
portion of the fee will be refunded to you as described in the Agreement.
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ADMINISTRATIVE SERVICES PROVIDED BY BLACK DIAMOND
We have contracted with Black Diamond to utilize its technology platforms to support data reconciliation,
performance reporting, fee calculation, client relationship maintenance, performance evaluations, and
other functions related to the administrative tasks of managing client accounts. Due to this arrangement,
Black Diamond will have access to client accounts, but does not serve as an investment adviser to our clients
or bill the accounts. Correct Capital and Black Diamond are non-affiliated companies. Black Diamond
charges our Firm an annual fee for each account administered by its software. Please note that the fee
charged to the client will not increase due to the annual fee Correct Capital pays to Black Diamond.
ADDITIONAL FEES AND EXPENSES
In addition to the advisory fees paid to our Firm, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions
(collectively “Financial Institutions”). These additional charges will include securities transaction fees,
custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund
company or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Correct
Capital’s brokerage practices are described at length in Item 12, below. Legacy assets that pay a trail will be
received by supervised persons of Correct Capital. Further, our Firm does not share in any of these
additional fees and expenses outlined above.
Correct Capital may include mutual funds and exchange-traded funds (“ETFs”) in our investment strategies.
Correct Capital’s policy is to purchase institutional share classes of those mutual funds selected for the
client’s portfolio. The institutional share class generally has the lowest expense ratio. The expense ratio is
the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets
deducted each fiscal year for funds expenses, including 12b-1 fees, management fees, administrative fees,
operating costs, and all other asset-based costs incurred by the fund. Some fund families offer different
classes of the same fund, and one share class may have a lower expense ratio than another share class.
These expenses come from client assets which could impact the client’s account performance. Mutual fund
expense ratios are in addition to the Correct Capital fee, and we do not receive any portion of these charges.
If an institutional share class is not available for the mutual fund selected, the adviser will purchase the least
expensive share class available for the mutual fund. As share classes with lower expense ratios become
available, Correct Capital may use them in the client’s portfolio, and/or convert the existing mutual fund
position to the lower-cost share class. Clients who transfer mutual funds into their accounts with Correct
Capital would bear the expense of any contingent or deferred sales loads incurred upon selling the product.
If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the
fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). All mutual fund expenses and fees are
disclosed in the respective mutual fund prospectus.
The mutual fund and exchange-traded fund companies that choose to participate in your custodian’s NTF
fund program pay a fee to be included in the NTF program. The fees paid by these companies to participate
in the program are ultimately borne by the owners of the mutual fund or exchange-traded fund including
clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we
consider our expected holding period of the fund, the position size and the expense ratio of the fund versus
alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best
interest.
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ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client
account (so-called performance-based fees), nor engage side by side management.
ITEM 7 - TYPES OF CLIENTS
Correct Capital offers investment advice to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations and other business entities.
Our Firm maintains a $500,000 minimum in aggregate investable assets. In certain instances, at the
discretion of our Firm, this minimum may be waived.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Correct Capital Wealth Management analyzes securities we may use for Client’s accounts based upon two
methodologies:
Fundamental Analysis. Defined as a method of evaluating a security that considers future, intrin-
sic value by reviewing related economic, financial and other factors. We consider as many data
points as we can that might affect the security’s value.
Technical Analysis. Defined as an analysis discipline used for forecasting the direction of stock /
market prices through the study of past market data, primarily price and volume. Many believe
technical analysis is a key component of active portfolio management; we believe that the utiliza-
tion of both fundamental and technical analysis provides Correct Capital Wealth Management
with our best understanding of our conclusions and assumptions.
In concert with our analysis methodology, we utilize several tools to conduct our internal (and proprietary)
research / analysis. These tools include, but are not limited to:
Standard and Poors
Market data
Liquidity debt ratios
52-week average forecasts
Internal research
Charting software to best align portfolio decisions with risk / reward objectives
We also may determine to overweight or underweight a certain market sector or market capitalization of a
security based on our assessment of the various datapoints.
We utilize our model portfolios as a guide to build efficient portfolios for each Client, based upon your risk
profile and objectives and the resulting correlation between your needs and each model.
As long-term investors (we typically hold positions for 24 months, although market conditions can impact
our decision making), we define our entrance and exit strategies for individual security positions. Of course,
we utilize asset allocation and protect portfolios by limiting the exposure of any one equity security,
typically (but not always) to 10% or less of the portfolio value at purchase. In addition to asset allocation,
we also use beta and standard deviation that coincide with our risk / reward assumptions.
CORRECT CAPITAL WEALTH MANAGEMENT, LLC
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Asset allocation also attempts to mitigate portfolio exposure (risk) by covering all equity sectors, and in
some cases, asset classes. When using cash or the fixed income asset class, we may include:
Short, intermediate or long-term US Treasury securities
Credit bonds
Agencies
Corporate
Municipal bonds; and,
Preferred equity
We can also purchase, sell or hold:
Individual stocks
Bonds
ETFs
UITs
Mutual Funds
RETIREMENT PLANS:
In formulating our investment advice and managing assets within a defined contribution plan, we review
and assess the performance of the investment options within a plan to ensure a broad range of investment
opportunities are available to participants. We also review and assess the performance of the investment
options to ensure they reflect the broad spectrum appropriate to the age and risk tolerance of plan
participants. We evaluate the cost of each investment with respect to alternative investments of a similar
nature. We evaluate Model Portfolios and Target Date Funds with respect to their suitability for the age
band specified by the investment.
RISK OF LOSS
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients should never assume that future performance of any specific investment or investment
strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different
types of investments, there will be varying degrees of risk. Clients and prospective clients should be
prepared to bear investment loss, including loss of original principal.
Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or general declines.
Investors should be aware that accounts are subject to the following risks:
MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic,
political, and issuer-specific events will cause the value of securities to rise or fall. Because the
value of investment portfolios will fluctuate, there is the risk that you will lose money, and your
investment may be worth more or less upon liquidation.
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-
market securities include exposure to risks such as currency fluctuations, foreign taxes and
regulations, and the potential for illiquid markets and political instability.
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CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited
resources or less diverse products or services. Their stocks have historically been more volatile
than the stocks of larger, more established companies.
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities may be adversely affected.
CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may affect a security’s value and thus, impact the fund’s
performance.
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an
active market for shares, losses from trading in the secondary markets, and disruption in the
creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading
at either a premium or a discount to its “net asset value.”
PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the
asset allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
LIQUIDITY RISK: Liquidity risk is the risk that there may be limited buyers for a security when an
investor wants to sell. Typically, this results in a discounted sale price in order to attract a buyer.
DEFAULT RISK - A default occurs when an issuer fails to make payment on a principal or interest
payment.
EVENT RISK - Event risk is difficult to predict because it may involve natural disasters such as
earthquakes or hurricanes, as well as changes in circumstance from regulators or political bodies.
POLITICAL RISK - Political risk is the risk associated with the laws of the country, or to events
that may occur there. Particular political events such as a government’s change in policy could
restrict the flow of capital.
DURATION RISK - Duration is a way to measure a bond's price sensitivity to changes in interest
rates. The duration of a bond is determined by its maturity date, coupon rate, and call feature.
Duration is a method to compare how different bonds will react to interest rate changes. If a bond
has a duration of five (5) years, it means that the value of that security will decline by
approximately five percent (5%) for every one percent (1%) increase in interest rates.
REINVESTMENT RISK: Reinvestment risk is the risk that future interest and principal payments
may be reinvested at lower yields due to declining interest rates.
TAX RISK: For municipal bonds, depending on the client’s state of residence, the interest earned
on certain bonds may not be tax-exempt at the state level. Also, changes in federal tax policy may
impact the tax treatment of interest and capital gains of an investment.
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REGULATORY RISK: Market participants are subject to rules and regulations imposed by one or
more regulators. Changes to these rules and regulations could have an adverse effect on the value
of an investment.
CONCENTRATION RISK: The risk of amplified losses that may occur from having a large portion
of your holdings in a particular investment, asset class or market segment relative to your overall
portfolio.
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money
because the borrower fails to return the securities in a timely manner or at all. The fund could also
lose money if the value of the collateral provided for loaned securities, or the value of the
investments made with the cash collateral, falls. These events could also trigger adverse tax
consequences for the fund.
CYBERSECURITY RISK - In addition to the Material Investment Risks listed above, investing
involves various operational and “cybersecurity” risks. These risks include both intentional and
unintentional events at our firm or one of its third-party counterparties or service providers, that
may result in a loss or corruption of data, result in the unauthorized release or other misuse of
confidential information, and generally compromise our Firm’s ability to conduct its business. A
cybersecurity breach may also result in a third-party obtaining unauthorized access to our clients’
information, including social security numbers, home addresses, account numbers, account
balances, and account holdings. Our Firm has established business continuity plans and risk
management systems designed to reduce the risks associated with cybersecurity breaches.
However, there are inherent limitations in these plans and systems, including those certain risks
may not have been identified, in large part because different or unknown threats may emerge in
the future. As such, there is no guarantee that such efforts will succeed, especially because our
Firm does not directly control the cybersecurity systems of our third-party service providers. There
is also a risk that cybersecurity breaches may not be detected.
COMMODITIES RISK - Exposure to commodities in Adviser Clients accounts is in non-physical
form, such as ETFs or mutual funds, there are risks associated with the movement in gold prices
and the ability of the fund or trust manager to respond or deal with those price movements. There
also may be initial charges as well as annual management fees associated with the fund or trust.
OPTION RISK: Variable degree of risk. Transactions in options carry a high degree of risk.
Purchasers and sellers of options should familiarize themselves with the type of option (i.e., put or
call) which they contemplate trading and the associated risks. Traders of options should calculate
the extent to which the value of the options must increase for the position to become profitable,
taking into account the premium and all transaction costs.
o The purchaser of options may offset or exercise the options or allow the options to expire.
The exercise of an option results either in a cash settlement or in the purchaser acquiring
or delivering the underlying interest. If the option is on a future, the purchaser will acquire
a futures position with associated liabilities for margin (see the section on Futures below).
If the purchased options expire worthless, the purchaser will suffer a total loss of the
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investment. In purchasing deep out-of-the-money options, the purchaser should be
aware that the chance of such options becoming profitable ordinarily is remote.
o
Selling ("writing" or "granting") an option generally entails considerably greater risk than
purchasing options. Although the premium received by the seller is fixed, the seller may
sustain a loss well in excess of that amount. The seller will be liable for additional margin
to maintain the position if the market moves unfavorably. The seller will also be exposed
to the risk of the purchaser exercising the option and the seller being obligated to either
settle the option in cash or to acquire or deliver the underlying interest. If the option is
on a future, the seller will acquire a position in a future with associated liabilities for
margin (see the section on Futures below). If the option is "covered" by the seller holding
a corresponding position in the underlying interest or a future or another option, the risk
may be reduced. If the option is not covered, the risk of loss can be unlimited.
o Certain exchanges in some jurisdictions permit deferred payment of the option premium,
exposing the purchaser to liability for margin payments not exceeding the amount of the
premium. The purchaser is still subject to the risk of losing the premium and transaction
costs. When the option is exercised or expires, the purchaser is responsible for any unpaid
premium outstanding at that time.
RESPONSIBLE INVESTING AND ESG RISK: clients utilizing responsible investing strategies
and environment, social responsibility, and corporate governance (ESG) factors may underperform
strategies which do not utilize responsible investing and ESG considerations. Responsible investing
and ESG strategies may operate by either excluding the investments of certain issuers or by
selecting investments based on their compliance with factors such as ESG. This strategy may
exclude certain sectors or industries from a client’s portfolio, potentially negatively affecting the
client’s investment performance if the excluded sector or industry outperforms. Responsible
investing and ESG are subjective by nature, and our firm may rely on analysis and ‘scores’ provided
by third parties in determining whether an issuer meets our firm’s standards for inclusion or
exclusion. A client’s perception may differ from our firm or a third parties on how to judge an
issuers adherence to responsible investing principles.
MARGIN RISK: When you purchase securities, you may pay for the securities in full or you may
borrow part of the purchase price from your brokerage firm. If you choose to borrow funds through
a margin account, securities purchased are the firm's collateral for the loan to you. If the securities
in your account decline in value, so does the value of the collateral supporting your loan, and, as a
result, the firm can take action, such as issue a margin call and/or sell securities or other assets in
any of your accounts held with the member, in order to maintain the required equity in the
account. Investing with margin is characterized by unique risks including amplified losses due to
increased leverage; margin calls; forced liquidations; and additional fees including margin interest
charges. In order to manage margin risk, we recommend leveraging responsibly (borrowing less
than the amount available); keeping a diversified portfolio; and monitoring the account and
evaluating risk regularly. Before investing on margin, be sure to read the Margin Disclosure
Statement provided by your custodian.
NON-LIQUID ALTERNATIVE INVESTMENTS: From time to time, our Firm will recommend to
certain qualifying clients that a portion of such clients’ assets be invested in private funds, private
investments (collectively, “Nonliquid Alternative
fund-of-funds and/or other alternative
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Investments”). Nonliquid Alternative Investments are not suitable for all of our Firm’s clients and
are offered only to those qualifying clients for whom our Firm believes such an investment is
suitable and in line with their overall investment strategy. Nonliquid Alternative Investments
typically are available to only a limited number of sophisticated investors who meet the definition
of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the
“Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified
purchaser” under the Investment Company Act of 1940. Nonliquid Alternative Investments
present special risks for our Firm’s clients, including without limitation, limited liquidity, higher
fees and expenses, volatile performance, no assurance of investment returns, heightened risk of
loss, limited transparency, additional reliance on underlying management of the investment,
special tax considerations, subjective valuations, use of leverage and limited regulatory oversight.
When a Nonliquid Alternative Investment invests part or all of its assets in real estate properties,
there are additional risks that are unique to real estate investing, including but not limited to:
limitations of the appraisal value; the borrower’s financial conditions (if the underlying property
has been obtained by a loan), including the risk of foreclosures on the property; neighborhood
values; the supply of and demand for properties of like kind; and certain city, state and/or federal
regulations. Additionally, real estate investing is also subject to possible loss due to uninsured
losses from natural and man-made disasters. The above list is not exhaustive of all risks related to
an investment in Nonliquid Alternative Investments. A more comprehensive discussion of the risks
associated with a particular Nonliquid Investment is set forth in that fund’s offering documents,
which will be provided to each client subscribing to a Nonliquid Alternative Investment, for review
and consideration. It is important that each potential, qualified investor carefully read each
offering or private placement memorandum prior to investing.
ALTERNATIVE STRATEGY MUTUAL FUNDS OR ETFS - Certain ETFs and mutual funds we may use
in our models and accounts invest primarily in alternative investments and/or strategies. Investing
in these alternative investments / strategies may not be suitable for all our Clients. These include
special risks, such as those associated with commodities, real estate, and leverage, selling
securities short, use of derivatives, potential adverse market forces, regulatory changes and
potential ill-liquidity. There are special risks associated with ETFs that invest principally in real
estate securities, such as sensitivity to changes in real estate values and/or changes in interest
rates and price volatility due to the ETF’s concentration in the real estate market.
CRYPTOCURRENTY RISK - Cryptocurrency (notably, bitcoin), often referred to as “virtual
currency”, “digital currency,” or “digital assets,” operates as a decentralized, peer-to-peer financial
exchange and value storage that is used like money. If deemed appropriate, Clients may have
exposure to bitcoin, a cryptocurrency. Cryptocurrency operates without central authority or banks
and is not backed by any government. Cryptocurrencies (i.e., bitcoin) may experience very high
volatility. Cryptocurrency is also not legal tender. Federal, state or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. The
SEC has issued a public report stating U.S. federal securities laws require treating some digital
assets as securities. Cryptocurrency exchanges may stop operating or permanently shut down due
to fraud, technical glitches, hackers or malware. Due to its relatively recent launch, bitcoin has a
limited trading history, making it difficult for investors to evaluate investments in this
cryptocurrency. It is possible that another entity could manipulate the blockchain in a manner that
is detrimental to the bitcoin network. Bitcoin transactions are irreversible such that an improper
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FEBRUARY 2026 | PAGE 19
transfer can only be undone by the receiver of the bitcoin agreeing to return the bitcoin to the
original sender. Digital assets are highly dependent on their developers and there is no guarantee
that development will continue or that developers will not abandon a project with little or no
notice. Third parties may assert intellectual property claims relating to the holding and transfer of
digital assets, including cryptocurrencies, and their source code. Any threatened action that
reduces confidence in a network’s long-term ability to hold and transfer cryptocurrency may affect
investments in cryptocurrencies.
ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components, such as our client
relationship management system that utilizes artificial intelligence to summarize client meeting
notes. The use of artificial intelligence and machine learning includes increased risk of data
inaccuracies and security vulnerabilities. Due to the rapid advancement of machine learning
technologies, future risks related to artificial intelligence are unpredictable. As a measure to
mitigate these risks to our clients, our Firm performs periodic due diligence of our service providers
for assurance that the service providers have appropriate controls in place to protect our clients’
information and to limit data inaccuracies when artificial intelligence is used by the service
provider.
ITEM 9 - DISCIPLINARY INFORMATION
We are required to disclose any legal or disciplinary events that are material to a client, or prospective
client's, evaluation of our advisory business or the integrity of our management. Our Firm has not been
subject to any legal or disciplinary events to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
THIRD PARTY MONEY MANAGER RELATIONSHIPS
Please refer to Item 4 and Item 5 above for more information about the selection of TPMMs used with our
investment services. Our Firm will invoice separately for Correct Capital’s portion of the advisory fee. A
conflict of interest may arise for our Firm when utilizing a TPMM due to the receipt of discounts or services
that are not available to us from another similar TPMM. In order to minimize this conflict, our Firm will
make our recommendations and selections of TPMMs in the best interest of our clients.
Clients should be aware that the ability to receive additional compensation by Correct Capital and its
management persons or employees creates conflicts of interest that impair the objectivity of the Firm and
these individuals when making advisory recommendations. Correct Capital acts in the best interest of
clients as part of our fiduciary duty as a registered investment adviser; we take the following steps, among
others to address this conflict:
we disclose to clients the existence of all material conflicts of interest, including the potential for
the Firm and our employees to earn compensation from advisory clients in addition to the Firm's
advisory fees;
we disclose to clients that they have the right to decide to purchase the recommended investment
products from our IARs;
we collect, maintain and document accurate, complete and relevant client background
information, including the client’s financial goals, objectives and risk tolerance;
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the Firm conducts regular reviews of each client advisory account to verify that all
recommendations made to a client are in the best interest of the client’s needs and circumstances;
we require that our employees seek prior approval of any outside employment activity so that we
may ensure that any conflicts of interests in such activities are properly addressed;
we periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by the Firm; and
we educate our employees regarding the responsibilities of a fiduciary, including the need for
having a reasonable and independent basis for the investment advice provided to clients. Conflicts
of interests are properly addressed with our clients, disclosed in our Firm documents and mitigated
by our Firm’s policies and procedures.
IARs of our Firm do not have an application pending to register, as a futures commission merchant,
commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.
INSURANCE
Some of our IARs are licensed insurance agent and sell various life insurance products, long term care and
fixed annuities through the licensed insurance agency. Our IARs receive compensation (commissions, trails,
or other compensation from the respective product sponsors) as a result of effecting insurance transactions
for clients. IARs spend a portion of their time in connection with these insurance activities and it represents
ongoing revenue for our IARs. The IAR has an incentive to recommend insurance and this incentive creates
a conflict of interest between your interests and our Firm. Clients should note that they have the right to
decide whether or not to engage the services of our IARs. Further, clients should note they have the right
to decide whether to act on the recommendations and the right to choose any professional to execute the
advice for any insurance products through our IAR or any licensed insurance agent not affiliated with our
Firm. We recognize the fiduciary responsibility to place your interests first and have established policies in
this regard to mitigate any conflicts of interest.
ITEM 11 - CODE OF ETHICS
Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial
investment in the same securities or other investments that we recommend or acquire for your account,
and may engage in transactions that are the same as or different than transactions recommended to or
made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in
your best interest and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things,
personal trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel
regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a
position of trust and must act with complete propriety at all times, protect the reputation of Correct Capital,
safeguard against the violation of the securities laws, and establish procedures for personnel to follow so
that we may determine whether their personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
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A director, officer, or employee of Correct Capital shall not buy or sell any securities for their
personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of
his or her employment unless the information is also available to the investing public on
reasonable inquiry No supervised employee of Correct Capital shall prefer his or her own interest
to that of the advisory client. Trades for supervised employees are traded alongside client accounts
We maintain a list of all securities holdings of anyone associated with this advisory practice with
access to advisory recommendations. These holdings are reviewed on a regular basis by an
appropriate officer/individual of Correct Capital.
We emphasize the unrestricted right of the client to decline implementation of any advice
rendered, except in situations where we are granted discretionary authority of the client’s account
We require that all supervised employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices
Any supervised employee not in observance of the above may be subject to termination
INVESTMENT POLICY
None of our associated persons may affect for himself/herself or for accounts in which he/she holds a
beneficial interest, any transactions in a security which is being actively recommended to any of our clients,
unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email on the
cover page of this Part 2; ATTN: Pintip Perdun, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
We generally recommend that clients utilize the custody, brokerage and clearing services of Fidelity
Institutional Wealth Services (“Fidelity”) and Charles Schwab & Co., Inc (“Charles Schwab”) (defined in this
document as “Custodian(s)”) for investment management accounts. We may recommend other custodians
beside Fidelity and Charles Schwab based on your needs and the services offered.
We recommend that you establish accounts with these Custodians to maintain custody of your assets and
to effect trades for your accounts. Some of the products, services and other benefits provided by our
Custodians benefit us and may not benefit you or your account. Our recommendation/requirement that
you place assets with one of these Custodians may be based in part on benefits they provide us, and not
solely on the nature, cost or quality of custody and execution services provided by the custodian. The
Custodian we utilize makes available to us other products and services that benefit us but may not benefit
your accounts in every case.
Custodian(s) provides various benefits and payments to registered investment advisers that are new to the
Custodial platform to assist the firm with the costs associated with starting a Registered Investment
Advisory firm and transitioning the business to Custodian (collectively referred to as “Transition
Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety
of purposes, including but not necessarily limited to, initial registration, compliance assistance, legal
assistance, and technology expenses incurred as a result of the firm transitioning to Custodian’s custodial
platform. The amount of the Transition Assistance payments is often significant in relation to the overall
revenue earned or compensation received by the Firm.
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The receipt of Transition Assistance by Correct Capital creates conflicts of interest relating to Correct
Capital’s advisory business because it creates a financial incentive for Correct Capital to recommend that
its clients maintain their accounts with Custodian. Correct Capital attempts to mitigate these conflicts of
interest by evaluating and recommending that clients use Custodian’s services based on the benefits that
such services provide to our clients, rather than the Transition Assistance earned by Correct Capital. Correct
Capital considers Custodian’s execution capability when recommending or requiring that clients maintain
accounts with Custodian. However, clients should be aware of this conflict and take it into consideration in
making a decision whether to custody their assets in an account at Custodian.
Some of the other Custodian’s products and services assist us in managing and administering your accounts.
These include software and technology that provide access to client account data (such as trade
confirmations and account statements), facilitate trade execution (and allocation of aggregated trade
orders for multiple client accounts), provide research, pricing information and other market data, facilitate
payment of our fees from your account, and assist with back-office functions, recordkeeping and reporting.
We are independently owned and operated and not affiliated with these Custodians. They provide us with
access to their institutional trading and custody services. These services include brokerage, custody,
research and access to mutual funds and other investments that are otherwise generally available only to
institutional investors.
You have the right to not act upon any recommendations, and if you elect to act upon any
recommendations, you have the right to not place the transactions through any broker/dealer we
recommend. Our recommendation is generally based on the broker’s cost and fees, skills, reputation,
dependability and compatibility with the client. You may be able to obtain lower commissions and fees from
other brokers and the value of products, research and services given to us is not a factor in determining the
selection of broker/dealer or the reasonableness of their commissions.
We place trades for your account subject to our duty to seek best execution and other fiduciary duties. You
may be able to obtain lower commissions and fees from other brokers and the value of products, research
and services given to us is not a factor in determining the selection of broker/dealer or the reasonableness
of their commissions. The Custodian's execution quality may be different than other broker-dealers.
Many of these services generally may be used to service all or a substantial number of our accounts. The
Custodians also make available to us other services intended to help us manage and further develop our
business enterprise. These services may include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, and marketing. In
addition, the custodians may make available, arrange and/or pay for these services rendered to us by third
parties. The Custodians may discount or waive fees it would otherwise charge for some of these services
or pay all or a part of the fees of a third-party providing these services to us.
While as a fiduciary, we endeavor to act in your best interest, our recommendation that you maintain your
assets in accounts at our recommended custodians may be based in part on the benefit to us or the
availability of some of the foregoing products and services and not solely on the nature, cost or quality of
custody and brokerage services provided by the custodian, which may create a conflict of interest. IARs
endeavor at all times to put the interest of our clients first as a part of their fiduciary duty.
There is no direct link between our participation in a Custodian’s platform and the investment advice we
give to our clients. We/you may receive economic benefits through our participation in the platforms that
may not be available to other advisors. These benefits include the following products and services
(provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research
CORRECT CAPITAL WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 23
related products and tools; consulting services; access to a trading desk serving Adviser participants; access
to block trading (which provides the ability to aggregate securities transactions for execution and then
allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from
Client accounts; access to an electronic communications network for Client order entry and account
information; access to mutual funds with no transaction fees and to certain institutional money managers;
and discounts on compliance, marketing, research, technology, and practice management products or
services provided to us by third party vendors. The Custodians may also have paid for business consulting
and professional services received by some of our related persons. Some of the products and services made
available by the Custodians through the program may benefit us but may not benefit your account. These
products or services may assist us in managing and administering your account, including accounts not
maintained at the Custodians. Other services made available by the Custodians are intended to help us
manage and further develop our business enterprise. The benefits received by our firm or our personnel
through participation in the program do not depend on the amount of brokerage transactions directed to
the Custodians. As part of our fiduciary duties to clients, we endeavor at all times to act in the best interest
of our clients. You should be aware, however, that the receipt of economic benefits by us or our related
persons in and of itself creates a conflict of interest and may indirectly influence our choice of the
Custodians for custody and brokerage services.
We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary
duties. Custodian's execution quality may be different than other Custodians.
Our Firm annually reviews the relationship between our Custodian, Correct Capital and the client in order
to determine if the custodial relationship is in the best interest of the client.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any custodian or third party in exchange for using that
broker-dealer or third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We may aggregate transactions if we believe that aggregation is consistent with the duty to seek best
execution for our clients and is consistent with the disclosures made to clients and terms defined in the
client investment advisory agreement. No advisory client will be favored over any other client, and each
account that participates in an aggregated order will participate at the average share price (per custodian)
for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis.
If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will
base the allocation on other relevant factors, which may include:
When only a small percentage of the order is executed, with respect to purchase allocations,
allocations may be given to accounts high in cash
With respect to sale allocations, allocations may be given to accounts low in cash
We may allocate shares to the account with the smallest order, or to the smallest position, or to
an account that is out of line with respect to security or sector weightings, relative to other
portfolios with similar mandates
We may allocate to one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment
results and that can be purchased by other accounts in the block
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If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account’s assets after an order is placed
If a pro-rata allocation of a potential execution would result in a de Minimis allocation in one or
more accounts, we may exclude the account(s) from the allocation
We will document the reasons for any deviation from a pro-rata allocation.
TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade
errors in a manner that is in the best interest of the client. In cases where the client causes the trade error,
the client will be responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client will be made
whole, and we will absorb any loss resulting from the trade error if the error was caused by the Firm. If the
error is caused by the custodian, the custodian will be responsible for covering all trade error costs. If an
investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit
or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that you direct us to execute transactions through a
specified broker-dealer. Additionally, we typically do not permit you to direct brokerage. We place trades
for your account subject to our duty to seek best execution and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
The Firm monitors client portfolios on a continuous and ongoing basis while regular account reviews are
conducted on at least an annual basis. Such reviews are conducted by the Firm’s Investment Committee
and/or investment adviser representatives and are intended to fulfil the Firm’s fiduciary obligations to their
advisory clients. All advisory clients are encouraged to discuss their needs, goals and objectives with Correct
Capital and to keep the Firm informed of any changes thereto. Correct Capital contacts ongoing investment
advisory clients at least annually to review its previous services and/or recommendations and quarterly to
discuss the impact resulting from any changes in the client’s financial and/or investment objectives.
STATEMENTS AND REPORTS
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from the Firm and/or an outside service
provider, which contain certain account and/or market-related information, such as an inventory of account
holdings or account performance. Clients should compare the account statements they receive from their
custodian with any documents or reports they receive from the Firm or an outside service provider.
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ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Affiliated or unaffiliated persons (“promoters”) may, from time to time, refer, solicit, or introduce clients to
our Firm. Our Firm may compensate certain promoters consistent with the requirements of applicable law
and regulation, including the Advisers Act as well as applicable state/local laws and regulations. We may
pay a promoter a recurring fee, a one-time fee or a portion of the advisory fees or revenues that we earn
for managing client or investor assets referred to us by the promoter. The costs of such referral fees are
typically paid entirely by our Firm and do not result in any additional charges to the client or investor. Our
Firm may be asked to recommend a financial professional, such as an attorney, accountant, or mortgage
broker. In such cases, our Firm does not receive any direct compensation in return for any referrals made
to individuals or firms in our professional network. Clients must independently evaluate these firms or
individuals before engaging in business with them and clients have the right to choose any financial
professional to conduct business. Individuals and firms in our financial professional network may refer
clients to our Firm. Our Firm does recognize the fiduciary responsibility to place your interests first and have
established policies in this regard to mitigate any conflicts of interest.
ITEM 15 – CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined by
regulators as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm
has established procedures to ensure all client funds and securities are held at a qualified custodian in a
separate account for each client under that client’s name. Clients, or an independent representative of the
client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s independent
representative, at least quarterly. The client should carefully review those statements and are urged to
compare the statements against reports received from Correct Capital. When the client has questions
about their account statements or fee deductions, the client should contact Correct Capital or the qualified
custodian preparing the statement. Please refer to Item 5 for more information about the deduction of
adviser fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations
with their custodian to move money from a client’s account to a third-party (“SLOA”) and, under that SLOA,
it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a
set of standards intended to protect client assets in such situations, which we follow. We do not have a
beneficial interest in any of the accounts we are deemed to have custody where SLOAs are on file. In
addition, account statements reflecting all activity on the account(s), are delivered directly from the
qualified custodian to each client or the client’s independent representative, at least quarterly. The client
should carefully review those statements and are urged to compare the statements against reports received
from us. When the client has questions about their account statements, the client should contact us, the
client’s Adviser or the qualified custodian preparing the statement.
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ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging Correct Capital to provide investment advisory services, you
will enter into a written Agreement with us granting the Firm the authority to supervise and direct, on an
on-going basis, investments in accordance with the client’s investment objective and guidelines. In
addition, you will need to execute additional documents required by the custodian to authorize and enable
Correct Capital, in its sole discretion, without prior consultation with or ratification by you, to purchase,
sell, or exchange securities in and for your accounts. We are authorized, in our discretion and without prior
consultation with you to: (1) buy, sell, exchange, and trade any stocks, bonds or other securities or assets,
(2) determine the amount of securities to be bought or sold, and (3) place orders with the custodian. Any
limitations to such discretionary authority will be communicated to our Firm in writing by you, the client.
The limitations on investment and brokerage discretion held by Correct Capital for you are:
For discretionary accounts, we require that we be provided with authority to determine which
securities and the amounts of securities to be bought or sold.
Any limitations on this discretionary authority shall in writing as indicated on the Investment
Advisory Agreement. You may change/amend these limitations as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to execution
or you will be required to make the trades if in an employer-sponsored account.
ITEM 17 – VOTING YOUR SECURITIES
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent
third-party at your own discretion. You designate proxy voting authority in the custodial account
documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We
do not take action with respect to any securities or other investments that become the subject of any legal
proceedings, including bankruptcies. Clients can contact our office with questions about a particular
solicitation by phone at 314-930-4015.
Class Action Suits A class action is a procedural device used in litigation to determine the rights of and
remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact.
Class action suits frequently arise against companies that publicly issue securities, including securities
recommended by investment advisors to clients. With respect to class action suits and claims, you (or your
agent) will have the responsibility for class actions or bankruptcies, involving securities purchased for or
held in your account. We do not provide such services and are not obligated to forward copies of class
action notices we may receive to you or your agents.
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are
not subject to a financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time.
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PRIVACY POLICY
Our Firm collects nonpublic personal information about Clients from information provided on applications
or other forms, as well as from information regarding Client transactions with our Firm, our affiliates, or
others. In accordance with Regulation S-P, our Firm does not disclose any nonpublic personal information
about current or former Clients to third parties, except as permitted or required by law, or as necessary to
service Client accounts. Access to Client information is restricted to Firm personnel who require such
information to provide investment advisory services. Our Firm maintains physical, electronic, and
procedural safeguards designed to protect Client information in compliance with federal standards and
Regulation S-P. Our Firm provides a copy of its Privacy Policy to Clients at the time of account opening,
upon request, and annually if the Policy is amended.
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