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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 2026
801 E. Chapman Avenue, Suite 104
Fullerton, CA 92831
www.doncrane.com
Firm Contact:
D. Scott Crane
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Crane Advisory LLC dba
Crane & Associates Wealth Management. If clients have any questions about the contents of this brochure,
please contact us at (714) 525-4445. 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. Additional information
about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #314432.
Please note that the use of the term “registered investment adviser” and description of our firm and/or our
associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review
this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on
the qualifications of our firm and our employees.
Item 2: Material Changes
Crane & Associates Wealth Management is required to notify clients of any information that has changed since
the last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can request a
full copy of our Brochure or contact us with any questions that they may have about the changes.
Since our last Annual Amendment, filed on 03/6/2025, we have no material changes to disclose.
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Item 3: Table of Contents
Item 1: Cover Page ....................................................................................................................................... 1
Item 2: Material Changes ............................................................................................................................ 2
Item 3: Table of Contents ............................................................................................................................ 3
Item 4: Advisory Business .......................................................................................................................... 4
Item 5: Fees & Compensation ..................................................................................................................... 5
Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 7
Item 7: Types of Clients & Account Requirements ................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 7
Item 9: Disciplinary Information .............................................................................................................. 17
Item 10: Other Financial Industry Activities & Affiliations .................................................................... 17
Item 11: Code of Ethics, Participation or Interest in .............................................................................. 18
Item 12: Brokerage Practices ................................................................................................................... 19
Item 13: Review of Accounts or Financial Plans ..................................................................................... 21
Item 14: Client Referrals & Other Compensation ................................................................................... 22
Item 15: Custody ....................................................................................................................................... 22
Item 16: Investment Discretion ............................................................................................................... 23
Item 17: Voting Client Securities .............................................................................................................. 23
Item 18: Financial Information ................................................................................................................ 23
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Crane & Associates Wealth Management
Item 4: Advisory Business
Our firm provides individuals and other types of clients with a wide array of investment advisory services. Our
firm is a limited liability company formed under the laws of the State of California in 2021 and has been in
business as an investment adviser since that time. Our firm is owned by Todd M. Crane, D. Scott Crane, Alex J.
Crane, and Crane Family Trust DTD 11/25/1988 (trustees Donald B. Crane and Monsie C. Crane).
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions,
compensation, and any other matters related to investment decisions made by our firm or its representatives.
As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing
our client. Our firm has established a service-oriented advisory practice with open lines of communication for
many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and
time horizons. Working with clients to understand their investment objectives, while educating them about our
process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Comprehensive Portfolio Management: As part of our Comprehensive Portfolio Management service, clients
will be provided asset management and financial planning or consulting services. This service is designed to
assist clients in meeting their financial goals using a financial plan or consultation. Our firm will gather Client
data to understand their current financial situation, existing resources, financial goals, and tolerance for risk.
Based on what is learned, an investment approach is presented to the client, consisting of individual stocks,
bonds, ETFs, options, mutual funds and other public and private securities or investments. Once the
appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if
necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Upon client request,
our firm provides a summary of observations and recommendations for the planning or consulting aspects of
this service.
Standalone Financial Planning & Consulting: Our firm provides a variety of standalone financial planning
and consulting services to clients for the management of financial resources based upon an analysis of current
situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan,
providing planning recommendations, or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass Investment Planning, Retirement
Planning, Estate Planning, Charitable Planning, Education Planning, Personal Tax Planning, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Held-Away Portfolio Advice, or
Business and Personal Financial Planning. Financial plans or consultations rendered to clients usually include
general recommendations for a course of activity or specific actions to be taken by the clients. Clients may be
provided a written report as part of the financial planning or consulting service. Implementation of the
recommendations will be at the discretion of the client. Initial plans and/or consultations are rendered to
clients within six months of engagement, assuming that all requested information and documents are provided
to our firm promptly by the Client.
Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan
sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors
in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs
of the plan sponsor dictate, areas of advising may include:
Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that
summarizes the investment goals and objectives along with the broad strategies to be employed to meet
the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options
and make recommendations for appropriate changes.
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Crane & Associates Wealth Management
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to
aid Participants in developing strategies to meet their investment objectives, time horizon, financial
situation, and risk tolerance.
Investment Monitoring – Our firm will monitor the performance of the investments and notify the client
in the event of over/underperformance and in times of market volatility.
Participant Education – Our firm will provide opportunities to educate plan participants about their
retirement plan offerings, different investment options, and general guidance on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services with
respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly
traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or
brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be
in compliance with the applicable state laws regulating retirement consulting services. This applies to client
accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts
appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the
meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with
respect to the provision of services described therein.
Our firm may recommend the use of outside 3(21) providers for additional investment option screening,
research, analytical, and monitoring services. In such cases, our firm will make investment option
recommendations within the parameters of the outside 3(21) provider’s screened investment option universe.
Client will sign a service agreement directly with the outside 3(21) provider defining the services to be
provided and fees charged.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management, Financial
Planning & Consulting, & Retirement Plan Consulting Clients. Each Comprehensive Portfolio Management client
can place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on
investments in certain securities or types of securities may not be possible due to the level of difficulty this
would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2025, our firm manages $735,957,993 on a discretionary basis and $198,673,542 on a non-
discretionary basis, totaling $934,631,535 in aggregate Assets Under Management.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Comprehensive Portfolio Management: The maximum annual fee charged for this service will not exceed
1.25%. Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Our firm bills
on cash unless otherwise agreed to. Annualized fees are billed on a pro-rata basis monthly in arrears based on
the time-weighted daily average value of the account(s) during the month. Fees are negotiable and will be
deducted from client account(s). Our firm does not offer direct invoicing. As part of this process, Clients
understand the following:
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Crane & Associates Wealth Management
a) The client’s independent custodian sends statements at least quarterly showing the market values for
each security included in the Assets and all account disbursements, including the amount of the advisory
fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will
c)
send an invoice directly to the custodian; and
If our firm sends a copy of our invoice to the client, a legend urging the comparison of information
provided in our statement with those from the qualified custodian will be included.
Standalone Financial Planning & Consulting: Our firm charges on an hourly, flat or recurring fee basis for
financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based
on the scope and complexity of our engagement with the Client. The maximum hourly fee to be charged will
not exceed $1,000. Flat fees will not exceed $60,000. Annual recurring fees will not exceed $60,000. The fee-
paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting
agreement. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6
months.
Retirement Plan Consulting: Our firm charges a fee based on the percentage of Plan assets under
management for retirement plan consulting services. The total estimated fee, as well as the ultimate fee
charged, is based on the scope and complexity of our engagement with the client. The maximum
hourly fee to be charged will not exceed $1,000. Flat fees will not exceed $200,000 annually. Fees based on a
percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangements will be determined on
a case-by-case basis and will be detailed in the signed consulting agreement.
Other Types of Fees & Expenses
Clients will incur applicable transaction fees for trades executed by their chosen custodian based on individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by
the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed
equities and exchange traded funds but may pass on exchange fees when applicable. Clients may also pay
holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a
mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund
management fees), distribution fees, surrender charges, variable annuity fees, IRA and qualified retirement
plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from
custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our
firm does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Comprehensive Portfolio
Management services in writing at any time. Upon notice of termination, pro-rata advisory fees for services
rendered to the point of termination will be charged. If advisory fees cannot be deducted, our firm will send an
invoice for due advisory fees to the client.
Financial Planning & Consulting Clients may terminate their agreement at any time before the delivery of a
financial plan by providing written notice. For purposes of calculating refunds or additional money owed, all
work performed by C&A up to the point of termination shall be calculated according to an agreed upon hourly
rate or on a pro-rata basis based on the number of days during the year for which services were provided.
Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice
to the other party. Full refunds will only be made in cases where cancellation occurs within 5 business days of
signing an agreement. After 5 business days from initial signing, either party must provide the other party 30
days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice.
Clients will be charged on a pro-rata basis, which considers work completed by our firm on behalf of the Client.
Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined
as 30 days from receipt of said written notice) and such fees will be due and payable.
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Crane & Associates Wealth Management
Commissionable Securities Sales
Representatives of our firm are registered representatives of Cetera Wealth Services LLC (“Cetera”), member
FINRA/SIPC. As such, they can accept compensation for the sale of securities or other investment products,
including distribution or service (“trail”) fees. Clients should be aware that the practice of accepting
commissions for the sale of securities presents a conflict of interest and gives our firm and/or our
representatives an incentive to recommend investment products based on the compensation received. Our firm
generally addresses commissionable sales conflicts that arise when explaining to clients these sales create an
incentive to recommend based on the compensation to be earned and/or when recommending commissionable
mutual funds, explaining that “no-load” funds are also available. Our firm does not prohibit clients from
purchasing recommended investment products through other unaffiliated brokers or agents. The firm does not
receive 12B-1s in RIA client accounts and therefore there is no incentive to recommend commissionable
mutual fund share classes.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Types of Clients
Our firm has the following types of clients: Individuals and High Net Worth Individuals; Trusts, Estates or
Charitable Organizations; Pension and Profit-Sharing Plans; Corporations, Limited Liability Companies and/or
Other Business Types.
Account Requirements
Our firm requires a minimum account balance of $500,000 for our Comprehensive Portfolio Management
service. Generally, this minimum account balance requirement is not negotiable and would be required
throughout the course of the client’s relationship with our firm. However, exceptions may be made on a case-
by-case basis at our firm’s discretion.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response to certain
events taking place around the world. These include events directly involving the issuers of securities held as
underlying assets in a client’s account, conditions affecting the general economy, and overall market changes.
Other contributing factors include local, regional, or global political, social, or economic instability and
governmental or governmental agency responses to economic conditions. Currency, interest rate, and
commodity price fluctuations may also affect security prices and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be affected by
changing interest rates and by changes in the effective maturities and credit ratings of these securities. For
example, the prices of debt securities in the client’s account generally will decline when interest rates rise and
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Crane & Associates Wealth Management
increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call” or
refinance a security before its stated maturity, which may result in our firm having to reinvest the proceeds in
lower yielding securities. Longer maturity debt securities generally have higher rates of interest and may be
subject to greater price fluctuations than shorter maturity debt securities. Debt securities are also subject to
credit risk, which is the possibility that the credit strength of an issuer will weaken and/or an issuer of a debt
security will fail to make timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S. government only
covers the timely payment of interest and principal when held to maturity. This means that the current market
values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to increased levels
of the risks described above. Currency fluctuations and controls, different accounting, auditing, financial
reporting, disclosure, regulatory and legal standards and practices could also affect investments in securities
of foreign issuers. Additional factors may include expropriation, changes in tax policy, greater market volatility,
different securities market structures, and higher transaction costs. Various administrative difficulties, such as
delays in clearing and settling portfolio transactions, or in receiving payment of dividends can increase risk.
Finally, investments in securities issued by entities domiciled in the United States may also be subject to many
of these risks.
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing client assets:
Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical forces
drive price movements in the financial markets. Risks include that cycles may invert or disappear and there is
no expectation that this type of analysis will pinpoint turning points, instead be used in conjunction with other
methods of analysis.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the business's
assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a stock, futures
contract, or currency using fundamental analysis there are two basic approaches one can use: bottom-up
analysis and top-down analysis. The terms are used to distinguish such analysis from other types of investment
analysis, such as quantitative and technical. Fundamental analysis is performed on historical and present data,
but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company
stock valuation and predict its probable price evolution; (b) to make a projection on its business performance;
(c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.;
and (e) to find out the intrinsic value of the share.
When the objective of the analysis is to determine what stock to buy and at what price, there are two basic
methodologies investors rely upon: (a) Fundamental analysis maintains that markets may misprice a security
in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the
mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b)
Technical analysis maintains that all information is reflected already in the price of a security. Technical
analysts analyze trends and believe that sentiment changes predate and predict trend changes. Investors'
emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also
analyze historical trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security can move up
or down along with the overall market regardless of the economic and financial factors considered in evaluating
the stock.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and track record
of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an
ability to invest over a period of time and in different economic conditions. The underlying assets in a mutual
fund or ETF are also reviewed in an attempt to determine if there is significant overlap in the underlying
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investments held in another fund(s) in the Client’s portfolio. The funds or ETFs are monitored in an attempt to
determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF
analysis is that, as in all securities investments, past performance does not guarantee future results. A manager
who has been successful may not be able to replicate that success in the future. In addition, as our firm does
not control the underlying investments in a fund or ETF, managers of different funds held by the Client may
purchase the same security, increasing the risk to the Client if that security were to fall in value. There is also a
risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information,
such as management expertise, industry cycles, strength of research and development, and labor relations.
Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on
reports such as balance sheets. The two techniques, however, will often be used together to examine a
company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with
intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one.
This approach depends on the kind of intelligence that machines (currently) lack, since things like positive
associations with a brand, management trustworthiness, customer satisfaction, competitive advantage and
cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative
analysis is that subjective judgment may prove incorrect.
Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually
consists of searching vast databases for patterns, such as correlations among liquid assets or price-movement
patterns (trend following or mean reversion). The results of the analysis are taken into consideration in the
decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative
analysis is that the methods or models used may be based on assumptions that prove to be incorrect.
Sector Analysis: Sector analysis involves identification and analysis of various industries or economic sectors
that are likely to exhibit superior performance. Academic studies indicate that the health of a stock's sector is
as important as the performance of the individual stock itself. In other words, even the best stock located in a
weak sector will often perform poorly because that sector is out of favor. Each industry has differences in terms
of its customer base, market share among firms, industry growth, competition, regulation and business cycles.
Learning how the industry operates provides a deeper understanding of a company's financial health. One
method of analyzing a company's growth potential is examining whether the amount of customers in the overall
market is expected to grow. In some markets, there is zero or negative growth, a factor demanding careful
consideration. Additionally, market analysts recommend that investors should monitor sectors that are nearing
the bottom of performance rankings for possible signs of an impending turnaround.
Security Analysis: Analysis of tradeable financial instruments called securities. These can be classified into
debt securities, equities, or some hybrid of the two. More broadly, futures contracts and tradeable credit
derivatives are sometimes included. Security analysis is typically divided into fundamental analysis, which
relies upon the examination of fundamental business factors such as financial statements, and technical
analysis, which focuses upon price trends and momentum. Quantitative analysis may use indicators from both
areas.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through the study
of past market data, primarily price and volume. A fundamental principle of technical analysis is that a market's
price reflects all relevant information, so their analysis looks at the history of a security's trading pattern rather
than external drivers such as economic, fundamental and news events. Therefore, price action tends to repeat
itself due to investors collectively tending toward patterned behavior – hence technical analysis focuses on
identifiable trends and conditions. Technical analysts also widely use market indicators of many sorts, some of
which are mathematical transformations of price, often including up and down volume, advance/decline data
and other inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between price/volume
indices and market indicators. Technical analysis employs models and trading rules based on price and volume
transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-
market price correlations, business cycles, stock market cycles or, classically, through recognition of chart
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patterns. Technical analysis is widely used among traders and financial professionals and is very often used by
active day traders, market makers and pit traders. The risk associated with this type of analysis is that analysts
use subjective judgment to decide which pattern(s) a particular instrument reflects at a given time and what
the interpretation of that pattern should be.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are appropriate to
the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons,
among other considerations:
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward
by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance,
goals and investment time frame. Asset allocation is based on the principle that different assets perform
differently in different market and economic conditions. A fundamental justification for asset allocation is the
notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces
the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced
as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical
relationships (like correlation and variance) that existed over some past period. Expectations for return are
often derived in the same way.
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return.
There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional"
asset classes are stocks (value, dividend, growth, or sector-specific [or a "blend" of any two or more of the
preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or
frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield];
government or corporate; short-term, intermediate, long-term; domestic, foreign, emerging markets), and cash
or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid
instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other
alternative assets that may be considered include: commodities: precious metals, nonferrous metals,
agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles such as art, coins,
or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products,
etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures;
foreign currency; venture capital; private equity; and/or distressed securities.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and
diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core-satellite.
Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that
seeks to provide the optimal balance between expected risk and return for a long-term investment
horizon. Generally speaking, strategic asset allocation strategies are agnostic to economic environments,
i.e., they do not change their allocation postures relative to changing market or economic conditions.
Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that
portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between
expected risk and return for a long-term investment horizon. Like strategic allocation strategies,
dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic
strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in
the economic environment.
Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active
approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the
most potential for perceived gains. While an original asset mix is formulated much like strategic and
dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and
out of their core asset classes
Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic
element making up the most significant portion of the portfolio, while applying a dynamic or tactical
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'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation
strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above.
Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business
Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be
illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged,
speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative
investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures
often result in delayed tax reporting. Compared to mutual funds, hedge funds and commodity pools are subject
to less regulation and often charge higher fees and may require “capital calls” which would require additional
investment. Alternative investment managers typically exercise broad investment discretion and may apply
similar strategies across multiple investment vehicles, resulting in less diversification.
Bond Funds: A fund that invests in bonds, or other debt securities. Bond funds can be contrasted with stock
funds and money funds. Bond funds typically pay periodic dividends that include interest payments on the
fund's underlying securities plus periodic realized capital appreciation. Bond funds typically pay higher
dividends than a certificate of deposit (“CD”) and money market accounts. Most bond funds pay out dividends
more frequently than individual bonds.
Bond Funds can be classified by their primary underlying assets: (a) Government: Government bonds are
considered safest, since a government can always "print more money" to pay its debt. In the United States, these
are United States Treasury securities or Treasurys. Due to the safety, the yields are typically low.; (b) Agency:
In the United States, these are bonds issued by government agencies such as the Government National Mortgage
Association (Ginnie Mae), Federal Home Loan Mortgage Corp. (Freddie Mac), and Federal National Mortgage
Association (Fannie Mae).; (c) Municipal: Bonds issued by state and local governments and agencies are subject
to certain tax preferences and are typically exempt from federal taxes. In some cases, these bonds are even
exempt from state or local taxes.; and (d) Corporate: Bonds are issued by corporations. All corporate bonds are
guaranteed by the borrowing (issuing) company, and the risk depends on the company's ability to pay the loan
at maturity. Some bond funds specialize in high-yield securities (junk bonds), which are corporate bonds
carrying a higher risk, due to the potential inability of the issuer to repay the bond. Bond funds specializing in
junk bonds – also known as "below investment-grade bonds" – pay higher dividends than other bond funds,
with the dividend return correlating approximately with the risk. Bond funds may also be classified by factors
such as type of yield (high income) or term (short, medium, long) or some other specialty such as zero-coupon
bonds, international bonds, multisector bonds or convertible bonds.
Fund managers provide dedicated management and save the individual investor from researching issuer
creditworthiness, maturity, price, face value, coupon rate, yield, and countless other factors that affect bond
investing. Bond funds invest in many individual bonds, so that even a relatively small investment is
diversified—and when an underperforming bond is just one of many bonds in a fund, its negative impact on an
investor's overall portfolio is lessened. In a fund, income from all bonds can be reinvested automatically and
consistently added to the value of the fund. Investors can sell shares in a bond fund at any time without regard
to bond maturities.
Bond funds typically charge a fee, often as a percentage of the total investment amount. This fee is not
applicable to individually held bonds. Bond fund dividend payments may not be fixed as with the interest
payments of an individually held bond, leading to potential fluctuation of the value of dividend payments. The
net asset value (“NAV”) of a bond fund may change over time, unlike an individual bond in which the total issue
price will be returned upon maturity (provided the bond issuer does not default).
Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars or highly
liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and commercial papers.
Generally, these assets are considered nonproductive and will be exposed to inflation risk and considerable
opportunity cost risk. Investments in cash and cash equivalents will generally return less than the advisory fee
charged by our firm. Our firm may recommend cash and cash equivalents as part of our clients’ asset allocation
when deemed appropriate and in their best interest. Our firm considers cash and cash equivalents to be an
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Crane & Associates Wealth Management
asset class. Therefore, our firm assess an advisory fee on cash and cash equivalents unless indicated otherwise
in writing.
Cryptocurrency Products: We may recommend investment in digital (crypto) currency products. These
products may be structured as exchange traded funds or exchange traded products which pool capital together
to purchase holdings of digital currencies based on their value. Such products are extremely volatile and are
suitable only as a means of diversification for investors with high-risk tolerances.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end fund or
unit investment trust) whose primary objective is to achieve the same return as a particular market index. The
vast majority of ETFs are designed to track an index, so their performance is close to that of an index mutual
fund, but they are not exact duplicates. A tracking error, or the difference between the returns of a fund and the
returns of the index, can arise due to differences in composition, management fees, expenses, and handling of
dividends. ETFs benefit from continuous pricing; they can be bought and sold on a stock exchange throughout
the trading day. Because ETFs trade like stocks, you can place orders just like with individual stocks - such as
limit orders, good-until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual
funds are bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are independent of it.
However, arbitrageurs will ensure that ETF prices are kept very close to the NAV of the underlying securities.
Although an investor can buy as few as one share of an ETF, most buy in board lots. Anything bought in less
than a board lot will increase the cost to the investor. Anyone can buy any ETF no matter where in the world it
trades. This provides a benefit over mutual funds, which generally can only be bought in the country in which
they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional mutual
funds. The passive nature of index investing, reduced marketing, and distribution and accounting expenses all
contribute to the lower fees. However, individual investors must pay a brokerage commission to purchase and
sell ETF shares; for those investors who trade frequently, this can significantly increase the cost of investing in
ETFs. That said, with the advent of low-cost brokerage fees, small or frequent purchases of ETFs are becoming
more cost efficient.
Exchange Traded Notes (“ETN”): An ETN is a senior, unsecured, unsubordinated debt security by an
underwriting bank whose primary objective is to achieve the same return as a particular market index. Similar
to other debt securities, the credit of the issuer is the only backing for ETNs, which have a maturity date.
Although performance is contractually tied to whatever index the ETN is intended to track, ETNs do not have
any assets, other than a claim against their issuer for payment according to the terms of the contract. Unlike
traditional mutual funds, which can only be redeemed at the end of a trading day, ETNs trade throughout the
day on an exchange. ETNs, as debt instruments, are subject to risk of default by the issuing bank as counter
party. This is the major design difference between ETFs and ETNs: ETFs are only subject to market risk whereas
ETNs are subject to both market risk and the risk of default by the issuing bank.
Equity Securities: Equity securities represent an ownership position in a company. Equity securities typically
consist of common stocks. The prices of equity securities fluctuate based on, among other things, events specific
to their issuers and market, economic and other conditions. For example, prices of these securities can be
affected by financial contracts held by the issuer or third parties (such as derivatives) relating to the security
or other assets or indices. There may be little trading in the secondary market for particular equity securities,
which may adversely affect our firm 's ability to value accurately or dispose of such equity securities. Adverse
publicity and investor perceptions, whether or not based on fundamental analysis, may decrease the value
and/or liquidity of equity securities. Investing in smaller companies may pose additional risks as it is often
more difficult to value or dispose of small company stocks, more difficult to obtain information about smaller
companies, and the prices of their stocks may be more volatile than stocks of larger, more established
companies. Clients should have a long-term perspective and, for example, be able to tolerate potentially sharp
declines in value.
Fee-Based Variable Annuities (“VA”): A variable annuity is a type of annuity contract that allows for the
accumulation of capital on a tax-deferred basis. As opposed to a fixed annuity that offers a guaranteed interest
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Crane & Associates Wealth Management
rate and a minimum payment at annuitization, variable annuities offer investors the opportunity to generate
higher rates of returns by investing in equity and bond subaccounts. If a variable annuity is annuitized for
income, the income payments can vary based on the performance of the subaccounts. Risks associated with
VAs may include:
Taxes and federal penalties for early withdrawal
Earnings taxed at ordinary income tax rates
Mortality expense to compensate the insurance company for insurance risks
Fees and expenses imposed for the subaccounts
Other features with additional fees and charges
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or periodic
income is received at regular intervals and at reasonably predictable levels. Fixed-income investors are
typically retired individuals who rely on their investments to provide a regular, stable income stream. This
demographic tends to invest heavily in fixed-income investments because of the reliable returns they offer.
Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding
their spending power.
Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds,
asset-backed securities, municipal bonds and international bonds. The primary risk associated with fixed-
income investments is the borrower defaulting on his payment. Other considerations include exchange rate
risk for international bonds and interest rate risk for longer-dated securities. The most common type of fixed-
income security is a bond. Bonds are issued by federal governments, local municipalities and major
corporations. Fixed-income securities are recommended for investors seeking a diverse portfolio; however, the
percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There
is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio.
The interest payment on fixed-income securities is considered regular income and is determined based on the
creditworthiness of the borrower and current market rates. In general, bonds and fixed-income securities with
longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered
riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end
of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the
principal or par value.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long time
(more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this
strategy is that our firm could miss out on potential short-term gains that could have been profitable to your
account, or it is possible that the security’s value may decline sharply before our firm decides to sell.
Money Market Fund: Money market funds have relatively low risks, compared to other mutual funds (and
most other investments). By law, they can invest in only certain high quality, short-term investments issued by
the U.S. Government, U.S. corporations, and state and local governments. Money market funds try to keep their
net asset value (NAV), which represents the value of one share in a fund, at a stable $1.00 per share. However,
the NAV may fall below $1.00 if the fund’s investments perform poorly. Investor losses have been rare, but they
are possible. Money market funds pay dividends that generally reflect short-term interest rates, and
historically, the returns for money market funds have been lower than for either bond or stock funds. That is
why “inflation risk,” the risk that inflation, will outpace and erode investment returns over time, and can be a
potential concern for investors in money market funds.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests that money in
a variety of differing security types based on the objectives of the fund. The portfolio of the fund consists of the
combined holdings it owns. Each share represents an investor’s proportionate ownership of the fund’s holdings
and the income those holdings generate. The price that investors pay for mutual fund shares are the fund’s per
share net asset value (“NAV”) plus any shareholder fees that the fund imposes at the time of purchase (such as
sales loads). Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor
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Crane & Associates Wealth Management
can they directly influence which securities the fund manager buys and sells or the timing of those trades. With
an individual stock, investors can obtain real-time (or close to real-time) pricing information with relative ease
by checking financial websites or by calling a broker or your investment adviser. Investors can also monitor
how a stock’s price changes from hour to hour—or even second to second. By contrast, with a mutual fund, the
price at which an investor purchases or redeems shares will typically depend on the fund’s NAV, which is
calculated daily after market close.
The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed by an
investment adviser who researches, selects, and monitors the performance of the securities purchased by the
fund; (b) Mutual funds typically have the benefit of diversification, which is an investing strategy that generally
sums up as “Don’t put all your eggs in one basket.” Spreading investments across a wide range of companies
and industry sectors can help lower the risk if a company or sector fails. Some investors find it easier to achieve
diversification through ownership of mutual funds rather than through ownership of individual stocks or
bonds.; (c) Some mutual funds accommodate investors who do not have a lot of money to invest by setting
relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any
time, mutual fund investors can readily redeem their shares at the current NAV, less any fees and charges
assessed on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must pay sales
charges, annual fees, and other expenses regardless of how the fund performs. Depending on the timing of their
investment, investors may also have to pay taxes on any capital gains distributions they receive. This includes
instances where the fund performed poorly after purchasing shares.; (b) Investors typically cannot ascertain
the exact make-up of a fund’s portfolio at any given time, nor can they directly influence which securities the
fund manager buys and sells or the timing of those trades.; and (c) With an individual stock, investors can obtain
real-time (or close to real-time) pricing information with relative ease by checking financial websites or by
calling a broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour
to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor purchases
or redeems shares will typically depend on the fund’s NAV, which the fund might not calculate until many hours
after the investor placed the order. In general, mutual funds must calculate their NAV at least once every
business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year on the
dividends or interest the investor receives. However, the investor will not have to pay any capital gains tax until
the investor actually sells and makes a profit. Mutual funds, however, are different. When an investor buys and
holds mutual fund shares, the investor will owe income tax on any ordinary dividends in the year the investor
receives or reinvests them. Moreover, in addition to owing taxes on any personal capital gains when the
investor sells shares, the investor may have to pay taxes each year on the fund’s capital gains. That is because
the law requires mutual funds to distribute capital gains to shareholders if they sell securities for a profit, and
cannot use losses to offset these gains.
Proprietary Models: Our firm develops proprietary asset allocation models and investment strategies as part
of our investment process. The purpose of these models and strategies is to create a foundation for clients’
investment portfolios based on their individual risk tolerance, investment timeframe, and specific investment
goals. Our proprietary models provide recommended percentage allocation ranges to specific asset classes
based on risk tolerance. Our risk tolerance models typically range from aggressive to conservative, with several
levels in between. Our firm then tailors our investment model to fit clients’ individual investment needs and
goals. The risks associated with our proprietary models reflect risks similar to that of asset allocation strategies.
This includes that a client may not participate in sharp increases in a particular security, industry or market
sector. Another risk is that a client’s actual holdings may deviate from the model over time and if not corrected,
may no longer be appropriate for the client’s goals.
Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea of
selling them within a relatively short time (typically a year or less). Our firm does this in an attempt to take
advantage of conditions that our firm believes will soon result in a price swing in the securities our firm
purchase.
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Crane & Associates Wealth Management
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may
increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease, and the
account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the
stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask
our firm any questions regarding their risk tolerance.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may
lose 100% of your money. All investments carry some form of risk, and the loss of capital is generally a risk for
any investment instrument.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can
be reduced through appropriate diversification. There is the risk that the company will perform poorly or have
its value reduced based on factors specific to the company or its industry. For example, if a company’s
employees go on strike or the company receives unfavorable media attention for its actions, the value of the
company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s
repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance
if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve
forms of indebtedness (i.e. borrowed funds) are subject to credit risk.
Cryptocurrency Products: Cryptocurrencies (hereinafter, “Digital Assets”) involves risks, including extreme
volatility, that may continue indefinitely and may create a future material adverse effect on the value of the
asset. Digital assets were introduced within the past two decades, and the medium-to-long term value of the
assets is subject to several factors relating to the capabilities and development of blockchain technologies and
to the fundamental investment characteristics of Digital Assets. The volatility of Digital Assets and
cryptocurrencies are subject to a few risk factors including, but not limited to, the following:
•
the economic conditions in the Digital Asset industry and market (such as an increase in the global
supply of such Digital Asset(s));
•
• manipulative activity on Digital Asset exchanges;
•
forks in the applicable Digital Asset network;
•
scaling challenges in the effort to increase the volume and speed of transactions;
•
changes in laws or regulations, including those concerning taxes made by governmental authorities or
regulatory bodies;
litigation or regulatory investigations concerning the Digital Assets classification under the federal
securities laws and the costs and effect of any litigation or regulatory investigations;
• general economic, market and business conditions; and
• other global or regional political, economic, or financial conditions, events, and situations, such as
pandemic outbreak, hackers or other malicious actors, destruction of Digital Assets, reliance on Digital
Asset service providers, and general governmental oversight of Digital Assets.
Digital Asset investors are necessarily subject to the risk brought by the fact that Digital Assets represent a new
and rapidly evolving industry. The unregulated nature and lack of transparency surrounding the operations of
Digital Asset exchanges create an opportunity for investors to experience fraud, security failures, or operational
problems, which may adversely affect the value of the Digital Assets. Investors are also subject to the risk of
changes in the governance of Digital Assets and Digital Asset exchanges. Digital Asset values can fluctuate
substantially, which may result in a total loss of the value of the digital assets. We do not own or control any of
the protocols that are used in connection with Digital Asset Products available on your custodial platform and
their related networks.
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Crane & Associates Wealth Management
Economic Risk: The prevailing economic environment is important to the health of all businesses. Some
companies, however, are more sensitive to changes in the domestic or global economy than others. These types
of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are
in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If
an investment is issued by a party located in a country that experiences wide swings from an economic
standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such
countries, the investment instrument will generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and, volatile
increases and decreases in value as market confidence in and perceptions of their issuers change. If you held
common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater
risk than if you held preferred stocks and debt obligations of the issuer.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk, which is
the risk that their value will generally decline as prevailing interest rates rise, which may cause your account
value to likewise decrease, and vice versa. How specific fixed income securities may react to changes in interest
rates will depend on the specific characteristics of each security. Fixed-income securities are also subject to
credit risk, prepayment risk, valuation risk, and liquidity risk. Credit risk is the chance that a bond issuer will
fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make
such payments will cause the price of a bond to decline.
Foreign Exposure Risk: Our firm may have exposure to foreign markets, including emerging markets, which
can be more volatile than the U.S. markets. As a result, returns and net asset value may be affected to a large
degree by fluctuations in currency exchange rates or political or economic conditions in a particular country.
Any investments in emerging market countries may involve risks greater than, or in addition to, the risks of
investing in more developed countries.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds from your
investment will not be worth what they are today. Throughout time, the prices of resources and end-user
products generally increase and thus, the same general goods and products today will likely be more expensive
in the future. The longer an investment is held, the greater the chance that the proceeds from that investment
will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get
you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the
investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a
particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value
of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market
will have an inverse relationship to the value of existing, interest-paying investments. In other words, as
interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go
down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by changes in state
or federal laws or in the prevailing regulatory framework under which the investment instrument or its issuer
is regulated. Changes in the regulatory environment or tax laws can affect the performance of certain
investments or issuers of those investments and thus, can have a negative impact on the overall performance
of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market in
which they trade. This can create a substantial delay in the receipt of proceeds from an investment. Liquidity
risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment
before the price drops significantly) a particular investment and therefore, can have a negative impact on
investment returns.
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Crane & Associates Wealth Management
Market Risk: The value of your portfolio may decrease if the value of an individual company or multiple
companies in the portfolio decreases or if our belief about a company’s intrinsic worth is incorrect. Further,
regardless of how well individual companies perform, the value of your portfolio could also decrease if there
are deteriorating economic or market conditions. It is important to understand that the value of your
investment may fall, sometimes sharply, in response to changes in the market, and you could lose money.
Investment risks include price risk as may be observed by a drop in a security’s price due to company specific
events (e.g. earnings disappointment or downgrade in the rating of a bond) or general market risk (e.g. such as
a “bear” market when stock values fall in general). For fixed-income securities, a period of rising interest rates
could erode the value of a bond since bond values generally fall as bond yields go up. Past performance is not a
guarantee of future returns.
Market Timing Risk: Market timing can include high risk of loss since it looks at an aggregate market versus
a specific security. Timing risk explains the potential for missing out on beneficial movements in price due to
an error in timing. This could cause harm to the value of an investor's portfolio because of purchasing too high
or selling too low.
Past Performance: Charting and technical analysis are often used interchangeably. Technical analysis
generally attempts to forecast an investment’s future potential by analyzing its past performance and other
related statistics. In particular, technical analysis often times involves an evaluation of historical pricing and
volume of a particular security for the purpose of forecasting where future price and volume figures may go.
As with any investment analysis method, technical analysis runs the risk of not knowing the future and thus,
investors should realize that even the most diligent and thorough technical analysis cannot predict or
guarantee the future performance of any particular investment instrument or issuer thereof.
Strategy Risk: There is no guarantee that the investment strategies discussed herein will work under all
market conditions and each investor should evaluate his/her ability to maintain any investment he/she is
considering in light of his/her own investment time horizon. Investments are subject to risk, including possible
loss of principal.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit,
high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to
achieve the highest return on client cash balances through relatively low-risk conservative investments. In
most cases, at least a partial cash balance will be maintained in a money market account so that our firm may
debit advisory fees for our services related to our Comprehensive Portfolio Management services.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business or the
integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are dually registered as investment adviser representatives (“IAR”) of Cetera
Investment Advisors. A conflict of interest arises out of being an IAR for multiple investment advisory firms. To
mitigate this conflict, our representatives will act in the Client’s best interest. Furthermore, any services offered
through Cetera will remain separate from our firm’s advisory services and will be governed under a separate
agreement.
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Crane & Associates Wealth Management
Representatives of our firm are registered representatives of Cetera Wealth Services LLC, member FINRA/SIPC,
and licensed insurance agents. As a result of these transactions, they receive normal and customary
commissions. A conflict of interest exists as these commissionable securities sales create an incentive to
recommend products based on the compensation earned. To mitigate this potential conflict, our firm will act in
the Client’s best interest.
Representatives of our firm are licensed insurance agents. As a result of these transactions, they
receive normal and customary commissions. A conflict of interest exists as these commissionable
sales create an incentive to recommend products based on the compensation earned. To mitigate this
potential conflict, our firm will act in the client’s best interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and
to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for
our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our
firm requires all representatives to conduct business with the highest level of ethical standards and to comply with
all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter,
all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of
Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This
disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demand the application of a
Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not
endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for
clients and for our representatives, it is logical, and even desirable, that there be common ownership of some
securities.
To prevent conflicts of interest, our firm has established procedures for transactions effected by our
representatives for their personal accounts1. To monitor compliance with our personal trading policy, our firm has
pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our
firm or a related person has a material financial interest without prior disclosure to the client. Related persons
of our firm may buy or sell securities and other investments that are also recommended to clients. To minimize
this conflict of interest, our related persons will place client interests ahead of their own interests and adhere
to our firm’s Code of Ethics, a copy of which is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell
the same securities for client accounts. To minimize this conflict of interest, our related persons will place client
interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon
request. Except under limited circumstances, our related persons will refrain from buying or selling securities that
will be bought or sold in client accounts unless done so after the client execution or concurrently as a part of a block
trade.
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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Crane & Associates Wealth Management
Item 12: Brokerage Practices
Custodian & Brokers Used: Our firm does not maintain custody of client assets (although our firm may be
deemed to have custody of client assets if given the authority to withdraw assets from client accounts. See Item
15 Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division of Charles
Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Our
firm is independently owned and operated, and not affiliated with Schwab. Schwab will hold client assets in a
brokerage account and buy and sell securities when instructed. While our firm recommends that clients use
Schwab as custodian/broker, clients will decide whether to do so and open an account with Schwab by entering
into an account agreement directly with them. Our firm does not open the account. Even though the account is
maintained at Schwab, our firm can still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected: Our firm seeks to recommend a custodian/broker who will hold
client assets and execute transactions on terms that are overall most advantageous when compared to other
available providers and their services. A wide range of factors are considered, including, but not limited to:
combination of transaction execution services along with asset custody services (generally without a
separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds
(ETFs), etc.)
availability of investment research and tools that assist in making investment decisions quality of
services
competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.)
and willingness to negotiate them
reputation, financial strength and stability of the provider
prior service to our firm and our other clients
availability of other products and services that benefit our firm, as discussed below (see “Products &
Services Available from Schwab”)
Custody & Brokerage Costs: Schwab generally does not charge a separate fee for custody services but is
compensated by charging commissions or other fees to clients on trades that are executed or that settle into
the Schwab account. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or
“trade away” fee for each trade that our firm has executed by a different broker-dealer but where the securities
bought or the funds from the securities sold are deposited (settled) into a Schwab account. These fees are in
addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, to
minimize client trading costs, our firm has Schwab execute most trades for the accounts.
Products & Services Available from Schwab: Schwab Advisor Services is Schwab’s business serving
independent investment advisory firms like our firm. They provide our firm and clients with access to its
institutional brokerage – trading, custody, reporting and related services – many of which are not typically
available to Schwab retail customers. Schwab also makes available various support services. Some of those
services help manage or administer our client accounts while others help manage and grow our business.
Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request
them) and at no charge to our firm. The availability of Schwab’s products and services is not based on the
provision of particular investment advice, such as purchasing particular securities for clients. Here is a more
detailed description of Schwab’s support services:
Services that Benefit Clients: Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which our firm might not otherwise have access or that
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Crane & Associates Wealth Management
would require a significantly higher minimum initial investment by firm clients. Schwab’s services described
in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients: Schwab also makes available other products and services that
benefit our firm but may not directly benefit clients or their accounts. These products and services assist in
managing and administering our client accounts. They include investment research, both Schwab’s and that of
third parties. This research may be used to service all or some substantial number of client accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides access to client account data (such as duplicate trade confirmations and account statements);
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm: Schwab also offers other services intended to help manage
and further develop our business enterprise. These services include:
educational conferences and events
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors
to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay
all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional
business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance the client
experience, help clients reach their goals and put client interests before that of our firm or associated persons.
Our Interest in Schwab’s Services. The availability of these services from Schwab benefits our firm because
our firm does not have to produce or purchase them. Our firm does not have to pay for these services, and they
are not contingent upon committing any specific amount of business to Schwab in trading commissions or
assets in custody.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive to require
that clients maintain their accounts with Schwab based on our interest in receiving Schwab’s services that
benefit our firm rather than based on client interest in receiving the best value in custody services and the most
favorable execution of transactions. As part of our fiduciary duty to our clients, our firm will endeavor at all
times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic
benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence
our firm’s choice of Schwab as a custodial recommendation. Our firm examined this potential conflict of interest
when our firm chose to recommend Schwab and have determined that the recommendation is in the best interest
of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services,
including the value of research provided, execution capability, commission rates, and responsiveness. Although
our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest
possible commission rates for specific client account transactions. Our firm believes that the selection of
Schwab as a custodian and broker is the best interest of our clients. It is primarily supported by the scope,
quality and price of Schwab’s services, and not Schwab’s services that only benefit our firm.
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Crane & Associates Wealth Management
Client Brokerage Commissions
Schwab does not make client brokerage commissions generated by client transactions available for our firm’s
use.
Client Transactions in Return for Soft Dollars
Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Directed Brokerage
Our firm routinely requires that Clients direct us to execute through a specified broker-dealer. Our firm
requires the use of Schwab. Please note that not all advisory firms have this requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a
specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted
provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary
course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits
directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the
plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter
documenting that this arrangement will be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm does not allow client-directed brokerage.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which portfolio
transactions may be executed as part of concurrent authorizations to purchase or sell the same security for
numerous accounts served by our firm, which involve accounts with similar investment objectives or similar levels
of review. Although such concurrent authorizations potentially could be either advantageous or disadvantageous
to any one or more particular accounts, they are affected only when our firm believes that to do so will be in the
best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the
executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm
attempts to allocate trade executions in the most equitable manner possible, taking into consideration client
objectives, levels of review, current asset allocation and availability of funds using price averaging, proration, and
consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Comprehensive Portfolio Management Clients. The nature of these reviews is to learn whether client accounts
are in line with their investment objectives, appropriately positioned based on market conditions, and
investment policies, if applicable. Our firm provides written account and performance reports on at least an
annual basis. Our firm may review client accounts more frequently than described above. Among the factors
which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by
the client, etc.
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Crane & Associates Wealth Management
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our
firm also provides ongoing services where clients are met with upon their request to discuss updates to their
plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal
updated reports regarding their plans unless they choose to engage our firm for ongoing services.
Item 14: Client Referrals & Other Compensation
Schwab
Our firm receives economic benefit from Schwab in the form of the support products and services made
available to our firm and other independent investment advisors that have their clients maintain accounts at
Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are
described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not
based on our firm giving particular investment advice, such as buying particular securities for our clients.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent solicitors (non-registered
representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-3 of the Investment
Advisers Act of 1940.
Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a qualified
custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to
withdraw assets from client accounts, as further described below under “Third Party Money Movement.” All
our clients receive account statements directly from their qualified custodian(s) at least quarterly upon
opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides
to send its own account statements to clients, such statements will include a legend that recommends the client
compare the account statements received from the qualified custodian with those received from our firm.
Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and
our custodial recommendations.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4) -2 (“Custody
Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody
Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a
standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following
safeguards in conjunction with our custodian:
The client provides an instruction to the qualified custodian, in writing, that includes the client’s
signature, the third party’s name, and either the third party’s address or the third party’s account number
at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or
separately, to direct transfers to the third party either on a specified schedule or from time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such as a signature
review or other method to verify the client’s authorization and provides a transfer of funds notice to the
client promptly after each transfer.
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Crane & Associates Wealth Management
The client has the ability to terminate or change the instruction to the client’s qualified custodian.
The investment adviser has no authority or ability to designate or change the identity of the third party,
the address, or any other information about the third party contained in the client’s instruction.
The investment adviser maintains records showing that the third party is not a related party of the
investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction
and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an
executed investment advisory client agreement. By granting investment discretion, our firm is authorized,
without prior consultation with the Client, to execute securities transactions, determine which securities are
bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the client in the
form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement.
Should clients grant our firm non-discretionary authority, our firm would be required to obtain the Client’s
permission prior to effecting securities transactions. However, sales for distributions, advisory fee payments,
and covering negative cash balances shall not be considered discretion and will not require the Client’s
permission.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other
solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our
firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the
client in the future. Clients may call, write, or email us to discuss questions they may have about particular
proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered
within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet contractual
and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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Crane & Associates Wealth Management