Overview
- Headquarters
- Portland, OR
- Average Client Assets
- $2.0 million
- SEC CRD Number
- 149937
Fee Structure
Primary Fee Schedule (CS PLANNING CORP DBA THE COLLINGWOOD GROUP)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.40% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.15% |
| $2,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,500 | 1.35% |
| $5 million | $55,000 | 1.10% |
| $10 million | $92,500 | 0.92% |
| $50 million | $392,500 | 0.78% |
| $100 million | $767,500 | 0.77% |
Clients
- HNW Share of Firm Assets
- 54.20%
- Total Client Accounts
- 9,340
- Discretionary Accounts
- 9,340
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: CS PLANNING CORP - THAYER & CO WEALTH MANAGEMENT - FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Thayer & Co. Total Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA THAYER & CO. TOTAL WEALTH
MANAGEMENT
8117 Preston Road, Suite 300
Dallas, TX 75225
Phone: (214) 361-3555
Kate@ThayerWealth.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Thayer & Co. Total Wealth Management. If you have any questions about the contents
of this Brochure or to obtain answers and additional information, you may contact us at (214) 361-
3555 or Kate@ThayerWealth.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested, free of charge, by contacting us at (214) 361-3555.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 4
Item 5 – Fees and Compensation ................................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 8
Item 7 – Types of Clients ................................................................................................................................ 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 9
Item 9 – Disciplinary Information ............................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 12
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 13
Item 12 – Brokerage Practices ..................................................................................................................... 14
Item 13 – Review of Accounts ..................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .............................................................................. 16
Item 15 – Custody ........................................................................................................................................... 16
Item 16 – Investment Discretion ................................................................................................................. 17
Item 17 – Voting Client Securities .............................................................................................................. 17
Item 18 – Financial Information .................................................................................................................. 18
Exhibit A – Summary of Material Changes ................................................................................................ 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with BluePrint Financial Marketing, LLC, a Texas
limited liability company doing business as Thayer & Co. Total Wealth Management, managed
by Kathleen Thayer Rentz. Mrs. Rentz is an Investment Advisor Representative associated with
CSP, offers investment advisory services exclusively through CSP, and only utilizes Thayer & Co.
Total Wealth Management for marketing purposes. Thayer & Co. Total Wealth Management is
not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
In addition to Wealth Management services, we offer financial planning services to Clients under
a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
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We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fees: 1.95% on all assets.
Existing clients may be grandfathered into a different fee.
We may also provide standalone financial planning services to Clients on a fixed fee or hourly rate
under a separate Financial Planning Agreement. Our fixed fee pricing is quoted for each project,
and is based on the scope and complexity of the project. Our maximum hourly rate is $150 per
hour. Prior to commencing planning services, Clients enter into a Financial Planning Agreement
which sets forth the services being provided and the fees being charged. Notwithstanding the
above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
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be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
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conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products, we do not know the actual dollar
amount of any commission payment to an Insurance Agent. Also, because CSP is neither a broker
dealer nor an insurance agency, we do not have the ability to rebate commissions received for the
sale of a product and cannot discount the price of a product to make up for any commission that
may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
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follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
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Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
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such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
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Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
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their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
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fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (214) 361-3555. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
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not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Thayer & Co. Total
Wealth Management shall not buy or sell securities for his personal portfolio where
his decision is substantially derived, in whole or in part, by reason of his
employment unless the information is also available to the investing public on
reasonable inquiry. No person associated with CSP and Thayer & Co. Total Wealth
Management shall prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
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We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
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Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they have
any questions about the foregoing arrangements.
Item 15 – Custody
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We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
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behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Kathleen Thayer Rentz, have been the subject of a
bankruptcy petition at any time in the past. We have no financial conditions that would impair our
ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 10, 2025. Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that you receive a summary of any material changes to this and subsequent
Brochures within 120 days of the close of our business’ fiscal year. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you
with a new Brochure as necessary based on changes or new information, at any time, without
charge.
Currently, our Brochure may be requested by contacting us at (214) 361-3555. Our Brochure is
provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP - MORIN PRIVATE CLIENT GROUP - FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Morin Private Client Group
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA MORIN PRIVATE CLIENT GROUP
240 West Broadway
Jackson, WY 83001
Phone: (833) 989-2869
bmorin@mp-cg.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (833)
989-2869 or bmorin@mp-cg.com to obtain answers and additional information. CS Planning Corp
is a registered investment adviser with the United States Securities and Exchange Commission
(“SEC”). Registration of an investment adviser does not imply any level of skill or training. The
information in this Brochure has not been approved or verified by the SEC or by any state securities
authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (833) 989-2869 or bmorin@mp-
cg.com. Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ................................................................................. Ex.
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Morin Private Client Group, LLC, a
Wyoming limited liability company (“Morin Private Client Group”) owned and managed by
Robert A. Morin. Mr. Morin is an Investment Advisor Representative associated with CSP and
offers investment advisory services through CSP and through Morin Private Client Group, LLC
an SEC registered investment advisor located in Wyoming. Morin Private Client Group is not
affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Annual Wealth Management Retainer Fee:
Maximum 2.5% on assets up to $1,000,000
Maximum 1.5% on assets $1,000,000 to $3,000,000
Maximum 1.0% on assets over $3,000,000
Morin Private Client Group does not offer financial planning services on a stand-alone basis in
general. However, we offer financial planning advice with mutual agreement as part of the
investment management services at no additional charge. This will typically include planning
regarding the investment, management, taxes and use of financial resources based upon an
assessment of a client’s individual situation and goals. We do not provide legal or accounting
services and do not prepare legal documents or tax returns.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and
complexity of the project. Our maximum hourly rate is $250.00 per hour. Prior to commencing
planning services, Clients enter into a Consulting or Financial Planning Agreement which sets
forth the services being provided and the fees being charged. Notwithstanding the above, fees are
generally negotiable.
Client’s asset management accounts are billed quarterly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
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Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
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conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
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give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed-end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
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and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
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payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
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• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital
Management, Inc. (“PCM”). PCM and CSP are under common control of Christopher K.
Hicks who is considered a control person of each firm because he holds more than 25%
ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliation
Certain associated persons of CSP are dually registered (“Dually Registered Persons”) as
registered representatives and/or investment advisor representatives of Purshe Kaplan Sterling
Investments (“PKS”), a registered investment advisor and independent broker-dealer firm and
Member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor
Protection Corporation (“SIPC”). Therefore, it is possible for clients to have both fee-based
advisory accounts through CSP and commission-based accounts through our Dually Registered
Persons via their registration with PKS. In these circumstances, our Dually Registered Persons
may receive fees and commissions for the sales of certain securities products, typically variable
annuities, to clients. However, in no instance will a client pay commissions in addition to advisory
fees in any single account. The dual registration of our financial professionals inherently represents
a conflict of interest, insofar as such individuals could recommend a fee-based (advisory) account
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over a commission-based (brokerage) account, or vice-versa, based on the potential level of
compensation to be received.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (833) 989-2869 or bmorin@mp-
cg.com. Brochures are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
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In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Morin Private Client
Group shall not buy or sell securities for his personal portfolio where his decision
is substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP or Morin Private Client Group shall prefer his or her
own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
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•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
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Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
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Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
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Neither CSP or any of its principals, nor Morin Private Client Group, LLC or any of its principals,
have been the subject of a bankruptcy petition at any time in the past. We have no financial
conditions that would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual amendment dated April 7, 2025. Since that date we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (833) 989-2869 or bmorin@mp-
cg.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA CHINESE ABRAHAM INVESTMENT ADVISORS - ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Chinese Abraham Investment Advisors
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA CHINESE ABRAHAM INVESTMENT ADVISORS
20111 Steven Creek Blvd., Suite 200
Cupertino, CA 95014
Phone: (408) 725-2975
william@chineseabraham.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (408)
725-2975 or william@chineseabraham.com to obtain answers and additional information. CS Planning
Corp is a registered investment adviser with the United States Securities and Exchange Commission
(“SEC”). Registration of an investment adviser does not imply any level of skill or training. The
information in this Brochure has not been approved or verified by the SEC or by any state securities
authority.
information about CS Planning Corp.
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
(408) 725-2975 or
Currently, our Brochure may be requested by contacting us at
william@chineseabraham.com. Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................... i
Item 2 – Material Changes ................................................................................................................................ ii
Item 3 – Table of Contents ............................................................................................................................. iii
Item 4 – Advisory Business .............................................................................................................................. 1
Item 5 – Fees and Compensation .................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 5
Item 7 – Types of Clients ................................................................................................................................. 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 6
Item 9 – Disciplinary Information .................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ......... 10
Item 12 – Brokerage Practices ....................................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................................... 12
Item 14 – Client Referrals and Other Compensation ................................................................................ 12
Item 15 – Custody ........................................................................................................................................... 13
Item 16 – Investment Discretion .................................................................................................................. 13
Item 17 – Voting Client Securities ................................................................................................................ 14
Item 18 – Financial Information ................................................................................................................... 14
Exhibit – A Summary of Material Changes ........................................................................................... Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland, Oregon.
We provide fee-only investment supervisory, portfolio management, investment consulting and
financial planning services. The firm has been in business since 2009. CSP is owned by Christopher
K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are used
for marketing purposes and may appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the Advisory Affiliate and not of our firm,
CSP, and the advisory services of the Advisory Affiliate are provided through our firm, CSP. CSP has
the arrangement described above with Chinese Abraham Investment Advisors LLC, a California
limited liability company (“Chinese Abraham Investment Advisors”) owned and managed by William
Fung. Mr. Fung is an Investment Advisor Representative associated with CSP and offers investment
advisory services through CSP and through Chinese Abraham Investment Advisors LLC, a state-
registered investment advisory firm located in Cupertino, California. Chinese Abraham Investment
Advisors is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to manage
client portfolios. Through our Advisory Affiliates, we help Clients coordinate and prioritize their
financial lives with all aspects of their life goals. Integrating investments across all individual
retirement accounts, taxable accounts, and employee retirement accounts is crucial to the process.
Client input and involvement are critical parts of the financial planning process and implementation
of investment decisions. After Client assets are invested, we continuously monitor their investments
and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory Affiliates
meet with Clients as needed to review portfolio performance, discuss current issues, and re-assess
goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit, municipal
securities, U.S. government securities, and money market funds when suitable and appropriate for a
Client’s particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See Item
8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client assets
on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
Chinese Abraham Investment Advisors offers investment advisory services that encompass a wide
range of investment objectives, from conservative to aggressive. This allows the client and us to design
a custom program and asset allocation that meets the client's specific needs. We provide investment
supervisory, financial planning and investment consulting services to Clients primarily under the
following fee schedules below:
Assets Under Management:
For all assets under management, the maximum annual wealth management retainer fee is
2.0%:
Active Management Program
The Active Management Program uses market timing and asset allocation to seek maximum returns
at acceptable risk. Clients have a variety of choices that range from lower-risk, all bond portfolios to
aggressive all equity portfolios or a combination of both, based on asset allocations tailored to the
needs of each client. These include regular IRA or other tax deferred accounts. The annual fee varies
(between 0.5% and 2.00%) depending upon the market value of assets under management. Lower fees
for comparable services may be available from other sources.
Tax Efficient Strategies
The Tax Efficient Strategies is designed for investors who seek long-term growth in a tax efficient
portfolio. This program is intended to be tax and cost efficient and has a similar annual fee schedule
(between 0.5% and 2%). Lower fees for comparable services may be available from other sources.
Chinese Abraham Investment Advisors does not offer financial planning services on a stand-alone
basis in general. However, we offer financial planning advice with mutual agreement as part of the
investment management services at no additional charge. This will typically include planning regarding
the investment, management, taxes and use of financial resources based upon an assessment of a
client’s individual situation and goals. We do not provide legal or accounting services and do not
prepare legal documents or tax returns.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee or
hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and complexity
of the project. Our maximum hourly rate is $275 per hour. Prior to commencing planning services,
Clients enter into a Consulting or Financial Planning Agreement which sets forth the services being
provided and the fees being charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly from
the client’s account by the custodian upon our submission of an invoice. Payment of fees may result
in the liquidation of Client’s securities if there is insufficient cash in the account. The fee is based on
the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded on a
market for which actual transaction prices are publicly reported are generally valued at the last reported
sale price on the principal market in which they are traded. Mutual Funds are only valued once per
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day after the close of the market. Whenever valuation information for specific, illiquid, foreign, private
or other investments is not available through the custodian, our approach will be to value at zero. We
do this in order to not overvalue a position which could potentially over inflate billing calculations.
Alternatively, we may also seek to obtain and document price information from at least one
independent source, whether it be a broker-dealer, bank, pricing service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of the
account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated based
on the number of days the account was open during the quarter. Quarterly fee adjustments for
additional assets received into an account during a quarter or for partial withdrawals may also be
provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30 days
written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g. wire
fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange traded funds
have additional internal expenses which generally include a fund management fee, other fund
expenses, and a possible distribution fee. In addition, some funds charge a redemption fee on shares
bought and sold within a short period. Funds describe their expenses in their prospectuses, summary
prospectuses, or product descriptions. Clients are advised that these fees are separate and additional
expenses incurred by the Client. See Item 12 for additional information on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as assisting
those advisors in implementation of all appropriate documents. However, we are not responsible for
attorney, accountant or other third party professional fees charged to Client as a result of these
activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more fully
disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written notice.
Upon termination, any fees that have been earned by us but not yet paid will be immediately due and
payable. Clients are also responsible for all applicable charges including, but not limited to, account
administrative fees, account closure fees and all trading costs due to the termination, including any
fees the mutual funds may assess. Upon request, we will provide a good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are generally
invoiced by us with payment due by the Client upon receipt of the invoice. We may estimate the
number of hours necessary to complete a project, and we may collect a portion of this estimate up
front and invoice the balance. Upon termination of any hourly or fixed fee project, any prepaid but
unearned fees will be promptly refunded to the Client.
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Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products through
various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or agency
and is not otherwise affiliated with any insurance brokerages or agencies. However, a conflict of
interest arises when insurance related business is transacted with advisory Clients because certain
individual Advisory Affiliates of CSP are independently licensed to sell insurance products through
various carriers. In their capacity as an Insurance Agent, they may receive commissions or other fees
from products sold to Clients. As such, Clients are advised that they are under no obligation to use
any individual associated with CSP for insurance products or services, and may use any insurance firm
or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance or
other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the actual
dollar amount of any commission payment to an Insurance Agent or Registered Representative. Also,
because CSP is neither a broker dealer nor an insurance agency, we do not have the ability to rebate
commissions received for the sale of a product and cannot discount the price of a product to make
up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from your
employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan
Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA,
or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also
recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts,
and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover
recommendations we are acting as fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-
based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of
interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e.,
receipt of additional fee-based compensation). You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest,
when we make rollover recommendations, we operate under a special rule that requires us to act in
your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
meet a professional standard of care when making investment recommendations (give prudent
advice);
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never put our financial interests ahead of yours when making recommendations (give loyal
advice);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1.
Under this approach, our role will be limited only to providing you with general educational materials
regarding the pros and cons of rollover transactions. We will make no recommendation to you
regarding the prospective rollover of your assets and you are advised to speak with your trusted tax
and legal advisors with respect to rollover decisions. As part of this educational approach, we may
provide you with materials discussing some or all of the following topics: the general pros and cons
of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement
withdrawals on retirement income; the investment options available inside your Plan Account; and
high level discussion of general investment concepts (e.g., risk versus return, the benefits of
diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide
you with questionnaires and/or interactive investment materials that may provide a means for you to
independently determine your future retirement income needs and to assess the impact of different
asset allocations on your retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client is
unique, they must be willing to be involved in the planning and ongoing processes. Such involvement
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does not have to be time consuming, however we want our Clients to remain informed about their
overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets, combined
with periodic rebalancing. Our Advisory Affiliates create an investment strategy with each Client,
outlining the investment philosophy, management procedures, and long-term goals for the investor.
Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed-end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer advice
on digital assets and cryptocurrency. Each type of security has its own unique set of risks associated
with it, and it would not be possible to disclose all of the specific risks of every type of investment in
this brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client pays
for part of a purchase and borrows the rest from the brokerage firm that custodies the account. If our
Clients have any questions regarding the risks associated with a particular investment, they are
encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager that
trades the fund’s investments in accordance with the fund's investment objective. While mutual funds
generally provide diversification, risks can be significantly increased if the fund is concentrated in a
particular sector of the market, primarily invests in small cap or speculative companies, uses leverage
(i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. Other fund risks include
foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk,
trading risk, and turnover risk that can increase fund expenses and may decrease fund performance.
Brokerage and transactions costs incurred by the fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such
as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is,
perhaps, the most significant risk associated with ETFs. This risk is defined by the day to day
fluctuations associated with any exchange traded security, where fluctuations occur in part based on
the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in numerous
ways. Price fluctuations and market risk are the most significant risk concerns. As such, the value of
your investment can increase or decrease over time. Furthermore, you should understand that stock
prices can be affected by many factors including, but not limited to, the overall health of the economy,
the health of the market sector or industry of the issuing company, and national and political events.
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When investing in stock, it is important to focus on the average returns achieved over a given period
of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but their risk
can also vary widely based on: the financial health of the issuer; the risk that the issuer might default;
when the bond is set to mature; and, whether or not the bond can be “called” prior to maturity. When
a bond is called, it may not be possible to replace it with a bond of equal character paying the same
rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time, generally
greater than one year. Sometimes we will employ a Short Term Purchase strategy where securities are
purchased with the expectation that they will be sold within a relatively short period of time, generally
less than one year, to take advantage of the securities’ short term price fluctuations. Short-term trading
(in general, selling securities within 30 days of purchasing the same securities) is not a fundamental
part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk when
suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum, Litecoin,
and others (collectively, “Cryptocurrency”). Where exposure to this asset class is appropriate, we will
typically, if not exclusively, obtain such exposure through purchases and sales of ETFs and other
publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative than
an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike the
market valuations of publicly-traded stocks and bonds which can be objectively valued on the basis
of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and other
factors, prices of Cryptocurrency are based entirely on the market’s perception of value and are subject
to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an extremely high
level of price volatility, including “flash crashes,” and may lose significant value in a matter of minutes,
hours, or days. It is not uncommon for the value of Cryptocurrency to move as much as twenty
percent (20%) or more in a single day. The ownership of particular Cryptocurrency is opaque and
therefore certain Cryptocurrency may be owned and controlled by relatively small number of
individuals, increasing the potential for fraud and market-manipulation such as pump-and-dump
schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is in
its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do not
create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of their
future viability as a store of value or a means of exchange. Federal, state, or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the United States is still developing.
Cryptocurrency is not legal tender in most jurisdictions, including the United States. No laws require
individuals or businesses to accept Cryptocurrency as a form of payment and Cryptocurrency does
not have any intrinsic value. Its value derives entirely from market forces of supply and demand.
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Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies. Cryptocurrency
exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or
malware. Due to relatively recent launches, most Cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, Cryptocurrency transactions are
irreversible, such that an improper transfer can only be reversed by the receiver of the cryptocurrency
agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would have
insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing economic,
demographic and social trends followed by a more focused analysis at the country level, then the
industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such as the
background and experience of the fund manager and/or the fund company (style, consistency, risk-
adjusted performance, management expenses, average daily trading volume, etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This strategy
would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should be
prepared to bear. We do not represent or guarantee that our services or methods of analysis can or
will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses
due to market corrections or declines. We cannot offer any guarantees or promises that your financial
goals and objectives will be met. Past performance is in no way an indication of future performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
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It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM offers
investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of CSP
Clients and will only transact insurance related business with Clients when the products are fully
disclosed, suitable, and appropriate to fit their needs, and in order to simplify the implementation of
various wealth management strategies.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms unaffiliated
with CSP. In their separate capacity as registered representatives, these Advisor Affiliates will typically
receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Advisory Affiliates of CSP.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals and
Other Compensation”), below. We do not believe this arrangement creates any conflicts of interest
with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM) or
sub-advisors who provide customized investment portfolio management services. These services may
include the construction of investment portfolios, execution of securities purchase and sale
transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-advisor
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to execute a confidentiality agreement and not share non-public personal information with any
unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If applicable,
any additional fees will be fully disclosed to Clients in a separate agreement with the TPAM or sub-
advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
upon
request by
contacting
at
(408)
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any Client
725-2975 or
us
or prospective Client
william@chineseabraham.com. Brochures are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their own
account that we buy and sell for Clients. When appropriate we will purchase or sell securities for
Clients before purchasing the same for our account or allowing representatives to purchase or sell the
same for their own account. However, we do allow the accounts of employees to be included in block
trading alongside the accounts of Clients. In some cases, we or our representatives may buy or sell
securities for our own account for reasons not related to the strategies adopted for our Clients. Our
employees are required to follow the Code of Ethics when making trades for their own accounts in
securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed
to assure that the personal securities transactions will not interfere with decisions made in the best
interest of advisory Clients while at the same time, allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we will
disclose to our advisory Clients any material conflict of interest relating to us, our representatives, or
any of our employees which could reasonably be expected to impair the rendering of unbiased and
objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Chinese Abraham
Investment Advisors shall not buy or sell securities for his personal portfolio where
his decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable inquiry.
No person associated with CSP or Chinese Abraham Investment Advisors shall prefer
his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated with
its advisory practice who has access to advisory recommendations. An appropriate
officer reviews these holdings on a regular basis.
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•
Any individual not in observance of the above may be subject to discipline up to and
including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which the
Client directs the use of a particular custodian if we believe that this choice would hinder either our
fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and with
the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of such
services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined by us
before the trade is placed with the broker. When practical, Client trades in the same security will be
bunched in a single order (a “block”) in an effort to obtain best execution at the best security price
available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to underlying
accounts on a pro rata basis, adjusted as necessary to keep Client transaction costs to
a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades, an
average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average price.
Multiple blocks may be executed within a single day. However, only trades executed
within the block on the single day may be combined for purposes of calculating the
average price.
It is expected that this trade aggregation and allocation policy will be applied consistently. However,
if application of this policy results in unfair or inequitable treatment to some or all of our Clients, we
may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which are
attributable to CSP occur, we shall take any steps necessary to put the Client in the position it should
have been as if the trade error never occurred. In the event we determine that a bona fide trade error
has occurred which is attributable to CSP, we will correct the trade error using funds from our error
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account. Depending on the internal trade error policies and procedures of the particular custodian,
our error account may be debited if the correction results in a loss. Likewise, our error account may
be credited if the correction results in a gain. This situation creates a conflict of interest as CSP has
an incentive to recommend particular custodians over others that may not have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of each
Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a particular
Client’s account. The Advisory Affiliate assigned to a particular Client’s account will be responsible
for the periodic reviews to that account. Clients will be provided the Supplemental Brochure (Form
ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; or
changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their accounts
generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates may also
provide Clients with periodic written reports summarizing the account activity and performance.
Along with these reports, we discuss the asset allocation of the portfolio compared to the portfolio
target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless otherwise
agreed at the start of the engagement. Dependent upon the level and scope of Financial Planning
services being provided, Advisor Affiliates will meet with clients at least twice per year or more often
as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with these
conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell insurance.
The conflicts of interest these arrangements present and how we deal with these conflicts are described
in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash compensation
to third-party intermediaries in exchange for their promotion, referral, and endorsement of our
advisory services to prospective clients. The cash compensation paid to such promoters may take the
form of a retainer, a flat advertising fee, a fee per referral, and/or a percentage of the advisory fees we
collect from referred client accounts. These fees may be paid to the promoter on a one-time or
recurring basis. Unless otherwise explicitly disclosed in writing to the client, the cash compensation
paid to a promoter will be borne entirely by CSP and the Advisory Affiliate. Referred clients do not
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pay any additional or increased advisory fees as a result of having been referred to our firm by a paid
third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940. Any
promoters engaged for this purpose will disclose to you at or reasonably prior to the time of their
referral or endorsement of CSP (i) that they will receive compensation from CSP as a result of their
endorsement of our firm; (ii) a description of the material terms of the compensation they will receive;
and (iii) a brief statement discussing the conflicts of interest arising out of the compensation
arrangement and/or the relationship between CSP and the third-party promoter. Clients referred to
our firm by a third-party promoter are encouraged to inquire with us if they have any questions about
the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise have
custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian or
any acts of the agents or employees of the custodian and whether or not the full amount or such loss
is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which
may be carried by the custodian. The Client understands that SIPC provides only limited protection
for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge all
Clients to carefully review statements from the custodian and compare these to any reports that we
may provide to you. Our reports may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary authority
to execute investment recommendations in accordance with an agreed upon investment strategy or
plan without the Client’s prior approval of each specific transaction. Under discretionary authority,
Client allows us to purchase and sell securities and instruments in their account(s), arrange for delivery
and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the
Client in matters necessary or incidental to the handling of the account, including monitoring certain
assets. The only restrictions on this discretionary authority are those set by the Client on a case by case
basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine or
make changes to a Client’s stated investment strategy without the Client’s prior approval. However,
CSP will still have complete discretion to implement its trading strategies to update the portfolio
allocation within that stated investment strategy, without the Client’s prior approval. In this type of
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situation, CSP will require authorization from the Client before making any changes to a Client’s
investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether authority
is discretionary or non-discretionary. Further, we make it a practice to question Clients to determine
if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do not
provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf
of a Client, they will be sent directly to the Client who remains responsible to vote the proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to Clients.
Neither CSP or any of its principals, nor Chinese Abraham Investment Advisors, LLC or any of its
principals, have been the subject of a bankruptcy petition at any time in the past. We have no financial
conditions that would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual amendment dated March 31, 2025. Since that date we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
(408) 725-2975 or
Currently, our Brochure may be requested by contacting us at
william@chineseabraham.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA FINANCIAL ALTERNATIVES (SPOKANE) (2026-04-30)
View Document Text
CS Planning Corp dba Financial Alternatives
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA FINANCIAL ALTERNATIVES
1212 N. Washington St. Ste 116
Spokane, WA 99201
(509) 342-7788
https://www.finaltllc.com/
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (509)
663-7526 or epeterson@finaltllc.com to obtain answers and additional information. CS Planning
Corp is a registered investment adviser with the United States Securities and Exchange
Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or
training. The information in this Brochure has not been approved or verified by the SEC or by any
state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further
provide other ongoing disclosure information about material changes as necessary and will further
provide you with a new Brochure as necessary based on changes or new information, at any time,
without charge.
Currently, our Brochure may be requested by contacting us at (509) 663-7526 or
epeterson@finaltllc.com . Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ............................................................................ Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is owned
by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Financial Alternatives owned and managed
by Erik J. Peterson, Aaron D. Bessonette and Timothy K. Kadlec. Mr. Peterson, Mr. Bessonette
and Mr. Kadlec are Investment Advisor Representatives associated with CSP and offer investment
advisory services exclusively through CSP and only utilize Financial Alternatives for marketing
purposes. Financial Alternatives is not a registered investment advisor and is not affiliated with
CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Fee:
On assets $0.00 to $1,000,000.00
1.5%
On assets $1,000,000.00 to $2,000,000.00 1.25%
On assets over $2,000,000.00
1.0%
Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
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traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
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Certain associated persons of CSP are dually registered (“Dually Registered Persons”) as
registered representatives and/or investment advisor representatives of Planmember Securities,
Corporation (“Planmember Securities”), a registered investment advisor and independent broker-
dealer firm and Member of the Financial Industry Regulatory Authority (“FINRA”) and the
Securities Investor Protection Corporation (“SIPC”). Therefore, it is possible for clients to have
both fee-based advisory accounts through CSP and commission-based accounts through our
Dually Registered Persons via their registration with Planmember Securities. In these
circumstances, our Dually Registered Persons may receive fees and commissions for the sales of
certain securities products, typically variable annuities, to clients. However, in no instance will a
client pay commissions in addition to advisory fees in any single account. The dual registration of
our financial professionals inherently represents a conflict of interest, insofar as such individuals
could recommend a fee-based (advisory) account over a commission-based (brokerage) account,
or vice-versa, based on the potential level of compensation to be received.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
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follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
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involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
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understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
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United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
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• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. The firm has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital
Management, Inc. (“PCM”). PCM and CSP are under common control of Christopher K.
Hicks who is considered a control person of each firm because he holds more than 25%
ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliations:
As noted in Item 5 above, certain Advisory Affiliates of CSP are Dually Registered Persons with
Planmember Securities Corporation (“Planmember Securities”), a broker-dealer firm and Member
FINRA/SIPC. Planmember Securities is independent of and unaffiliated with CSP. In their
separate capacity as registered representatives, these Advisor Affiliates will typically receive
commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Advisory Affiliates of
CSP.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
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and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third-Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (315) 732-2701. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases, we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
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As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Financial Alternatives
shall not buy or sell securities for his personal portfolio where his decision is
substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP or Financial Alternatives shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
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•
•
•
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
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Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
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all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case-by-case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP or any of its principals, nor Financial Alternatives or any of its principals, have been
the subject of a bankruptcy petition at any time in the past. We have no financial conditions that
would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 10, 2025. Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (509) 663-7526 or
epeterson@finaltllc.com . Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA FINANCIAL ALTERNATIVES (WENATCHEE) (2026-04-30)
View Document Text
CS Planning Corp dba Financial Alternatives
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA FINANCIAL ALTERNATIVES
667 Grant Road, Suite 1
East Wenatchee, WA 98802
(509) 663-7526
https://www.finaltllc.com/
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (509)
663-7526 or epeterson@finaltllc.com to obtain answers and additional information. CS Planning
Corp is a registered investment adviser with the United States Securities and Exchange
Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or
training. The information in this Brochure has not been approved or verified by the SEC or by any
state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further
provide other ongoing disclosure information about material changes as necessary and will further
provide you with a new Brochure as necessary based on changes or new information, at any time,
without charge.
Currently, our Brochure may be requested by contacting us at (509) 663-7526 or
epeterson@finaltllc.com . Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ............................................................................ Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is owned
by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Financial Alternatives owned and managed
by Erik J. Peterson, Aaron D. Bessonette and Timothy K. Kadlec. Mr. Peterson, Mr. Bessonette
and Mr. Kadlec are Investment Advisor Representatives associated with CSP and offer investment
advisory services exclusively through CSP and only utilize Financial Alternatives for marketing
purposes. Financial Alternatives is not a registered investment advisor and is not affiliated with
CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Fee:
On assets $0.00 to $1,000,000.00
1.5%
On assets $1,000,000.00 to $2,000,000.00 1.25%
On assets over $2,000,000.00
1.0%
Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
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traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
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Certain associated persons of CSP are dually registered (“Dually Registered Persons”) as
registered representatives and/or investment advisor representatives of Planmember Securities,
Corporation (“Planmember Securities”), a registered investment advisor and independent broker-
dealer firm and Member of the Financial Industry Regulatory Authority (“FINRA”) and the
Securities Investor Protection Corporation (“SIPC”). Therefore, it is possible for clients to have
both fee-based advisory accounts through CSP and commission-based accounts through our
Dually Registered Persons via their registration with Planmember Securities. In these
circumstances, our Dually Registered Persons may receive fees and commissions for the sales of
certain securities products, typically variable annuities, to clients. However, in no instance will a
client pay commissions in addition to advisory fees in any single account. The dual registration of
our financial professionals inherently represents a conflict of interest, insofar as such individuals
could recommend a fee-based (advisory) account over a commission-based (brokerage) account,
or vice-versa, based on the potential level of compensation to be received.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
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follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
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involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
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understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
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United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
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• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. The firm has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital
Management, Inc. (“PCM”). PCM and CSP are under common control of Christopher K.
Hicks who is considered a control person of each firm because he holds more than 25%
ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliations:
As noted in Item 5 above, certain Advisory Affiliates of CSP are Dually Registered Persons with
Planmember Securities Corporation (“Planmember Securities”), a broker-dealer firm and Member
FINRA/SIPC. Planmember Securities is independent of and unaffiliated with CSP. In their
separate capacity as registered representatives, these Advisor Affiliates will typically receive
commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Advisory Affiliates of
CSP.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
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and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third-Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (315) 732-2701. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases, we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
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As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Financial Alternatives
shall not buy or sell securities for his personal portfolio where his decision is
substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP or Financial Alternatives shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
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•
•
•
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
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Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
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all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case-by-case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP or any of its principals, nor Financial Alternatives or any of its principals, have been
the subject of a bankruptcy petition at any time in the past. We have no financial conditions that
would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 10, 2025. Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (509) 663-7526 or
epeterson@finaltllc.com . Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA MERIDAN WEALTH ALLIANCE - ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Meridian Wealth Alliance
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA MERIDIAN WEALTH ALLIANCE
302 Saunders Road, Suite 200
Riverwoods, Illinois 60015
(773) 425-3675
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Meridian Wealth Alliance. If you have any questions about the contents of this Brochure
or to obtain answers and additional information, you may contact us at (773) 425-3675 or
bob@meridianwealthalliance.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will be included as “Exhibit A” to this Brochure and
will be available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for CS Planning Corp. is 149937. We may further provide other ongoing disclosure
information about material changes as necessary and will further provide you with a new Brochure
as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (773) 425-3675 or
bob@meridianwealthalliance.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 5
Item 7 – Types of Clients ................................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 6
Item 9 – Disciplinary Information ................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 10
Item 12 – Brokerage Practices ..................................................................................................................... 11
Item 13 – Review of Accounts ..................................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .............................................................................. 13
Item 15 – Custody ........................................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................................. 14
Item 17 – Voting Client Securities .............................................................................................................. 14
Item 18 – Financial Information .................................................................................................................. 15
Exhibit A – Summary of Material Changes ................................................................................................ 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Pillars of Success LLC, an Illinois limited
liability company doing business as Meridian Wealth Alliance, managed by Robert W. Burns. Mr.
Burns is an Investment Advisor Representative associated with CSP, offers investment advisory
services exclusively through CSP, and only utilizes Meridian Wealth Alliance for marketing
purposes. Meridian Wealth Alliance is not a registered investment advisor and is not affiliated
with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedule below:
Maximum Annual Wealth Management Retainer Fees: 1.5% of total market value of accounts per
household, depending upon the size and composition of a Client’s portfolio, and the type and
amount of services rendered.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and
complexity of the project. Our maximum hourly rate is $250 per hour. Consulting or financial
planning services Prior to commencing planning services, Clients enter into a Consulting or
Financial Planning Agreement which sets forth the services being provided and the fees being
charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
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Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
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commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
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give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
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involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
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Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
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Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
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Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Meridian Wealth Alliance Principal, Robert W. Burns, has never been subject to any legal or
disciplinary proceedings which would be considered material (or otherwise) to a Client’s
evaluation of him or any of the services he provides. Pillars of Success LLC dba Meridian Wealth
Alliance is an Illinois limited liability company owned by Robert W. Burns. Mr. Burns is an
Investment Advisor Representative registered with CSP effective December 2024.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
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Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (858) 243-2269. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
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included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Meridian Wealth
Alliance shall not buy or sell securities for his personal portfolio where his decision
is substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP and Meridian Wealth Alliance shall prefer his or her
own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
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•
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
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More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
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Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they have
any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior approval.
However, CSP will still have complete discretion to implement its trading strategies to update the
portfolio allocation within that stated investment strategy, without the Client’s prior approval. In
this type of situation, CSP will require authorization from the Client before making any changes
to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
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We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP nor any of the principals have been the subject of a bankruptcy petition at any time
in the past. We have no financial conditions that would impair our ability to meet contractual
commitments to our Clients.
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Exhibit A – Summary of Material Changes
This item discusses only specific material changes that have been made to our Brochure since our
prior version dated April 1, 2025. Since that date, we have made the following material changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is #149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
requested by
contacting us
at
(773) 425-3675 or
Our Brochure may be
bob@meridianwealthalliance.com.
Exh. A
Additional Brochure: CS PLANNING CORP DBA RENEE REKSC & ASSOCIATES ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Renee Reksc & Associates
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA RENEE REKSC & ASSOCIATES
1249 Upper Front Street, Suite 107
Binghamton, New York 13905
(607) 238-7155
April 27, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Renee Reksc & Associates. If you have any questions about the contents of this Brochure
or to obtain answers and additional information, you may contact us at (607) 238-7155 or
Renee@rekscgroup.com. CS Planning Corp is a registered investment adviser with the United
States Securities and Exchange Commission (“SEC”). Registration of an investment adviser does
not imply any level of skill or training. The information in this Brochure has not been approved
or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will be included as “Exhibit A” to this Brochure and
will be available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for CS Planning Corp. is 149937. We may further provide other ongoing disclosure
information about material changes as necessary and will further provide you with a new Brochure
as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (607) 238-7155 or
Renee@rekscgroup.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 15
Item 18 – Financial Information ................................................................................................... 15
Exhibit A – Summary of Material Changes .................................................................................... 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Renee Reksc & Associates LLC, a New
York limited liability company doing business as Renee Reksc & Associates, managed by Renee
R. Reksc. Renee R. Reksc is an Investment Advisor Representative associated with CSP, offers
investment advisory services exclusively through CSP, and only utilizes Renee Reksc &
Associates for marketing purposes. Renee Reksc & Associates LLC is not a registered investment
advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedule below:
Maximum 1.3% Annual Wealth Management Retainer Fee on client assets under management.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and
complexity of the project. Our maximum hourly rate is $250 per hour. Consulting or financial
planning services Prior to commencing planning services, Clients enter into a Consulting or
Financial Planning Agreement which sets forth the services being provided and the fees being
charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed monthly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
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Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
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Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
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Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
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such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
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not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
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or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Renee Reksc & Associates LLC Principal, Renee R. Reksc, has never been subject to any legal or
disciplinary proceedings which would be considered material (or otherwise) to a Client’s
evaluation of her or any of the services she provides. Renee Reksc & Associates LLC is a New
York limited liability company owned by Renee R. Reksc. Renee R. Reksc is an Investment
Advisor Representative registered with CSP effective May 30, 2025.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
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fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms
unaffiliated with CSP. In their separate capacity as registered representatives, these Advisor
Affiliates will typically receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Affiliates of CSP.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (607) 238-7155. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
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for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Renee Reksc &
Associates LLC shall not buy or sell securities for their personal portfolio where
their decision is substantially derived, in whole or in part, by reason of their
employment unless the information is also available to the investing public on
reasonable inquiry. No person associated with CSP and Renee Reksc & Associates
LLC shall prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
Price;
The custodian’s facilities, reliability and financial responsibility;
•
•
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•
•
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
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be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
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compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they have
any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
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Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Renee Reksc & Associates, LLC, have been the subject
of a bankruptcy petition at any time in the past. We have no financial conditions that would impair
our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This item discusses only specific material changes that have been made to our Brochure since our
prior annual amendment. Since our last Brochure filed May 30, 2025 we report the following
material changes:
•
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The
H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated
entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is #149937. The Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (607) 238-7155 or
Renee@rekscgroup.com. Our Brochure is provided free of charge.
Exh. A
Additional Brochure: CS PLANNING CORP DBA RICHARDSON WEALTH MANAGEMENT - FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Richardson Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA RICHARDSON WEALTH
MANAGEMENT
2450 Colorado Avenue, Suite 100
Santa Monica, CA 90404
Phone: (424) 422-8798
Walt@richardsonwealthmanagement.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (424)
422-8798 or Walt@richardsonwealthmanagement.com to obtain answers and additional
information. CS Planning Corp is a registered investment adviser with the United States Securities
and Exchange Commission (“SEC”). Registration of an investment adviser does not imply any
level of skill or training. The information in this Brochure has not been approved or verified by
the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (424) 422-8798 or
Walt@richardsonwealthmanagement.com. Our Brochure is provided free of charge.
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Part 2A of Form ADV – Brochure
Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 12
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ............................................................................. Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Richardson Wealth Management, LLC, a
California limited liability company (“Richardson Wealth Management”) owned and managed by
Walter Richardson. Mr. Richardson is an Investment Advisor Representative associated with CSP
and offers investment advisory services through CSP. Richardson Wealth Management is not
affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
Richardson Wealth Management offers investment advisory services that encompass a wide
range of investment objectives, from conservative to aggressive. This allows the client and us to
design a custom program and asset allocation that meets the client's specific needs. We provide
investment supervisory, financial planning and investment consulting services to Clients
primarily under the following fee schedules below:
Assets Under Management:
Annual Wealth Management Retainer Fee:
Maximum 1.3% on assets less than $500,000
Maximum 1.23% on assets $500,000 to $1,000,000
Maximum 1.15% on assets $1,000,000 to $1,500,000
Maximum 1.0% on assets $1,500,000 and up
Richardson Wealth Management does not offer financial planning services on a stand-alone basis
in general. However, we offer financial planning advice with mutual agreement as part of the
investment management services at no additional charge. This will typically include planning
regarding the investment, management, taxes and use of financial resources based upon an
assessment of a client’s individual situation and goals. We do not provide legal or accounting
services and do not prepare legal documents or tax returns.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and
complexity of the project. Our maximum hourly rate is $200.00 per hour. Prior to commencing
planning services, Clients enter into a Consulting or Financial Planning Agreement which sets
forth the services being provided and the fees being charged. Notwithstanding the above, fees are
generally negotiable.
Client’s asset management accounts are billed monthly in arrears. Fees are paid to us directly from
the client’s account by the custodian upon our submission of an invoice. Payment of fees may
result in the liquidation of Client’s securities if there is insufficient cash in the account. The fee is
based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
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The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
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CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
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follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
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involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed-end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
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understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
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United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
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• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital
Management, Inc. (“PCM”). PCM and CSP are under common control of Christopher K.
Hicks who is considered a control person of each firm because he holds more than 25%
ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms
unaffiliated with CSP. In their separate capacity as registered representatives, these Advisor
Affiliates will typically receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Affiliates of CSP.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
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Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (424) 422-8798 or
Walt@richardsonwealthmanagement.com. Brochures are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases, we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
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•
A director, officer, associated person, or employee of CSP or Richardson Wealth
Management shall not buy or sell securities for his personal portfolio where his
decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable
inquiry. No person associated with CSP or Richardson Wealth Management shall
prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
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•
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
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As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
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Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP nor any of its principals, nor Richardson Wealth Management, LLC or any of its
principals, have been the subject of a bankruptcy petition at any time in the past. We have no
financial conditions that would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
last annual amendment dated March 4, 2025. Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H Group
Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of CSP under
the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and
will further provide you with a new Brochure as necessary based on changes or new information,
at any time, without charge.
Currently, our Brochure may be requested by contacting us at (424) 422-8798 or
Walt@richardsonwealthmanagement.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA TAO PRIVATE WEALTH ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Tao Private Wealth
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA TAO PRIVATE WEALTH
1316 E. 35th Place, Suite 200
Tulsa, Oklahoma 74105
(918) 986-7282
Justin.hart@tao-pw.com
www.taoprivatewealth.com
April 29, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Tao Private Wealth. If you have any questions about the contents of this Brochure, you
may contact us at (918) 986-7282 or to obtain answers and additional information. CS Planning
Corp is a registered investment adviser with the United States Securities and Exchange
Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or
training. The information in this Brochure has not been approved or verified by the SEC or by any
state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (918) 986-7282. Our Brochure is
provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 4
Item 5 – Fees and Compensation .................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 8
Item 7 – Types of Clients ................................................................................................................ 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 8
Item 9 – Disciplinary Information ................................................................................................ 12
Item 10 – Other Financial Industry Activities and Affiliations .................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 13
Item 12 – Brokerage Practices ...................................................................................................... 14
Item 13 – Review of Accounts ...................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .................................................................... 15
Item 15 – Custody ......................................................................................................................... 16
Item 16 – Investment Discretion ................................................................................................... 16
Item 17 – Voting Client Securities................................................................................................ 17
Item 18 – Financial Information ................................................................................................... 17
Exhibit A – Summary of Material Changes .................................................................................... 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Tao Private Wealth. Tao Private Wealth,
LLC (“TPW”) is an Oklahoma limited liability company solely owed by Justin A. Hart, who is an
investment advisor representative (“IAR”) associated with CSP. Mr. Hart offers investment
advisory services exclusively through CSP and only utilizes TPW for marketing purposes. Tao
TPW is not a registered investment advisor and is not affiliated with CSP. Our investment
approach utilizes broadly diversified portfolios and a systematic strategy to manage client
portfolios.
Through our Advisory Affiliates, we help Clients coordinate and prioritize their financial lives
with all aspects of their life goals. Integrating investments across all individual retirement
accounts, taxable accounts, and employee retirement accounts is crucial to the process. Client
input and involvement are critical parts of the financial planning process and implementation of
investment decisions. After Client assets are invested, we continuously monitor their investments
and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include ETFs, mutual funds, exchange-listed equity securities,
certificates of deposit, municipal securities, U.S. government securities and money market funds
when suitable and appropriate for a Client’s particular situation. If Clients hold other types of
investments, we will advise them on those investments also. Clients may impose restrictions on
investing in certain securities or types of securities. We consider such restrictions when
formulating the Client’s investment strategy. See Item 8 for a description of our investment
strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory, financial planning, and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fees:
Above $1,000,000
Up to 0.95%
Less than $1,000,000
Up to 1.5%
The recommended minimum investment amount for establishing and maintaining an advisory
account is $1,000,000. This minimum is based on the aggregate amount of client accounts per
household. We may accept smaller accounts on a case-by-case basis.
Existing clients may be grandfathered into a different fee. Fees are generally negotiable.
We may also provide investment advice or financial planning to Clients on an hourly or fixed rate
fee. Our maximum hourly rate is $250.00 per hour depending on the complexity of the issue being
addressed. Fixed fee project pricing is quoted for each project, depending on the scope of work
performed. Notwithstanding the above, project fees are generally negotiable.
Client’s asset management accounts are billed monthly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior period.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
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be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. . Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange-
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in advance. All Wealth
Management agreements may be terminated by the Client at any time by providing us with written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by Client upon receipt of the invoice. We may estimate
the number of hours necessary to complete a project, and we may collect a portion of this estimate
up front and invoice the balance. Upon termination of any hourly or fixed fee project, any prepaid
but unearned fees will be promptly refunded to the Client.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
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Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
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trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to individuals, businesses, pension and profit sharing plans, trusts,
estates, and charitable organizations. Because each Client is unique, they must be willing to be
involved in the planning and ongoing processes. Such involvement does not have to be time
consuming, however we want our Clients to remain informed about their overall financial
situation.
The recommended minimum investment amount for establishing and maintaining an advisory
account is $1,000,000. This minimum is based on the aggregate amount of client accounts per
household. We may accept smaller accounts on a case-by-case basis.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments primarily including
mutual funds. However, we may also utilize other investments such as: exchange-traded funds,
closed-end funds, equity securities, debt securities, certificates of deposit, municipal securities,
U.S. government securities, and money market funds when suitable and appropriate. In limited
circumstances, and only when suitable and appropriate, we may offer advice on digital assets and
cryptocurrency. Each type of security has its own unique set of risks associated with it, and it
would not be possible to disclose all of the specific risks of every type of investment in this
brochure. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
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Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund's investments in accordance with the fund's investment objective. While mutual
funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day-to-
day fluctuations associated with any exchange-traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short-term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
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Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
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consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Technical analysis
Technical analysis is a method of evaluating securities that involves a statistical analysis of market
activity, such as price and volume. Technical analysts do not attempt to measure a
security’s intrinsic value, but rather, use charts and other tools to identify patterns that can be used
as a basis for investment decisions.
There are many different forms of technical analysis: Some rely on chart patterns, others use
technical indicators and oscillators, and most use a combination of techniques. In any case,
technical analysts’ exclusive use of historical price and volume data is what separates them from
their fundamental counterparts. Unlike fundamental analysts, technical analysts don’t concern
themselves with a stock’s valuation – the only thing that matters are past trading data and what
information the data might provide about future price movements.
Technical analysis is based on three assumptions:
1. The market discounts everything.
2. Price moves in trends.
3. History tends to repeat itself.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
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It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Advisor Affiliate principal, Justin Hart, has never been subject to any legal or disciplinary
proceedings which would be considered material (or otherwise) to a client’s evaluation of him or
any of the services he provides through his affiliate with CSP. Our investment advisory services
are coordinated through Tao Private Wealth. Tao Private Wealth, LLC is an Oklahoma limited
liability company solely owned by Justin A. Hart, who is an investment advisor representative
(“IAR”) associated with CSP, effective October 2017.
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently
licensed as insurance agents with other agencies. Affiliates may recommend the purchase
and sale of certain insurance products to Clients. As a fiduciary, the Affiliate must act
primarily for the benefit of CSP Clients and will only transact insurance related business
with Clients when the products are fully disclosed, suitable, and appropriate to fit their
needs, and in order to simplify the implementation of various wealth management
strategies.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms
unaffiliated with CSP. In their separate capacity as registered representatives, these
Advisor Affiliates will typically receive commissions for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement
any recommendation provided by Advisory Affiliates of CSP.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
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Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (918) 986-7282. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
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•
A director, officer, associated person, or employee of CSP or TPW shall not buy or
sell securities for his personal portfolio where his decision is substantially derived,
in whole or in part, by reason of his employment unless the information is also
available to the investing public on reasonable inquiry. No person of CSP or TPW
shall prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
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•
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. However additional review or reports will not
typically be provided unless otherwise provided for under the terms of the engagement. Consulting
Services Clients will not typically receive reports or formal reviews due to the nature of the service.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
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Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. Otherwise, we do not
otherwise have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
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account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case-by-case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, have been the subject of a bankruptcy petition at any time
in the past. We have no financial conditions that would impair our ability to meet contractual
commitments to our Clients.
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Exhibit A – Summary of Material Changes
The most recent annual amendment filing of this Brochure for CS Planning Corp dba Tao Private
Wealth was made on April 10, 2025. Since that filing, we have made the following material
changes:
Item 10 has been updated to indicate that Advisory Affiliates of CSP may also be
independently licensed as insurance agents with other agencies, that certain
Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms
unaffiliated with CSP, and that CSP may enter into promoter agreements with
individuals or other registered investment advisors.
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. We may further provide other ongoing disclosure information about material changes
as necessary and will further provide you with a new Brochure as necessary based on changes or
new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (918) 986-7282. Our Brochure is
provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA TECHNICAL MNGT GP - FORM ADV 2A (2026-04-30)
View Document Text
CS PLANNING CORP DBA TECHNICAL MNGT GP
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA TECHNICAL MNGT GP
3106 Edgewood Drive SE
Jefferson, OR 97352
(971) 218-4053
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba TECHNICAL MNGT GP. If you have any questions about the contents of this Brochure,
you may contact us at (971) 218-4053 or to obtain answers and additional information. CS Planning
Corp is a registered investment adviser with the United States Securities and Exchange Commission
(“SEC”). Registration of an investment adviser does not imply any level of skill or training. The
information in this Brochure has not been approved or verified by the SEC or by any state securities
authority.
information about CS Planning Corp.
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Part 2A of Form ADV – Brochure
Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (971) 218-4053. Our Brochure is
provided free of charge.
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Part 2A of Form ADV – Brochure
Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................... i
Item 2 – Material Changes ................................................................................................................................ ii
Item 3 – Table of Contents ............................................................................................................................. iii
Item 4 – Advisory Business .............................................................................................................................. 4
Item 5 – Fees and Compensation .................................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 8
Item 7 – Types of Clients ................................................................................................................................. 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 8
Item 9 – Disciplinary Information ................................................................................................................ 11
Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 11
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ........... 12
Item 12 – Brokerage Practices ....................................................................................................................... 13
Item 13 – Review of Accounts ...................................................................................................................... 14
Item 14 – Client Referrals and Other Compensation .................................................................................. 14
Item 15 – Custody ........................................................................................................................................... 15
Item 16 – Investment Discretion .................................................................................................................. 15
Item 17 – Voting Client Securities .................................................................................................................. 16
Item 18 – Financial Information ................................................................................................................... 16
Exhibit A – Summary of Material Changes ................................................................................................... 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland, Oregon.
We provide fee-only investment supervisory, portfolio management, investment consulting and
financial planning services. The firm has been in business since 2009. CSP is owned by Christopher
K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are used
for marketing purposes and may appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the Advisory Affiliate and not of our firm,
CSP, and the advisory services of the Advisory Affiliate are provided through our firm, CSP. CSP has
the arrangement described above with TECHNICAL MNGT GP, LLC. TECHNICAL MNGT GP, LLC
is an Oregon limited liability company solely owned by Steven Beranek who is an investment advisor
representative (“IAR”) associated with CSP. Mr. Beranek offers investment advisory services
exclusively through CSP and only utilizes TECHNICAL MNGT GP for marketing purposes.
TECHNICAL MNGT GP is not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to manage
client portfolios. Through our Advisory Affiliates, we help Clients coordinate and prioritize their
financial lives with all aspects of their life goals. Integrating investments across all individual
retirement accounts, taxable accounts, and employee retirement accounts is crucial to the process.
Client input and involvement are critical parts of the financial planning process and implementation
of investment decisions. After Client assets are invested, we continuously monitor their investments
and provide advice related to ongoing financial and investment needs.
We offer initial financial planning services to Clients under a separate Financial Planning Agreement.
After completion of an initial financial planning engagement, Clients may elect to enter into a retainer
agreement for ongoing Wealth Management services which include financial planning and portfolio
management.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory Affiliates
meet with Clients as needed to review portfolio performance, discuss current issues, and re-assess
goals and plans.
Our investment recommendations include ETFs, mutual funds, exchange-listed equity securities,
certificates of deposit, municipal securities, U.S. government securities and money market funds when
suitable and appropriate for a Client’s particular situation. If Clients hold other types of investments,
we will advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client assets
on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to Clients
primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fees:
1%
Existing clients may be grandfathered into a different fee.
We may also provide investment advice or financial planning to Clients on an hourly or fixed rate fee.
Our maximum hourly rate is $250.00 per hour depending on the complexity of the issue being
addressed. Fixed fee project pricing is quoted for each project, depending on the scope of work
performed. Notwithstanding the above, project fees are generally negotiable.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly from
the client’s account by the custodian upon our submission of an invoice. Payment of fees may result
in the liquidation of Client’s securities if there is insufficient cash in the account. The fee is based on
the market value of the Client’s account on the last trading day of the prior period.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded on a
market for which actual transaction prices are publicly reported are generally valued at the last reported
sale price on the principal market in which they are traded. Mutual Funds are only valued once per
day after the close of the market. Whenever valuation information for specific, illiquid, foreign, private
or other investments is not available through the custodian, our approach will be to value at zero. We
do this in order to not overvalue a position which could potentially over inflate billing calculations.
Alternatively, we may also seek to obtain and document price information from at least one
independent source, whether it be a broker-dealer, bank, pricing service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of the
account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated based
on the number of days the account was open during the quarter. Quarterly fee adjustments for
additional assets received into an account during a quarter or for partial withdrawals may also be
provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30 days
written notice in advance.
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Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Client may be charged up to $35.00 by us as an administrative fee for Client-directed trades.
Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g. wire
fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange traded funds
have additional internal expenses which generally include a fund management fee, other fund
expenses, and a possible distribution fee. In addition, some funds charge a redemption fee on shares
bought and sold within a short period. Funds describe their expenses in their prospectuses, summary
prospectuses, or product descriptions. Clients are advised that these fees are separate and additional
expenses incurred by the Client. See Item 12 for additional information on Brokerage Practices.
Our fees include the time necessary to work with Client's attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as assisting
those advisors in implementation of all appropriate documents. However, we are not responsible for
attorney, accountant or other third party professional fees charged to Client as a result of these
activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more fully
disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written notice.
Upon termination, any fees that have been earned by us but not yet paid will be immediately due and
payable. Clients are also responsible for all applicable charges including, but not limited to, account
administrative fees, account closure fees and all trading costs due to the termination, including any
fees the mutual funds may assess. Upon request, we will provide a good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are generally
invoiced by us with payment due by Client upon receipt of the invoice. We may estimate the number
of hours necessary to complete a project, and we may collect a portion of this estimate up front and
invoice the balance. Upon termination of any hourly or fixed fee project, any prepaid but unearned
fees will be promptly refunded to the Client.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or agency
and is not otherwise affiliated with any insurance brokerages or agencies.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan
Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA,
or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also
recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts,
and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover
recommendations we are acting as fiduciaries within the meaning of Title I of the Employee
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Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover to
you (i.e., receipt of additional fee-based compensation). You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest,
when we make rollover recommendations, we operate under a special rule that requires us to act in
your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire or
change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1.
Under this approach, our role will be limited only to providing you with general educational materials
regarding the pros and cons of rollover transactions. We will make no recommendation to you
regarding the prospective rollover of your assets and you are advised to speak with your trusted tax
and legal advisors with respect to rollover decisions. As part of this educational approach, we may
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provide you with materials discussing some or all of the following topics: the general pros and cons
of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement
withdrawals on retirement income; the investment options available inside your Plan Account; and
high level discussion of general investment concepts (e.g., risk versus return, the benefits of
diversification and asset allocation, historical returns of certain asset classes, etc.). We may also
provide you with questionnaires and/or interactive investment materials that may provide a means
for you to independently determine your future retirement income needs and to assess the impact of
different asset allocations on your retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side management.
Item 7 – Types of Clients
We provide investment advice to individuals, businesses, pension and profit sharing plans, trusts,
estates, and charitable organizations. Because each Client is unique, they must be willing to be
involved in the planning and ongoing processes. Such involvement does not have to be time
consuming, however we want our Clients to remain informed about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets, combined
with periodic rebalancing. Our Advisory Affiliates create an investment strategy with each Client,
outlining the investment philosophy, management procedures, and long-term goals for the investor.
Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments primarily including ETFs.
However, we may also utilize other investments such as: mutual funds, equity securities, debt
securities, certificates of deposit, municipal securities, U.S. government securities, and money market
funds when suitable and appropriate. In limited circumstances, and only when suitable and
appropriate, we may offer advice on digital assets and cryptocurrency. Each type of security has its
own unique set of risks associated with it, and it would not be possible to disclose all of the specific
risks of every type of investment in this brochure. If our Clients have any questions regarding the risks
associated with a particular investment, they are encouraged to contact us.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such
as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is,
perhaps, the most significant risk associated with ETFs. This risk is defined by the day to day
fluctuations associated with any exchange traded security, where fluctuations occur in part based on
the perception of investors.
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Mutual funds are professionally managed collective investment companies that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager that
trades the fund's investments in accordance with the fund's investment objective. While mutual funds
generally provide diversification, risks can be significantly increased if the fund is concentrated in a
particular sector of the market, primarily invests in small cap or speculative companies, uses leverage
(i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. Other fund risks include
foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk,
trading risk, and turnover risk that can increase fund expenses and may decrease fund performance.
Brokerage and transactions costs incurred by the fund will reduce returns.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in numerous
ways. Price fluctuations and market risk are the most significant risk concerns. As such, the value of
your investment can increase or decrease over time. Furthermore, you should understand that stock
prices can be affected by many factors including, but not limited to, the overall health of the economy,
the health of the market sector or industry of the issuing company, and national and political events.
When investing in stock, it is important to focus on the average returns achieved over a given period
of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but their risk
can also vary widely based on: the financial health of the issuer; the risk that the issuer might default;
when the bond is set to mature; and, whether or not the bond can be “called” prior to maturity. When
a bond is called, it may not be possible to replace it with a bond of equal character paying the same
rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time, generally
greater than one year. Sometimes we will employ a Short Term Purchase strategy where securities are
purchased with the expectation that they will be sold within a relatively short period of time, generally
less than one year, to take advantage of the securities’ short term price fluctuations. Short-term trading
(in general, selling securities within 30 days of purchasing the same securities) is not a fundamental
part of our overall investment strategy.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum, Litecoin,
and others (collectively, “Cryptocurrency”). Where exposure to this asset class is appropriate, we will
typically, if not exclusively, obtain such exposure through purchases and sales of ETFs and other
publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative than
an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike the
market valuations of publicly-traded stocks and bonds which can be objectively valued on the basis
of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and other
factors, prices of Cryptocurrency are based entirely on the market’s perception of value and are subject
to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an extremely high
level of price volatility, including “flash crashes,” and may lose significant value in a matter of minutes,
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hours, or days. It is not uncommon for the value of Cryptocurrency to move as much as twenty
percent (20%) or more in a single day. The ownership of particular Cryptocurrency is opaque and
therefore certain Cryptocurrency may be owned and controlled by relatively small number of
individuals, increasing the potential for fraud and market-manipulation such as pump-and-dump
schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is in
its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do not
create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of their
future viability as a store of value or a means of exchange. Federal, state, or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the United States is still developing.
Cryptocurrency is not legal tender in most jurisdictions, including the United States. No laws require
individuals or businesses to accept Cryptocurrency as a form of payment and Cryptocurrency does
not have any intrinsic value. Its value derives entirely from market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies. Cryptocurrency
exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or
malware. Due to relatively recent launches, most Cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, Cryptocurrency transactions are
irreversible, such that an improper transfer can only be reversed by the receiver of the cryptocurrency
agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would have
insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing economic,
demographic and social trends followed by a more focused analysis at the country level, then the
industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such as the
background and experience of the fund manager and/or the fund company (style, consistency, risk-
adjusted performance, management expenses, average daily trading volume, etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This strategy
would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
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Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should be
prepared to bear. We do not represent or guarantee that our services or methods of analysis can or
will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses
due to market corrections or declines. We cannot offer any guarantees or promises that your financial
goals and objectives will be met. Past performance is in no way an indication of future performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals and
Other Compensation”), below. We do not believe this arrangement creates any conflicts of interest
with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM) or
sub-advisors who provide customized investment portfolio management services. These services may
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include the construction of investment portfolios, execution of securities purchase and sale
transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-advisor
to execute a confidentiality agreement and not share non-public personal information with any
unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If applicable,
any additional fees will be fully disclosed to Clients in a separate agreement with the TPAM or sub-
advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (971) 218-4053. Brochures are provided
free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their own
account that we buy and sell for Clients. When appropriate we will purchase or sell securities for
Clients before purchasing the same for our account or allowing representatives to purchase or sell the
same for their own account. However, we do allow the accounts of employees to be included in block
trading alongside the accounts of Clients. In some cases we or our representatives may buy or sell
securities for our own account for reasons not related to the strategies adopted for our Clients. Our
employees are required to follow the Code of Ethics when making trades for their own accounts in
securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed
to assure that the personal securities transactions will not interfere with decisions made in the best
interest of advisory Clients while at the same time, allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we will
disclose to our advisory Clients any material conflict of interest relating to us, our representatives, or
any of our employees which could reasonably be expected to impair the rendering of unbiased and
objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP shall not buy or sell
securities for his personal portfolio where his decision is substantially derived, in whole
or in part, by reason of his employment unless the information is also available to the
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investing public on reasonable inquiry. No person of CSP shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated with
its advisory practice who has access to advisory recommendations. An appropriate
officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to and
including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which the
Client directs the use of a particular custodian if we believe that this choice would hinder either our
fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and with
the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of such
services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined by us
before the trade is placed with the broker. When practical, Client trades in the same security will be
bunched in a single order (a “block”) in an effort to obtain best execution at the best security price
available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to underlying
accounts on a pro rata basis, adjusted as necessary to keep Client transaction costs to
a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades, an
average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average price.
Multiple blocks may be executed within a single day. However, only trades executed
within the block on the single day may be combined for purposes of calculating the
average price.
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It is expected that this trade aggregation and allocation policy will be applied consistently. However,
if application of this policy results in unfair or inequitable treatment to some or all of our Clients, we
may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which are
attributable to CSP occur, we shall take any steps necessary to put the Client in the position it should
have been as if the trade error never occurred. In the event we determine that a bona fide trade error
has occurred which is attributable to CSP, we will correct the trade error using funds from our error
account. Depending on the internal trade error policies and procedures of the particular custodian,
our error account may be debited if the correction results in a loss. Likewise, our error account may
be credited if the correction results in a gain. This situation creates a conflict of interest as CSP has
an incentive to recommend particular custodians over others that may not have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of each
Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a particular
Client’s account. The Advisory Affiliate assigned to a particular Client’s account will be responsible
for the periodic reviews to that account. Clients will be provided the Supplemental Brochure (Form
ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; or
changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their accounts
generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates may also
provide Clients with periodic written reports summarizing the account activity and performance.
Along with these reports, we discuss the asset allocation of the portfolio compared to the portfolio
target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless otherwise
agreed at the start of the engagement. However additional review or reports will not typically be
provided unless otherwise provided for under the terms of the engagement. Consulting Services
Clients will not typically receive reports or formal reviews due to the nature of the service.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with these
conflicts are described in detail under Item 12, above.
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Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash compensation
to third-party intermediaries in exchange for their promotion, referral, and endorsement of our
advisory services to prospective clients. The cash compensation paid to such promoters may take the
form of a retainer, a flat advertising fee, a fee per referral, and/or a percentage of the advisory fees we
collect from referred client accounts. These fees may be paid to the promoter on a one-time or
recurring basis. Unless otherwise explicitly disclosed in writing to the client, the cash compensation
paid to a promoter will be borne entirely by CSP and the Advisory Affiliate. Referred clients do not
pay any additional or increased advisory fees as a result of having been referred to our firm by a paid
third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940. Any
promoters engaged for this purpose will disclose to you at or reasonably prior to the time of their
referral or endorsement of CSP (i) that they will receive compensation from CSP as a result of their
endorsement of our firm; (ii) a description of the material terms of the compensation they will receive;
and (iii) a brief statement discussing the conflicts of interest arising out of the compensation
arrangement and/or the relationship between CSP and the third-party promoter. Clients referred to
our firm by a third-party promoter are encouraged to inquire with us if they have any questions about
the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. Otherwise, we do not
otherwise have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian or
any acts of the agents or employees of the custodian and whether or not the full amount or such loss
is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which
may be carried by the custodian. The Client understands that SIPC provides only limited protection
for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge all
Clients to carefully review statements from the custodian and compare these to any reports that we
may provide to you. Our reports may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary authority
to execute investment recommendations in accordance with an agreed upon investment strategy or
plan without the Client’s prior approval of each specific transaction. Under discretionary authority,
Client allows us to purchase and sell securities and instruments in their account(s), arrange for delivery
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and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the
Client in matters necessary or incidental to the handling of the account, including monitoring certain
assets. The only restrictions on this discretionary authority are those set by the Client on a case by case
basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine or
make changes to a Client’s stated investment strategy without the Client’s prior approval. However
CSP will still have complete discretion to implement its trading strategies to update the portfolio
allocation within that stated investment strategy, without the Client’s prior approval. In this type of
situation, CSP will require authorization from the Client before making any changes to a Client’s
investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether authority
is discretionary or non-discretionary. Further, we make it a practice to question Clients to determine
if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do not
provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf
of a Client, they will be sent directly to the Client who remains responsible to vote the proxy.
Item 18 – Financial Information
We do not require Wealth Management Retainer fees to be paid in advance. A portion of hourly rate
or fixed fee projects are generally required to be paid in advance, however under no circumstances
will we retain more than $1,200.00, more than six months in advance from any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to Clients.
Neither CSP, nor any of the principals, have been the subject of a bankruptcy petition at any time in
the past. We have no financial conditions that would impair our ability to meet contractual
commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to this Brochure for CS
PLANNING CORP dba TECHNICAL MNGT GP since our prior annual update dated April 10,
2025. Since that date, we have made the following material changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is #149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (971) 218-4053. Our Brochure is
provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA THE COLLINGWOOD GROUP (2026-04-30)
View Document Text
CS Planning Corp dba The Collingwood Group
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA THE COLLINGWOOD GROUP
16 Kellogg Road
New Hartford, New York 13413
(315) 732-2701
www.collingwoodgrp.com
April 27, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (315)
732-2701 or to obtain answers and additional information. CS Planning Corp is a registered
investment adviser with the United States Securities and Exchange Commission (“SEC”).
Registration of an investment adviser does not imply any level of skill or training. The information
in this Brochure has not been approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (315) 732-2701. Our Brochure is
provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 6
Item 7 – Types of Clients ................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ............................................................................. Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with The Collingwood Group, LLC
(“Collingwood Group”) owned and managed by David L. Armstrong and Charles W. Burmaster.
Mr. Armstrong and Mr. Burmaster are Investment Advisor Representatives associated with CSP
and offer investment advisory services exclusively through CSP and only utilize The Collingwood
Group for marketing purposes. The Collingwood Group is not a registered investment advisor and
is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
In addition to Wealth Management services, we offer initial financial planning services to Clients
under a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fee:
1.50% on assets under $250,000
1.40% on assets between $250,001 and $500,000
1.25% on assets between $500,001 and $1,000,000
1.15% on assets between $1,000,001 and $2,000,000
1.00% on assets between $2,00,001 and $5,000,000
.75% on assets in excess of $5,000,000
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate under a separate Consulting or Financial Planning Agreement. Our fixed fee pricing
is quoted for each project, and is based on the scope and complexity of the project. Our maximum
hourly rate is $250 per hour. Prior to commencing planning services, Clients enter into a
Consulting or Financial Planning Agreement which sets forth the services being provided and the
fees being charged. Notwithstanding the above, fees are generally negotiable.
Except for 401(k) plans, Client’s asset management accounts are billed quarterly in advance. Fees
are paid to us directly from the client’s account by the custodian upon our submission of an invoice.
Payment of fees may result in the liquidation of Client’s securities if there is insufficient cash in
the account. The fee is based on the market value of the Client’s account on the last trading day
of the prior quarter. For 401(k) plans that we manage we may bill quarterly in arrears based on
the specific Plan’s average daily balance during the previous quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
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Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
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conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Certain associated persons of CSP are dually registered (“Dually Registered Persons”) as
registered representatives of Purshe Kaplan Sterling Investments (“PKS”), an independent broker-
dealer firm and Member of the Financial Industry Regulatory Authority (“FINRA”) and the
Securities Investor Protection Corporation (“SIPC”). Therefore, it is possible for clients to have
both fee-based advisory accounts through CSP and commission-based accounts through our
Dually Registered Persons via their registration with PKS. In these circumstances, our Dually
Registered Persons may receive fees and commissions for the sales of certain securities products,
typically variable annuities, to clients. However, in no instance will a client pay commissions in
addition to advisory fees in any single account. The dual registration of our financial professionals
inherently represents a conflict of interest, insofar as such individuals could recommend a fee-
based (advisory) account over a commission-based (brokerage) account, or vice-versa, based on
the potential level of compensation to be received.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
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conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
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Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
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ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
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Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
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Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. The firm has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliations:
As noted in Item 5 above, certain Advisory Affiliates of CSP are Dually Registered Persons with
Purshe Kaplan Sterling Investments (“PKS”), a broker-dealer firm and Member FINRA/SIPC.
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PKS is independent of and unaffiliated with CSP. In their separate capacity as registered
representatives, these Advisor Affiliates will typically receive commissions for the implementation
of recommendations for commissionable transactions. Clients are not obligated to implement any
recommendation provided by Advisory Affiliates of CSP.
Promotor Relationships: We may enter into promoter agreements with individuals or other
registered investment advisors. Promoter arrangements and requirements are more fully described
in Item 14 (“Client Referrals and Other Compensation”), below. We do not believe this
arrangement creates any conflicts of interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third-Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (315) 732-2701. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
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In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or The Collingwood
Group shall not buy or sell securities for his personal portfolio where his decision
is substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP or The Collingwood Group shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
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•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
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Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
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which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
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We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP or any of its principals, nor The Collingwood Group or any of its principals, have
been the subject of a bankruptcy petition at any time in the past. We have no financial conditions
that would impair our ability to meet contractual commitments to our Clients.
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Part 2A of Form ADV – Brochure
Exhibit A – Summary of Material Changes
We have made the following material changes to this Brochure since our prior annual amendment
dated March 31, 2025:
Item 5 was amended to reflect that for 401(k) plans that we manage we may bill
quarterly in arrears based on the specific Plan’s average daily balance during the
previous quarter.
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (315) 732-2701. Our Brochure is
provided free of charge.
Ex. A
Additional Brochure: CS PLANNING CORP DBA VERTICAL ASCENT WEALTH MANAGEMENT FORM ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Vertical Ascent Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA VERTICAL ASCENT WEALTH MANAGEMENT
1455 NW Leary Way
Seattle, WA 98107-5290
www.vertwealth.com
Phone: (206) 929-3636
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Vertical Ascent Wealth Management. If you have any questions about the contents of
this Brochure or to obtain answers and additional information, you may contact us at (206) 929-
3636 or marc@vertwealth.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We have made the following material changes to this Brochure since the last annual amendment
dated April 1, 2025:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will be included as “Exhibit A” to this Brochure and
will be available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for CS Planning Corp. is 149937. We may further provide other ongoing disclosure
information about material changes as necessary and will further provide you with a new Brochure
as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (206) 929-3636 or
marc@vertwealth.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 6
Item 7 – Types of Clients ................................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 6
Item 9 – Disciplinary Information ................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 10
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 11
Item 12 – Brokerage Practices ..................................................................................................................... 12
Item 13 – Review of Accounts ..................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation .............................................................................. 13
Item 15 – Custody ........................................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................................. 14
Item 17 – Voting Client Securities .............................................................................................................. 15
Item 18 – Financial Information .................................................................................................................. 15
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Vertical Ascent Wealth Management, LLC,
a Washington limited liability company doing business as Vertical Ascent Wealth Management,
managed by Marc Michel Girardot. Mr. Girardot is an Investment Advisor Representative
associated with CSP, offers investment advisory services exclusively through CSP, and only
utilizes Vertical Ascent Wealth Management for marketing purposes. Vertical Ascent Wealth
Management is not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
In addition to Wealth Management services, we offer financial planning services to Clients under
a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
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We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client assets on
a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Investment Management Services AUM
Annual Fees (Breakpoint tiered billed
quarterly in advance)
$0.00
To
$ 1,500,000.00
1.50%
$ 1,500,000.01
To
$ 5,000,000.00
1.00%
$ 5,000,000.01
To
$10,000,000.00
0.90%
Above $10,000,000.00
Negotiable
Minimum fee: $15,000.00
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate under a separate Consulting or Financial Planning Agreement. Our fixed fee pricing
is quoted for each project, and is based on the scope and complexity of the project. Fixed fees
may be billed on a monthly, quarterly, or annual basis. Our maximum hourly rate is $450 per hour
for consulting or financial planning services. Prior to commencing planning services, Clients enter
into a Consulting or Financial Planning Agreement which sets forth the services being provided
and the fees being charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior period.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
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The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
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Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products, we do not know the actual dollar
amount of any commission payment to an Insurance Agent. Also, because CSP is neither a broker
dealer nor an insurance agency, we do not have the ability to rebate commissions received for the
sale of a product and cannot discount the price of a product to make up for any commission that
may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
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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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
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Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
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expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
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basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
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consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Vertical Ascent Wealth Management Principal, Marc Michel Girardot, has never been subject to
any legal or disciplinary proceedings which would be considered material (or otherwise) to a
Client’s evaluation of him or any of the services he provides. Vertical Ascent Wealth
Management, LLC is a Washington limited liability company owned by Marc Michel Girardot.
Mr. Girardot is an Investment Advisor Representative registered with CSP effective September
2021.
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Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Mr. Girardot is the founder and CEO of Saddlerock Assets, LLC, a Commercial Real Estate
Company. Mr. Girardot devotes 3-5 hours monthly to this business during securities trading hours.
Mr. Girardot’s real estate practice and services are separate and apart from Vertical Ascent Wealth
Management and CS Planning. Mr. Girardot’s work for Saddlerock Assets, LLC represents no
conflict of interest for the clients of Vertical Ascent Wealth Management and CS Planning.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
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applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (858) 243-2269. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Vertical Ascent
Wealth Management shall not buy or sell securities for his personal portfolio where
his decision is substantially derived, in whole or in part, by reason of his
employment unless the information is also available to the investing public on
reasonable inquiry. No person associated with CSP and Vertical Ascent Wealth
Management shall prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
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•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
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Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
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Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they have
any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
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strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Marc Michel Girardot, have been the subject of a
bankruptcy petition at any time in the past. We have no financial conditions that would impair our
ability to meet contractual commitments to our Clients.
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Additional Brochure: CS PLANNING CORP. DBA BRANDENBURG FINANCIAL SERVICES ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Brandenburg Financial Services
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA BRANDENBURG FINANCIAL SERVICES
203 Oakwind Court
Canton, Georgia 30114
(770) 202-6673
www.BrandenburgFS.com
April 27, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (770)
202-6673 or Hamilton@BrandenburgFS.com to obtain answers and additional information. CS
Planning Corp is a registered investment adviser with the United States Securities and Exchange
Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or
training. The information in this Brochure has not been approved or verified by the SEC or by any
state securities authority.
information about CS Planning Corp.
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
requested by contacting us at
(770) 202-6673 or
Currently, our Brochure may be
Hamilton@BrandenburgFS.com. Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................... i
Item 2 – Material Changes ................................................................................................................................ ii
Item 3 – Table of Contents ............................................................................................................................. iii
Item 4 – Advisory Business .............................................................................................................................. 1
Item 5 – Fees and Compensation .................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 5
Item 7 – Types of Clients ................................................................................................................................. 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 5
Item 9 – Disciplinary Information .................................................................................................................. 8
Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 8
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ............. 9
Item 12 – Brokerage Practices ....................................................................................................................... 10
Item 13 – Review of Accounts ...................................................................................................................... 11
Item 14 – Client Referrals and Other Compensation .................................................................................. 12
Item 15 – Custody ........................................................................................................................................... 13
Item 16 – Investment Discretion .................................................................................................................. 13
Item 17 – Voting Client Securities .................................................................................................................. 13
Item 18 – Financial Information ................................................................................................................... 14
Exhibit – A Summary of Material Changes ........................................................................................... Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland, Oregon.
We provide fee-only investment supervisory, portfolio management, investment consulting and
financial planning services. The firm has been in business since 2009. CSP is owned by Christopher
K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are used
for marketing purposes and may appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the Advisory Affiliate and not of our firm,
CSP, and the advisory services of the Advisory Affiliate are provided through our firm, CSP. CSP has
the arrangement described above with Brandenburg Financial Services, LLC, a Georgia limited liability
company (“Brandenburg Financial”) owned and managed by Hamilton D. Brandenburg. Mr.
Brandenburg is an Investment Advisor Representative associated with CSP and offers investment
advisory services exclusively through CSP and only utilizes Brandenburg Financial Services for
marketing purposes. Brandenburg Financial Services is not a registered investment advisor and is not
affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to manage
client portfolios. Through our Advisory Affiliates, we help Clients coordinate and prioritize their
financial lives with all aspects of their life goals. Integrating investments across all individual
retirement accounts, taxable accounts, and employee retirement accounts is crucial to the process.
Client input and involvement are critical parts of the financial planning process and implementation
of investment decisions. After Client assets are invested, we continuously monitor their investments
and provide advice related to ongoing financial and investment needs.
In addition to Wealth Management services, we offer initial financial planning services to Clients under
a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory Affiliates
meet with Clients as needed to review portfolio performance, discuss current issues, and re-assess
goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities, U.S.
government securities, and money market funds when suitable and appropriate for a Client’s particular
situation. If Clients hold other types of investments, we will advise them on those investments also.
Clients may impose restrictions on investing in certain securities or types of securities. We consider
such restrictions when formulating the Client’s investment strategy. See Item 8 for a description of
our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client assets
on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to Clients
primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fee:
1.5% on assets to $1,000,000
1.25% on assets $1,000,001 to $2,000,000
1.0% on assets over $2,000,000
We may also provide standalone consulting or financial planning services to Clients on a fixed fee or
hourly rate under a separate Consulting or Financial Planning Agreement. Our fixed fee pricing is
quoted for each project, and is based on the scope and complexity of the project. Our maximum
hourly rate is $250 per hour. Prior to commencing planning services, Clients enter into a Consulting
or Financial Planning Agreement which sets forth the services being provided and the fees being
charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed quarterly in advance. Fees are paid to us directly from
the client’s account by the custodian upon our submission of an invoice. Payment of fees may result
in the liquidation of Client’s securities if there is insufficient cash in the account. The fee is based on
the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded on a
market for which actual transaction prices are publicly reported are generally valued at the last reported
sale price on the principal market in which they are traded. Mutual Funds are only valued once per
day after the close of the market. Whenever valuation information for specific, illiquid, foreign, private
or other investments is not available through the custodian, our approach will be to value at zero. We
do this in order to not overvalue a position which could potentially over inflate billing calculations.
Alternatively, we may also seek to obtain and document price information from at least one
independent source, whether it be a broker-dealer, bank, pricing service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of the
account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated based
on the number of days the account was open during the quarter. Quarterly fee adjustments for
additional assets received into an account during a quarter or for partial withdrawals may also be
provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30 days
written notice in advance.
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Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g. wire
fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange traded funds
have additional internal expenses which generally include a fund management fee, other fund
expenses, and a possible distribution fee. In addition, some funds charge a redemption fee on shares
bought and sold within a short period. Funds describe their expenses in their prospectuses, summary
prospectuses, or product descriptions. Clients are advised that these fees are separate and additional
expenses incurred by the Client. See Item 12 for additional information on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as assisting
those advisors in implementation of all appropriate documents. However, we are not responsible for
attorney, accountant or other third party professional fees charged to Client as a result of these
activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more fully
disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written notice.
Upon termination, any fees that have been earned by us but not yet paid will be immediately due and
payable. Clients are also responsible for all applicable charges including, but not limited to, account
administrative fees, account closure fees and all trading costs due to the termination, including any
fees the mutual funds may assess. Upon request, we will provide a good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are generally
invoiced by us with payment due by the Client upon receipt of the invoice. We may estimate the
number of hours necessary to complete a project, and we may collect a portion of this estimate up
front and invoice the balance. Upon termination of any hourly or fixed fee project, any prepaid but
unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products through
various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or agency
and is not otherwise affiliated with any insurance brokerages or agencies. However, a conflict of
interest arises when insurance related business is transacted with advisory Clients because certain
individual Advisory Affiliates of CSP are independently licensed to sell insurance products through
various carriers. In their capacity as an Insurance Agent, they may receive commissions or other fees
from products sold to Clients. As such, Clients are advised that they are under no obligation to use
any individual associated with CSP for insurance products or services, and may use any insurance firm
or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance or
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other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the actual
dollar amount of any commission payment to an Insurance Agent or Registered Representative. Also,
because CSP is neither a broker dealer nor an insurance agency, we do not have the ability to rebate
commissions received for the sale of a product and cannot discount the price of a product to make
up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from your
employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan
Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA,
or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also
recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts,
and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover
recommendations we are acting as fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-
based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of
interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e.,
receipt of additional fee-based compensation). You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest,
when we make rollover recommendations, we operate under a special rule that requires us to act in
your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
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2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1.
Under this approach, our role will be limited only to providing you with general educational materials
regarding the pros and cons of rollover transactions. We will make no recommendation to you
regarding the prospective rollover of your assets and you are advised to speak with your trusted tax
and legal advisors with respect to rollover decisions. As part of this educational approach, we may
provide you with materials discussing some or all of the following topics: the general pros and cons
of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement
withdrawals on retirement income; the investment options available inside your Plan Account; and
high level discussion of general investment concepts (e.g., risk versus return, the benefits of
diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide
you with questionnaires and/or interactive investment materials that may provide a means for you to
independently determine your future retirement income needs and to assess the impact of different
asset allocations on your retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client is
unique, they must be willing to be involved in the planning and ongoing processes. Such involvement
does not have to be time consuming, however we want our Clients to remain informed about their
overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets, combined
with periodic rebalancing. Our Advisory Affiliates create an investment strategy with each Client,
outlining the investment philosophy, management procedures, and long-term goals for the investor.
Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal securities,
U.S. government securities and money market funds when suitable and appropriate. In limited
circumstances, and only when suitable and appropriate, we may offer advice on digital assets and
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cryptocurrency. Each type of security has its own unique set of risks associated with it, and it would
not be possible to disclose all of the specific risks of every type of investment in this brochure. In those
limited situations where it is suitable and appropriate to meet a particular Client’s needs, we may also
utilize margin to manage an account. Margin occurs when a client pays for part of a purchase and
borrows the rest from the brokerage firm that custodies the account. If our Clients have any questions
regarding the risks associated with a particular investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager that
trades the fund’s investments in accordance with the fund's investment objective. While mutual funds
generally provide diversification, risks can be significantly increased if the fund is concentrated in a
particular sector of the market, primarily invests in small cap or speculative companies, uses leverage
(i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. Other fund risks include
foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk,
trading risk, and turnover risk that can increase fund expenses and may decrease fund performance.
Brokerage and transactions costs incurred by the fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such
as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is,
perhaps, the most significant risk associated with ETFs. This risk is defined by the day to day
fluctuations associated with any exchange traded security, where fluctuations occur in part based on
the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in numerous
ways. Price fluctuations and market risk are the most significant risk concerns. As such, the value of
your investment can increase or decrease over time. Furthermore, you should understand that stock
prices can be affected by many factors including, but not limited to, the overall health of the economy,
the health of the market sector or industry of the issuing company, and national and political events.
When investing in stock, it is important to focus on the average returns achieved over a given period
of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but their risk
can also vary widely based on: the financial health of the issuer; the risk that the issuer might default;
when the bond is set to mature; and, whether or not the bond can be “called” prior to maturity. When
a bond is called, it may not be possible to replace it with a bond of equal character paying the same
rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time, generally
greater than one year. Sometimes we will employ a Short Term Purchase strategy where securities are
purchased with the expectation that they will be sold within a relatively short period of time, generally
less than one year, to take advantage of the securities’ short term price fluctuations. Short-term trading
(in general, selling securities within 30 days of purchasing the same securities) is not a fundamental
part of our overall investment strategy.
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In limited situations we may utilize put and call option strategies in order to mitigate market risk when
suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum, Litecoin,
and others (collectively, “Cryptocurrency”). Where exposure to this asset class is appropriate, we will
typically, if not exclusively, obtain such exposure through purchases and sales of ETFs and other
publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative than
an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike the
market valuations of publicly-traded stocks and bonds which can be objectively valued on the basis
of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and other
factors, prices of Cryptocurrency are based entirely on the market’s perception of value and are subject
to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an extremely high
level of price volatility, including “flash crashes,” and may lose significant value in a matter of minutes,
hours, or days. It is not uncommon for the value of Cryptocurrency to move as much as twenty
percent (20%) or more in a single day. The ownership of particular Cryptocurrency is opaque and
therefore certain Cryptocurrency may be owned and controlled by relatively small number of
individuals, increasing the potential for fraud and market-manipulation such as pump-and-dump
schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is in
its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do not
create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of their
future viability as a store of value or a means of exchange. Federal, state, or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the United States is still developing.
Cryptocurrency is not legal tender in most jurisdictions, including the United States. No laws require
individuals or businesses to accept Cryptocurrency as a form of payment and Cryptocurrency does
not have any intrinsic value. Its value derives entirely from market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies. Cryptocurrency
exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or
malware. Due to relatively recent launches, most Cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, Cryptocurrency transactions are
irreversible, such that an improper transfer can only be reversed by the receiver of the cryptocurrency
agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would have
insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment advice:
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Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing economic,
demographic and social trends followed by a more focused analysis at the country level, then the
industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such as the
background and experience of the fund manager and/or the fund company (style, consistency, risk-
adjusted performance, management expenses, average daily trading volume, etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This strategy
would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should be
prepared to bear. We do not represent or guarantee that our services or methods of analysis can or
will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses
due to market corrections or declines. We cannot offer any guarantees or promises that your financial
goals and objectives will be met. Past performance is in no way an indication of future performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
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PCM is an investment advisor registered with the Securities and Exchange Commission. PCM offers
investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of CSP
Clients and will only transact insurance related business with Clients when the products are fully
disclosed, suitable, and appropriate to fit their needs, and in order to simplify the implementation of
various wealth management strategies.
Hamilton Brandenburg provides tax preparation services for certain clients under the assumed
business name Brandenburg Tax Services, for a separate flat fee pursuant to a separate agreement.
Mr. Brandenburg devotes approximately 10 hours per week to this work during tax season. While this
business activity raises a potential conflict of interest, that is mitigated by Clients being informed that
they may be able to find similar services elsewhere.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms unaffiliated
with CSP. In their separate capacity as registered representatives, these Advisor Affiliates will typically
receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Advisory Affiliates of CSP.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals and
Other Compensation”), below. We do not believe this arrangement creates any conflicts of interest
with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM) or
sub-advisors who provide customized investment portfolio management services. These services may
include the construction of investment portfolios, execution of securities purchase and sale
transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However, we require any TPAM or sub-advisor
to execute a confidentiality agreement and not share non-public personal information with any
unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If applicable,
any additional fees will be fully disclosed to Clients in a separate agreement with the TPAM or sub-
advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
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upon
request by
contacting
us
at
(770)
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any Client
or prospective Client
202-6673 or
Hamilton@BrandenburgFS.com. Brochures are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their own
account that we buy and sell for Clients. When appropriate we will purchase or sell securities for
Clients before purchasing the same for our account or allowing representatives to purchase or sell the
same for their own account. However, we do allow the accounts of employees to be included in block
trading alongside the accounts of Clients. In some cases, we or our representatives may buy or sell
securities for our own account for reasons not related to the strategies adopted for our Clients. Our
employees are required to follow the Code of Ethics when making trades for their own accounts in
securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed
to assure that the personal securities transactions will not interfere with decisions made in the best
interest of advisory Clients while at the same time, allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we will
disclose to our advisory Clients any material conflict of interest relating to us, our representatives, or
any of our employees which could reasonably be expected to impair the rendering of unbiased and
objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Brandenburg Financial
Services shall not buy or sell securities for his personal portfolio where his decision is
substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No person
associated with CSP or Brandenburg Financial Services shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated with
its advisory practice who has access to advisory recommendations. An appropriate
officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to and
including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which the
Client directs the use of a particular custodian if we believe that this choice would hinder either our
fiduciary duty to the Client or our ability to service the account.
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In recommending custodians, we will comply with its fiduciary duty to seek best execution and with
the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of such
services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined by us
before the trade is placed with the broker. When practical, Client trades in the same security will be
bunched in a single order (a “block”) in an effort to obtain best execution at the best security price
available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to underlying
accounts on a pro rata basis, adjusted as necessary to keep Client transaction costs to
a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades, an
average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average price.
Multiple blocks may be executed within a single day. However, only trades executed
within the block on the single day may be combined for purposes of calculating the
average price.
It is expected that this trade aggregation and allocation policy will be applied consistently. However,
if application of this policy results in unfair or inequitable treatment to some or all of our Clients, we
may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which are
attributable to CSP occur, we shall take any steps necessary to put the Client in the position it should
have been as if the trade error never occurred. In the event we determine that a bona fide trade error
has occurred which is attributable to CSP, we will correct the trade error using funds from our error
account. Depending on the internal trade error policies and procedures of the particular custodian,
our error account may be debited if the correction results in a loss. Likewise, our error account may
be credited if the correction results in a gain. This situation creates a conflict of interest as CSP has
an incentive to recommend particular custodians over others that may not have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of each
Client's stated investment objectives and guidelines.
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We have a number of Advisory Affiliates who are assigned as the primary representative to a particular
Client’s account. The Advisory Affiliate assigned to a particular Client’s account will be responsible
for the periodic reviews to that account. Clients will be provided the Supplemental Brochure (Form
ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; or
changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their accounts
generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates may also
provide Clients with periodic written reports summarizing the account activity and performance.
Along with these reports, we discuss the asset allocation of the portfolio compared to the portfolio
target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless otherwise
agreed at the start of the engagement. Dependent upon the level and scope of Financial Planning
services being provided, Advisor Affiliates will meet with clients at least twice per year or more often
as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with these
conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell insurance.
The conflicts of interest these arrangements present and how we deal with these conflicts are described
in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash compensation
to third-party intermediaries in exchange for their promotion, referral, and endorsement of our
advisory services to prospective clients. The cash compensation paid to such promoters may take the
form of a retainer, a flat advertising fee, a fee per referral, and/or a percentage of the advisory fees we
collect from referred client accounts. These fees may be paid to the promoter on a one-time or
recurring basis. Unless otherwise explicitly disclosed in writing to the client, the cash compensation
paid to a promoter will be borne entirely by CSP and the Advisory Affiliate. Referred clients do not
pay any additional or increased advisory fees as a result of having been referred to our firm by a paid
third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940. Any
promoters engaged for this purpose will disclose to you at or reasonably prior to the time of their
referral or endorsement of CSP (i) that they will receive compensation from CSP as a result of their
endorsement of our firm; (ii) a description of the material terms of the compensation they will receive;
and (iii) a brief statement discussing the conflicts of interest arising out of the compensation
arrangement and/or the relationship between CSP and the third-party promoter. Clients referred to
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our firm by a third-party promoter are encouraged to inquire with us if they have any questions about
the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise have
custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian or
any acts of the agents or employees of the custodian and whether or not the full amount or such loss
is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which
may be carried by the custodian. The Client understands that SIPC provides only limited protection
for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge all
Clients to carefully review statements from the custodian and compare these to any reports that we
may provide to you. Our reports may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary authority
to execute investment recommendations in accordance with an agreed upon investment strategy or
plan without the Client’s prior approval of each specific transaction. Under discretionary authority,
Client allows us to purchase and sell securities and instruments in their account(s), arrange for delivery
and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the
Client in matters necessary or incidental to the handling of the account, including monitoring certain
assets. The only restrictions on this discretionary authority are those set by the Client on a case by case
basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine or
make changes to a Client’s stated investment strategy without the Client’s prior approval. However,
CSP will still have complete discretion to implement its trading strategies to update the portfolio
allocation within that stated investment strategy, without the Client’s prior approval. In this type of
situation, CSP will require authorization from the Client before making any changes to a Client’s
investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether authority
is discretionary or non-discretionary. Further, we make it a practice to question Clients to determine
if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do not
provide advice to Clients on how the Client should vote. Clients will receive proxies and other
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solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf
of a Client, they will be sent directly to the Client who remains responsible to vote the proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to Clients.
Neither CSP or any of its principals, nor Brandenburg Financial Services, LLC or any of its principals,
have been the subject of a bankruptcy petition at any time in the past. We have no financial conditions
that would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since
the prior annual amendment on April 28, 2025:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material
Changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal
year. When required, a Summary of Material Changes will also be included with our Brochure
on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for
CS Planning Corp. is 149937. Summary of Material Changes is listed as “Exhibit A” to our
Brochure. We may further provide other ongoing disclosure information about material
changes as necessary and will further provide you with a new Brochure as necessary based on
changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (770) 202-6673 or
Hamilton@BrandenburgFS.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CS PLANNING DBA CULTIVANT. FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Cultivant
Part 2A of Form ADV – Brochure
CS PLANNING CORP
DBA CULTIVANT
11400 SE 8th St, Suite 235
Bellevue, WA 98004
Phone: (206) 486-8700 Ext. 703
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Cultivant. If you have any questions about the contents of this Brochure, you may
contact us at (206) 486-8700 Ext. 703 or to obtain answers and additional information. CS
Planning Corp is a registered investment adviser with the United States Securities and Exchange
Commission (“SEC”). Registration of an investment adviser does not imply any level of skill or
training. The information in this Brochure has not been approved or verified by the SEC or by any
state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual amendment dated April 1, 2025. Since that date, we have made the following material
changes:
Item 5 was amended to reflect that for 401(k) plans that we manage we may bill
quarterly in arrears based on the specific Plan’s average daily balance during the
previous quarter.
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. We may further provide other ongoing disclosure information about material changes
as necessary and will further provide you with a new Brochure as necessary based on changes or
new information, at any time, without charge.
Currently, our Brochure may be requested, free of charge, by contacting us at (206) 486-8700 Ext.
703.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 5
Item 7 – Types of Clients ................................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 5
Item 9 – Disciplinary Information ................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 10
Item 12 – Brokerage Practices ..................................................................................................................... 11
Item 13 – Review of Accounts ..................................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .............................................................................. 12
Item 15 – Custody ........................................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................................. 13
Item 17 – Voting Client Securities .............................................................................................................. 14
Item 18 – Financial Information .................................................................................................................. 14
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our Advisory Affiliates. Advisory
Affiliates may have their own legal business entities whose trade names and logos are used for
marketing purposes and may appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the Advisory Affiliate and not of our
firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm, CSP.
CSP has the arrangement described above with Cultivant LLC, a Washington Limited Liability
Company owned by Hoon Kang, Christian Kang, and Wesley Kang (“Members”) in the state of
Washington. The Members are investment advisor representatives (“IARs”) associated with CSP,
offer investment advisory services exclusively through CSP, and utilize Cultivant for only
marketing purposes. Cultivant is not a registered investment advisor and is not affiliated with
CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include exchange-traded funds (ETFs) and mutual funds.
However, we may also recommend other investments such as exchange-listed equity securities,
certificates of deposit, municipal securities, U.S. government securities and money market funds
when suitable and appropriate for a Client’s particular situation. If Clients hold other types of
investments, we will advise them on those investments also. Clients may impose restrictions on
investing in certain securities or types of securities. We consider such restrictions when
formulating the Client’s investment strategy. See Item 8 for a description of our investment
strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory and investment consulting services, and incidental financial
advisory service to Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fee:
1.25% on assets to $500,000
1.00% on assets between $500,001 and $5,000,000
0.75% on assets between $5,000,001 and $10,000,000
0.50% on assets in excess of $10,000,000
Financial planning service beyond the scope of the incidental financial advisory service mentioned
above is billed separately on a fixed fee or hourly rate under a separate Financial Planning
Agreement. Our fixed fee pricing is quoted for each project, and is priced based on the scope and
complexity of the project. Our maximum hourly rate is $300 per hour. Notwithstanding the above,
fees are generally negotiable.
Except for 401(k) plans, Client’s asset management accounts are billed quarterly in arrears. Fees
are paid to us directly from the client’s account by the custodian upon our submission of an invoice.
Payment of fees may result in the liquidation of Client’s securities if there is insufficient cash in
the account. The fee is based on the market value of the Client’s account on the last trading day
of the quarter. For 401(k) plans that we manage we may bill quarterly in arrears based on the
specific Plan’s average daily balance during the previous quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
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Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange-
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Clients pay all Wealth Management Retainer fees quarterly in arrears. As such, there are never
any prepaid fees for Assets Under Management which would be subject to refund. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
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Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
products and CSP does not receive any compensation for products sold by these Advisory
Affiliates.
Because CSP is not involved in the sale of insurance, we do not know the actual dollar amount of
any commission payment to an Insurance Agent. Also, because CSP is not an insurance agency,
we do not have the ability to rebate commissions received for the sale of a product and cannot
discount the price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
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Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, and charitable organizations. Because each Client is
unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
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Types of Investments
As part of our core investment approach, we primarily utilize mutual funds and exchange traded
funds (ETFs). However, we may also utilize other investments such as: equity securities, debt
securities, certificates of deposit, municipal securities, U.S. government securities and money
market funds when suitable and appropriate. In limited circumstances, and only when suitable and
appropriate, we may offer advice on digital assets and cryptocurrency. Each type of security has
its own unique set of risks associated with it, and it would not be possible to disclose all of the
specific risks of every type of investment in this brochure. If our Clients have any questions
regarding the risks associated with a particular investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund's investments in accordance with the fund's investment objective. While mutual
funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day-to-
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As such,
the value of an investment can increase or decrease over time. Furthermore, stock prices can be
affected by many factors including, but not limited to, the overall health of the economy, the health
of the market sector or industry of the issuing company, and national and political events. When
investing in stock, it is important to focus on the average returns achieved over a given period of
time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
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Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short-term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
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Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
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Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
Cultivant’s management personnel are not registered or have any applications pending to register
as broker-dealers, registered representatives of a broker-dealer, future commission merchants,
commodity pool operators, commodity-trading advisors, or associated persons of the foregoing
entities.
Hoon Kang, Member of Cultivant LLC, is a Member of Elliott Bay Advisors LLC (previously
Elliott Bay Advisors). Elliott Bay Advisors LLC offers tax and accounting services for a separate
fee pursuant to a separate agreement. Services offered generally include tax preparation and filing,
tax planning, bookkeeping, and incidental business advisory services. We do not believe that
providing these services inherently creates a conflict of interests. Elliott Bay Advisors LLC is not
a CPA firm; as such, it does not offer audit or other attestation services.
The Members of Cultivant LLC are also members of Elliott Bay Insurance LLC, an insurance
agency. They are licensed life insurance agents appointed with multiple insurance carriers. In this
capacity, the Members may recommend the purchase and sale of certain insurance products to
Clients. The Members provide insurance services in order to simplify the implementation of
various wealth management strategies.
As fiduciaries the Members must act primarily for the benefit of CSP Clients. They will only
transact tax, accounting, and/or insurance related business with Clients when the products or
services are fully disclosed, suitable, and appropriate to fit their needs.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
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We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (206) 486-8700 Ext. 703. Brochures
are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP shall not buy or sell
securities for his personal portfolio where his decision is substantially derived, in
whole or in part, by reason of his employment unless the information is also
available to the investing public on reasonable inquiry. No person of CSP shall
prefer his or her own interest to that of the advisory Client.
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•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
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Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP are licensed may also be licensed
to sell insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail in those items.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
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to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
Other than having the ability to debit fees and disburse or transfer certain client funds pursuant to
Standing Letters of Authorization executed by Clients, we do not have custody of the assets in the
account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates continuous discretionary authority to
execute investment recommendations in accordance with an agreed upon investment strategy or
plan without the Client’s prior approval of each specific transaction. Under discretionary
authority, Client allows us to purchase and sell securities and instruments in their account(s),
arrange for delivery and payment in connection with the foregoing, select and retain sub-advisors,
and act on behalf of the Client in matters necessary or incidental to the handling of the account,
including monitoring certain assets. The only restrictions on this discretionary authority are those
set by the Client on a case-by-case basis.
We make it a practice to question Clients to determine if there are any limitations to our authority
on such matters.
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Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals or Advisory Affiliate and its members, Hoon Kang,
Christian Kang and Wesley Kang, have been the subject of a bankruptcy petition at any time in
the past. We have no financial conditions that would impair our ability to meet contractual
commitments to our Clients.
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Additional Brochure: CS PLANNING DBA MATTHEW FEVOLA WEALTH MANAGEMENT - FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Matt Fevola Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA MATT FEVOLA WEALTH
MANAGEMENT
2150 Route 35, Suite 250r
Sea Girt, NJ 08750
Phone: (732) 814-6208
Email: Matt@MattFevolaWealthManagement.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (732)
814-6208 or Matt@MattFevolaWealthManagement.com to obtain answers and additional
information. CS Planning Corp is a registered investment adviser with the United States Securities
and Exchange Commission (“SEC”). Registration of an investment adviser does not imply any
level of skill or training. The information in this Brochure has not been approved or verified by
the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (732) 814-6208 or
Matt@MattFevolaWealthManagement.com. Our Brochure is provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 5
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ...................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts ...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .................................................................... 12
Item 15 – Custody ......................................................................................................................... 13
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ................................................................................. Ex.
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Matt Fevola Wealth Management, owned
and managed by Matthew J. Fevola. Mr. Fevola is an Investment Advisor Representative
associated with CSP and offers investment advisory services through CSP. Matt Fevola Wealth
Management is not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guide us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
Matt Fevola Wealth Management offers investment advisory services under the following fee
schedule:
Assets Under Management:
Annual Wealth Management Retainer Fee:
Maximum 1.25% on all assets under management.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
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Our fees include the time necessary to work with Client’s attorney, accountant or other third-party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Certain associated persons of CSP are dually registered (“Dually Registered Persons”) as
registered representatives and/or investment advisor representatives of R.M. Stark & Co., Inc.
(“R.M. Stark”), a registered investment advisor and independent broker-dealer firm and Member
of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection
Corporation (“SIPC”). Therefore, it is possible for clients to have both fee-based advisory accounts
through CSP and commission-based accounts through our Dually Registered Persons via their
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registration with R.M. Stark. In these circumstances, our Dually Registered Persons may receive
fees and commissions for the sales of certain securities products, typically variable annuities, to
clients. However, in no instance will a client pay commissions in addition to advisory fees in any
single account. The dual registration of our financial professionals inherently represents a conflict
of interest, insofar as such individuals could recommend a fee-based (advisory) account over a
commission-based (brokerage) account, or vice-versa, based on the potential level of
compensation to be received.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a
“Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing
conflict of interest, when we make rollover recommendations, we operate under a special rule that
requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
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or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-
1. Under this approach, our role will be limited only to providing you with general educational
materials regarding the pros and cons of rollover transactions. We will make no recommendation
to you regarding the prospective rollover of your assets and you are advised to speak with your
trusted tax and legal advisors with respect to rollover decisions. As part of this educational
approach, we may provide you with materials discussing some or all of the following topics: the
general pros and cons of rollover transactions; the benefits of retirement plan participation; the
impact of pre-retirement withdrawals on retirement income; the investment options available
inside your Plan Account; and high level discussion of general investment concepts (e.g., risk
versus return, the benefits of diversification and asset allocation, historical returns of certain asset
classes, etc.). We may also provide you with questionnaires and/or interactive investment materials
that may provide a means for you to independently determine your future retirement income needs
and to assess the impact of different asset allocations on your retirement income. You will make
the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net-worth individuals, individuals, businesses, pension and
profit-sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
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each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund's investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
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Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
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Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
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• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital
Management, Inc. (“PCM”). PCM and CSP are under common control of Christopher K.
Hicks who is considered a control person of each firm because he holds more than 25%
ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliation
As noted in Item 5 above, certain Advisory Affiliates of CSP are Dually Registered Persons with
R.M. Stark & Co., Inc. a broker-dealer firm and Member FINRA/SIPC. R.M. Stark is independent
of and unaffiliated with CSP. In their separate capacity as registered representatives, these Advisor
Affiliates will typically receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Affiliates of CSP.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
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On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (732) 814-6208 or
Matt@MattFevolaWealthManagement.com. Brochures are provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
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•
A director, officer, associated person, or employee of CSP or Matt Fevola Wealth
Management shall not buy or sell securities for his personal portfolio where his
decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable
inquiry. No person associated with CSP or Matt Fevola Wealth Management shall
prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
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•
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
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As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
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Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP or any of its principals, nor Matt Fevola Wealth Management or any of its principals,
have been the subject of a bankruptcy petition at any time in the past. We have no financial
conditions that would impair our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 3, 2025 Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (732) 814-6208 or
Matt@MattFevolaWealthManagement.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CSP DBA CAELESTIBUS WEALTH MANAGEMENT - FORM ADV 2A (2026-04-30)
View Document Text
CS Planning Corp dba Caelestibus Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA CAELESTIBUS WEALTH MANAGEMENT
2801 Ocean Drive, Suite 300
Vero Beach, Florida 32963
Phone: (772) 879-4748
joseph@caelestibus.com
April 27, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Caelestibus Wealth Management. If you have any questions about the contents of this
Brochure or to obtain answers and additional information, you may contact us at (772) 879-4748
or joseph@caelestibus.com. CS Planning Corp is a registered investment adviser with the United
States Securities and Exchange Commission (“SEC”). Registration of an investment adviser does
not imply any level of skill or training. The information in this Brochure has not been approved
or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (772) 879-4748 or
joseph@caelestibus.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 4
Item 5 – Fees and Compensation .................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 8
Item 7 – Types of Clients ................................................................................................................ 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 9
Item 9 – Disciplinary Information ................................................................................................ 12
Item 10 – Other Financial Industry Activities and Affiliations .................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 13
Item 12 – Brokerage Practices ...................................................................................................... 14
Item 13 – Review of Accounts ...................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .................................................................... 16
Item 15 – Custody ......................................................................................................................... 17
Item 16 – Investment Discretion ................................................................................................... 17
Item 17 – Voting Client Securities................................................................................................ 17
Item 18 – Financial Information ................................................................................................... 18
Exhibit A – Summary of Material Changes .................................................................................... 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Caelestibus Wealth Management, Inc., a
Florida corporation doing business as Caelestibus Wealth Management, managed by Joseph
Gilewski. Mr. Gilewski is an Investment Advisor Representative associated with CSP, offers
investment advisory services exclusively through CSP, and only utilizes Caelestibus Wealth
Management for marketing purposes. Caelestibus Wealth Management is not a registered
investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
In addition to Wealth Management services, we offer financial planning services to Clients under
a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
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We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fees: 2% on all assets.
Existing clients may be grandfathered into a different fee.
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate under a separate Consulting or Financial Planning Agreement. Our fixed fee pricing
is quoted for each project, and is based on the scope and complexity of the project. Our maximum
hourly rate is $250 per hour. Prior to commencing planning services, Clients enter into a
Consulting or Financial Planning Agreement which sets forth the services being provided and the
fees being charged. Notwithstanding the above, fees are generally negotiable.
Except for 401(k) plans, Client’s asset management accounts are billed quarterly in arrears. Fees
are paid to us directly from the client’s account by the custodian upon our submission of an invoice.
Payment of fees may result in the liquidation of Client’s securities if there is insufficient cash in
the account. The fee is based on the market value of the Client’s account on the last trading day
of the prior quarter. For 401(k) plans that we manage we may bill quarterly in arrears based on
the specific Plan’s average daily balance during the previous quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
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Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
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CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
meet a professional standard of care when making investment recommendations (give
prudent advice);
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never put our financial interests ahead of yours when making recommendations (give
loyal advice);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
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Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed end funds equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
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such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
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Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
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their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. The firm has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm..
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
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CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (772) 879-4748. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
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for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Caelestibus Wealth
Management shall not buy or sell securities for his personal portfolio where his
decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable
inquiry. No person associated with CSP and Caelestibus Wealth Management shall
prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
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We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
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More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
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Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
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We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Joseph Gilewski, have been the subject of a bankruptcy
petition at any time in the past. We have no financial conditions that would impair our ability to
meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 10, 2025. Since that date, we have made the following material
changes:
Item 5 was amended to reflect that for 401(k) plans that we manage we may bill
quarterly in arrears based on the specific Plan’s average daily balance during the
previous quarter.
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is
#149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further
provide other ongoing disclosure information about material changes as necessary and will further
provide you with a new Brochure as necessary based on changes or new information, at any time,
without charge.
Currently, our Brochure may be requested by contacting us at (772) 879-4748 or
joseph@caelestibus.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CSP DBA COLLINGWOOD WEALTH MANAGEMENT ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Collingwood Wealth Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA COLLINGWOOD WEALTH MANAGEMENT
90 Canal Street, 4th Floor
Boston, MA 02114
(855) 357-2013
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. If you have any questions about the contents of this Brochure, you may contact us at (855)
357-2013 or to obtain answers and additional information. CS Planning Corp is a registered
investment adviser with the United States Securities and Exchange Commission (“SEC”). Registration
of an investment adviser does not imply any level of skill or training. The information in this Brochure
has not been approved or verified by the SEC or by any state securities authority.
information about CS Planning Corp.
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (855) 357-2013. Our Brochure is
provided free of charge.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ........................................................................................................... iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................... 5
Item 7 – Types of Clients ............................................................................................................... 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ......................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ........ 10
Item 12 – Brokerage Practices ...................................................................................................... 11
Item 13 – Review of Accounts...................................................................................................... 12
Item 14 – Client Referrals and Other Compensation ...................................................................... 12
Item 15 – Custody ........................................................................................................................ 13
Item 16 – Investment Discretion .................................................................................................. 13
Item 17 – Voting Client Securities ................................................................................................. 14
Item 18 – Financial Information ................................................................................................... 14
Exhibit – A Summary of Material Changes ........................................................................................... Ex. A
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland, Oregon.
We provide fee-only investment supervisory, portfolio management, investment consulting and
financial planning services. The firm has been in business since 2009. CSP is owned by Christopher
K. Hicks, President and Chief Compliance Officer. Our investment advisory services are coordinated
through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are used
for marketing purposes and may appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the Advisory Affiliate and not of our firm,
CSP, and the advisory services of the Advisory Affiliate are provide through our firm, CSP. CSP has
the arrangement described above with Collingwood Wealth Management, LLC, a Massachusetts
limited liability company owned and managed by David L. Armstrong. Mr. Armstrong is an
Investment Advisor Representative associated with CSP and offers investment advisory services
exclusively through CSP. Collingwood Wealth Management is not a registered investment advisor
and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to manage
client portfolios. Through our Advisory Affiliates, we help Clients coordinate and prioritize their
financial lives with all aspects of their life goals. Integrating investments across all individual
retirement accounts, taxable accounts, and employee retirement accounts is crucial to the process.
Client input and involvement are critical parts of the financial planning process and implementation
of investment decisions. After Client assets are invested, we continuously monitor their investments
and provide advice related to ongoing financial and investment needs.
We offer initial financial planning services to Clients under a separate Financial Planning Agreement.
After completion of an initial financial planning engagement, Clients may elect to enter into a retainer
agreement for ongoing Wealth Management services which include financial planning and portfolio
management.
In some limited instances, we act as a sub-advisor by providing investment models and investment
research to unaffiliated broker-dealer or investment advisor or firms. These arrangements are more
fully disclosed in Item 10, below.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory Affiliates
meet with Clients as needed to review portfolio performance, discuss current issues, and re-assess
goals and plans.
Our investment recommendations primarily include mutual funds. However, we may also
recommend other investments such as exchange-traded funds, closed-end funds, and exchange-listed
equity securities, certificates of deposit, municipal securities, U.S. government securities, and money
market funds when suitable and appropriate for a Client’s particular situation. If Clients hold other
types of investments, we will advise them on those investments also. Clients may impose restrictions
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on investing in certain securities or types of securities. We consider such restrictions when formulating
the Client’s investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client assets
on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to Clients
primarily under the following fee schedules below:
Assets Under Management:
Maximum Annual Wealth Management Retainer Fees:
$250,000
$250,001 and $500,000
$500,001 and $750,000
$750,001 and $1,000,000
$1,000,001 and $3,000,000
$3,000,001 and $5,000,000
2.05% on assets under
1.85% on assets between
1.60% on assets between
1.35% on assets between
1.10% on assets between
0.85% on assets between
0.60% on assets in excess of $5,000,000
We may also provide investment advice or financial planning to Clients on an hourly or fixed rate fee.
Our maximum hourly rate is $250.00 per hour depending on the complexity of the issue being
addressed. Fixed fee project pricing is quoted for each project, depending on the scope of work
performed. Notwithstanding the above, fees are generally negotiable.
Except for 401(k) plans, Client’s asset management accounts are billed quarterly in advance. Fees are
paid to us from the client’s account by the custodian upon our submission of an invoice. Payment of
fees may result in the liquidation of Client's securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
For 401(k) plans that we manage we may bill quarterly in arrears based on the specific Plan’s average
daily balance during the previous quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded on a
market for which actual transaction prices are publicly reported are generally valued at the last reported
sale price on the principal market in which they are traded. Mutual Funds are only valued once per
day after the close of the market. Whenever valuation information for specific, illiquid, foreign, private
or other investments is not available through the custodian, our approach will be to value at zero. We
do this in order to not overvalue a position which could potentially over inflate billing calculations.
Alternatively, we may also seek to obtain and document price information from at least one
independent source, whether it be a broker-dealer, bank, pricing service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of the
account for that quarter. This number is then divided by four.
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Fees for a partial quarter at the commencement or termination of an agreement will be prorated based
on the number of days the account was open during the quarter. Quarterly fee adjustments for
additional assets received into an account during a quarter or for partial withdrawals may also be
provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30 days
written notice in advance.
Clients may be charged a one-time set-up fee of up to $250.00 per account. A quarterly fee of up to
$37.50 may also be charged per account for administrative services. Clients may pay trading fees and
commissions on any discretionary trades initiated by us. Clients may also be charged up to $35.00 per
trade as an administrative fee by us for any Client directed trades. Notwithstanding the foregoing,
fees are generally negotiable.
Clients may be required to pay trading fees and other miscellaneous charges or fees directly to the
custodian (e.g. wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or
exchange traded funds have additional internal expenses which generally include a fund management
fee, other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees are
separate and additional expenses incurred by the Client. See Item 12 for additional information on
Brokerage Practices.
Our fees include the time necessary to work with Client's attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as assisting
those advisors in implementation of all appropriate documents. However, we are not responsible for
attorney, accountant or other third party professional fees charged to Client as a result of these
activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more fully
disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in advance. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written notice.
Upon termination, any fees that have been earned by us but not yet paid will be immediately due and
payable. Clients are also responsible for all applicable charges including, but not limited to, account
administrative fees, account closure fees and all trading costs due to the termination, including any
fees the mutual funds may assess. Upon request, we will provide a good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are generally
invoiced by us with payment due by the Client upon receipt of the invoice. We may estimate the
number of hours necessary to complete a project, and we may collect a portion of this estimate up
front and invoice the balance. However, under no circumstances will the Client be required to pay
more than $1200 for services more than six months in advance. Upon termination of any hourly or
fixed fee project, any prepaid but unearned fees will be promptly refunded to the Client.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products through
various carriers.
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CSP is a fee only registered investment adviser and does not act as an insurance brokerage or agency
and is not otherwise affiliated with any insurance brokerages or agencies. However, a conflict of
interest arises when insurance related business is transacted with advisory Clients because certain
individual Advisory Affiliates of CSP are independently licensed to sell insurance products through
various carriers. In their capacity as an Insurance Agent, they may receive commissions or other fees
from products sold to Clients. As such, Clients are advised that they are under no obligation to use
any individual associated with CSP for insurance products or services, and may use any insurance firm
or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance or
other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the actual
dollar amount of any commission payment to an Insurance Agent or Registered Representative. Also,
because CSP is neither a broker dealer nor an insurance agency, we do not have the ability to rebate
commissions received for the sale of a product and cannot discount the price of a product to make
up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from your
employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan
Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA,
or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also
recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts,
and from IRA Accounts to IRA Accounts. When we provide any of the foregoing rollover
recommendations we are acting as fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-
based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of
interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e.,
receipt of additional fee-based compensation). You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest,
when we make rollover recommendations, we operate under a special rule that requires us to act in
your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
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charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following
options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an entirely
educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1.
Under this approach, our role will be limited only to providing you with general educational materials
regarding the pros and cons of rollover transactions. We will make no recommendation to you
regarding the prospective rollover of your assets and you are advised to speak with your trusted tax
and legal advisors with respect to rollover decisions. As part of this educational approach, we may
provide you with materials discussing some or all of the following topics: the general pros and cons
of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement
withdrawals on retirement income; the investment options available inside your Plan Account; and
high level discussion of general investment concepts (e.g., risk versus return, the benefits of
diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide
you with questionnaires and/or interactive investment materials that may provide a means for you to
independently determine your future retirement income needs and to assess the impact of different
asset allocations on your retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side management.
Item 7 – Types of Clients
We provide investment advice to individuals, businesses, pension and profit sharing plans, trusts,
estates, and charitable organizations. Because each Client is unique, they must be willing to be
involved in the planning and ongoing processes. Such involvement does not have to be time
consuming, however we want our Clients to remain informed about their overall financial situation.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets, combined
with periodic rebalancing. Our Advisory Affiliates create an investment strategy with each Client,
outlining the investment philosophy, management procedures, and long-term goals for the investor.
Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed-end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer advice
on digital assets and cryptocurrency. Each type of security has its own unique set of risks associated
with it, and it would not be possible to disclose all of the specific risks of every type of investment in
this brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client pays
for part of a purchase and borrows the rest from the brokerage firm that custodies the account. If our
Clients have any questions regarding the risks associated with a particular investment, they are
encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from many
investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager that
trades the fund’s investments in accordance with the fund's investment objective. While mutual funds
generally provide diversification, risks can be significantly increased if the fund is concentrated in a
particular sector of the market, primarily invests in small cap or speculative companies, uses leverage
(i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e.,
equities) rather than balancing the fund with different types of securities. Other fund risks include
foreign securities and currency risk, emerging markets risk, small-cap, mid-cap and large-cap risk,
trading risk, and turnover risk that can increase fund expenses and may decrease fund performance.
Brokerage and transactions costs incurred by the fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index, such
as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market risk is,
perhaps, the most significant risk associated with ETFs. This risk is defined by the day to day
fluctuations associated with any exchange traded security, where fluctuations occur in part based on
the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in numerous
ways. Price fluctuations and market risk are the most significant risk concerns. As such, the value of
your investment can increase or decrease over time. Furthermore, you should understand that stock
prices can be affected by many factors including, but not limited to, the overall health of the economy,
the health of the market sector or industry of the issuing company, and national and political events.
When investing in stock, it is important to focus on the average returns achieved over a given period
of time, across a well-diversified portfolio.
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Individual debt securities (or “bonds”) are typically safer investments than equity securities, but their risk
can also vary widely based on: the financial health of the issuer; the risk that the issuer might default;
when the bond is set to mature; and, whether or not the bond can be “called” prior to maturity. When
a bond is called, it may not be possible to replace it with a bond of equal character paying the same
rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time, generally
greater than one year. Sometimes we will employ a Short Term Purchase strategy where securities are
purchased with the expectation that they will be sold within a relatively short period of time, generally
less than one year, to take advantage of the securities’ short term price fluctuations. Short-term trading
(in general, selling securities within 30 days of purchasing the same securities) is not a fundamental
part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk when
suitable and appropriate for an individual Client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum, Litecoin,
and others (collectively, “Cryptocurrency”). Where exposure to this asset class is appropriate, we will
typically, if not exclusively, obtain such exposure through purchases and sales of ETFs and other
publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative than
an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike the
market valuations of publicly-traded stocks and bonds which can be objectively valued on the basis
of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and other
factors, prices of Cryptocurrency are based entirely on the market’s perception of value and are subject
to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an extremely high
level of price volatility, including “flash crashes,” and may lose significant value in a matter of minutes,
hours, or days. It is not uncommon for the value of Cryptocurrency to move as much as twenty
percent (20%) or more in a single day. The ownership of particular Cryptocurrency is opaque and
therefore certain Cryptocurrency may be owned and controlled by relatively small number of
individuals, increasing the potential for fraud and market-manipulation such as pump-and-dump
schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is in
its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do not
create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of their
future viability as a store of value or a means of exchange. Federal, state, or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the United States is still developing.
Cryptocurrency is not legal tender in most jurisdictions, including the United States. No laws require
individuals or businesses to accept Cryptocurrency as a form of payment and Cryptocurrency does
not have any intrinsic value. Its value derives entirely from market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
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than established, regulated exchanges for securities, derivatives, and other currencies. Cryptocurrency
exchanges may stop operating or permanently shut down due to fraud, technical glitches, hackers, or
malware. Due to relatively recent launches, most Cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, Cryptocurrency transactions are
irreversible, such that an improper transfer can only be reversed by the receiver of the cryptocurrency
agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would have
insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing economic,
demographic and social trends followed by a more focused analysis at the country level, then the
industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such as the
background and experience of the fund manager and/or the fund company (style, consistency, risk-
adjusted performance, management expenses, average daily trading volume, etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This strategy
would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should be
prepared to bear. We do not represent or guarantee that our services or methods of analysis can or
will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses
due to market corrections or declines. We cannot offer any guarantees or promises that your financial
goals and objectives will be met. Past performance is in no way an indication of future performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
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Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM offers
investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
In addition to Collingwood Wealth Management, David L. Armstrong is an owner and Member of
Master Planners & Associates, LLC, which is the legal business entity of an advisory affiliate of CS
Planning Corp.
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of CSP
Clients and will only transact insurance related business with Clients when the products are fully
disclosed, suitable, and appropriate to fit their needs, and in order to simplify the implementation of
various wealth management strategies.
Promotor Relationships:
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals and
Other Compensation”), below. We do not believe this arrangement creates any conflicts of interest
with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM) or
sub-advisors who provide customized investment portfolio management services. These services may
include the construction of investment portfolios, execution of securities purchase and sale
transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-advisor
to execute a confidentiality agreement and not share non-public personal information with any
unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If applicable,
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any additional fees will be fully disclosed to Clients in a separate agreement with the TPAM or sub-
advisor.
Sub- Advisory Services:
In some limited instances we act as a sub-advisor by providing investment models and research to
unaffiliated broker dealer and investment advisor firms. In those situations we enter into a sub-advisor
agreement with the broker-dealer or investment advisor setting forth the services to be provided and
fees to be charged. Although we provide models and research to these broker-dealers and investment
advisors, we have no contact or interaction with any end-clients. The unaffiliated broker-dealer and
investment advisor firms and their associated registered persons remain solely responsible for
determining which investment model(s) is/are suitable and appropriate for their end-clients. Those
firms and their associated registered persons also retain full responsibility of the fiduciary duties owed
to their end-clients.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (855) 357-2013. Brochures are provided
free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their own
account that we buy and sell for Clients. When appropriate we will purchase or sell securities for
Clients before purchasing the same for our account or allowing representatives to purchase or sell the
same for their own account. However, we do allow the accounts of employees to be included in block
trading alongside the accounts of Clients. In some cases we or our representatives may buy or sell
securities for our own account for reasons not related to the strategies adopted for our Clients. Our
employees are required to follow the Code of Ethics when making trades for their own accounts in
securities which are recommended to and/or purchased for Clients. The Code of Ethics is designed
to assure that the personal securities transactions will not interfere with decisions made in the best
interest of advisory Clients while at the same time, allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we will
disclose to our advisory Clients any material conflict of interest relating to us, our representatives, or
any of our employees which could reasonably be expected to impair the rendering of unbiased and
objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP or Collingwood Wealth
shall not buy or sell securities for his personal portfolio where his decision is
substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No person
associated with CSP or Collingwood Wealth shall prefer his or her own interest to that
of the advisory Client.
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•
We maintain a list of all securities holdings for the firm and for anyone associated with
its advisory practice who has access to advisory recommendations. An appropriate
officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to and
including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which the
Client directs the use of a particular custodian if we believe that this choice would hinder either our
fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and with
the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of such
services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined by us
before the trade is placed with the broker. When practical, Client trades in the same security will be
bunched in a single order (a “block”) in an effort to obtain best execution at the best security price
available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to underlying
accounts on a pro rata basis, adjusted as necessary to keep Client transaction costs to
a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades, an
average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average price.
Multiple blocks may be executed within a single day. However, only trades executed
within the block on the single day may be combined for purposes of calculating the
average price.
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It is expected that this trade aggregation and allocation policy will be applied consistently. However,
if application of this policy results in unfair or inequitable treatment to some or all of our Clients, we
may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which are
attributable to CSP occur, we shall take any steps necessary to put the Client in the position it should
have been as if the trade error never occurred. In the event we determine that a bona fide trade error
has occurred which is attributable to CSP, we will correct the trade error using funds from our error
account. Depending on the internal trade error policies and procedures of the particular custodian,
our error account may be debited if the correction results in a loss. Likewise, our error account may
be credited if the correction results in a gain. This situation creates a conflict of interest as CSP has
an incentive to recommend particular custodians over others that may not have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of each
Client's stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a particular
Client’s account. The Advisory Affiliate assigned to a particular Client’s account will be responsible
for the periodic reviews to that account. Clients will be provided the Supplemental Brochure (Form
ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client's
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases; or
changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their accounts
generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates may also
provide Clients with periodic written reports summarizing the account activity and performance.
Along with these reports, we discuss the asset allocation of the portfolio compared to the portfolio
target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless otherwise
agreed at the start of the engagement. However additional review or reports will not typically be
provided unless otherwise provided for under the terms of the engagement. Consulting Services
Clients will not typically receive reports or formal reviews due to the nature of the service.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with these
conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell insurance.
The conflicts of interest these arrangements present and how we deal with these conflicts are described
in detail under Item 5, above.
Promoter Relationships:
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Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash compensation
to third-party intermediaries in exchange for their promotion, referral, and endorsement of our
advisory services to prospective clients. The cash compensation paid to such promoters may take the
form of a retainer, a flat advertising fee, a fee per referral, and/or a percentage of the advisory fees we
collect from referred client accounts. These fees may be paid to the promoter on a one-time or
recurring basis. Unless otherwise explicitly disclosed in writing to the client, the cash compensation
paid to a promoter will be borne entirely by CSP and the Advisory Affiliate. Referred clients do not
pay any additional or increased advisory fees as a result of having been referred to our firm by a paid
third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940. Any
promoters engaged for this purpose will disclose to you at or reasonably prior to the time of their
referral or endorsement of CSP (i) that they will receive compensation from CSP as a result of their
endorsement of our firm; (ii) a description of the material terms of the compensation they will receive;
and (iii) a brief statement discussing the conflicts of interest arising out of the compensation
arrangement and/or the relationship between CSP and the third-party promoter. Clients referred to
our firm by a third-party promoter are encouraged to inquire with us if they have any questions about
the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise have
custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian or
any acts of the agents or employees of the custodian and whether or not the full amount or such loss
is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance which
may be carried by the custodian. The Client understands that SIPC provides only limited protection
for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge all
Clients to carefully review statements from the custodian and compare these to any reports that we
may provide to you. Our reports may vary from custodial statements based on accounting procedures,
reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary authority
to execute investment recommendations in accordance with an agreed upon investment strategy or
plan without the Client’s prior approval of each specific transaction. Under discretionary authority,
Client allows us to purchase and sell securities and instruments in their account(s), arrange for delivery
and payment in connection with the foregoing, select and retain sub-advisors, and act on behalf of the
Client in matters necessary or incidental to the handling of the account, including monitoring certain
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assets. The only restrictions on this discretionary authority are those set by the Client on a case by case
basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine or
make changes to a Client’s stated investment strategy without the Client’s prior approval. However,
CSP will still have complete discretion to implement its trading strategies to update the portfolio
allocation within that stated investment strategy, without the Client’s prior approval. In this type of
situation, CSP will require authorization from the Client before making any changes to a Client’s
investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether authority
is discretionary or non-discretionary. Further, we make it a practice to question Clients to determine
if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do not
provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on behalf
of a Client, they will be sent directly to the Client who remains responsible to vote the proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to Clients.
Neither CSP, nor any of the principals, have been the subject of a bankruptcy petition at any time in
the past. We have no financial conditions that would impair our ability to meet contractual
commitments to our Clients.
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Exhibit A – Summary of Material Changes
This Item discusses only specific material changes that have been made to our Brochure since the
version dated April 10, 2025. Since that date we have made the following material changes:
Item 5 was amended to reflect that for 401(k) plans that we manage we may bill
quarterly in arrears based on the specific Plan’s average daily balance during the
previous quarter.
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated
entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When required,
a Summary of Material Changes will also be included with our Brochure on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is #149937.
Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further provide other
ongoing disclosure information about material changes as necessary and will further provide you with
a new Brochure as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (855) 357-2013. Our Brochure is
provided free of charge.
Ex. A
Additional Brochure: CSP DBA COMMON SENSE PORTFOLIOS ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Common Sense Portfolios
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA COMMON SENSE PORTFOLIOS
8117 Preston Road, Suite 300
Dallas, Texas 75225
Phone: (214) 417-8841
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Common Sense Portfolios. If you have any questions about the contents of this Brochure
or to obtain answers and additional information, you may contact us at (214) 417-8841 or
mike@commonsenseportfolio.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is #149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is #149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (214) 417-8841 or
mike@commonsenseportfolio.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 4
Item 5 – Fees and Compensation ................................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 8
Item 7 – Types of Clients ................................................................................................................................ 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 9
Item 9 – Disciplinary Information ............................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 12
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 13
Item 12 – Brokerage Practices ..................................................................................................................... 14
Item 13 – Review of Accounts ..................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .............................................................................. 16
Item 15 – Custody ........................................................................................................................................... 16
Item 16 – Investment Discretion ................................................................................................................. 17
Item 17 – Voting Client Securities .............................................................................................................. 17
Item 18 – Financial Information .................................................................................................................. 17
Exhibit A – Summary of Material Changes ................................................................................................ 1
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Item 4 – Advisory Business
CS Planning Corp (“CS Planning”) is an SEC registered investment advisory firm located in
Portland, Oregon. We provide fee-only investment supervisory, portfolio management,
investment consulting and financial planning services. The firm has been in business since 2009.
CS Planning is owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CS Planning, and the advisory services of the Advisory Affiliate are provided through
our firm, CS Planning. CS Planning has the arrangement described above with Common Sense
Portfolios, LLC, a Texas limited liability company doing business as Common Sense Portfolios,
managed by James Michael Plumlee. Mike Plumlee is an Investment Advisor Representative
associated with CS Planning, offers investment advisory services exclusively through CS
Planning, and only utilizes Common Sense Portfolios for marketing purposes. Common Sense
Portfolios is not a registered investment advisor and is not affiliated with CS Planning.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities and money market funds when suitable and appropriate for a Client’s
particular situation. If Clients hold other types of investments, we will advise them on those
investments also. Clients may impose restrictions on investing in certain securities or types of
securities. We consider such restrictions when formulating the Client’s investment strategy. See
Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
We provide investment supervisory services to Clients pursuant to a Wealth Management
Agreement and primarily under the following fee schedule below:
Advisory Fee Schedule
Range (Breakpoint)
$0
$200,000.01
$400,000.01
$600,000.01
$800,000.01
$200,000.00
$400,000.00
$600,000.00
$800,000.00
$1,000,000.00
More than $1,000,000
Annual Maximum Fee
$2,000.00
$4,000.00
$6,000.00
$8,000.00
$10,000.00
Negotiable
Existing clients may be grandfathered into a different fee.
Client’s asset management accounts are billed quarterly in arrears. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior quarter.
Market value includes all account values and transaction information as of the end of each quarter
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The quarterly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that quarter. This number is then divided by four.
Fees for a partial quarter at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the quarter. Quarterly fee adjustments
for additional assets received into an account during a quarter or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
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Under certain limited circumstances, Clients may pay commissions and trading fees on trades
initiated by us, in addition to other agreed upon fees.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees quarterly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Certain Advisory Affiliates of CS Planning are also independently licensed to sell insurance
products through various carriers.
CS Planning is a fee only registered investment adviser and does not act as an insurance brokerage
or agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CS Planning are independently licensed to sell
insurance products through various carriers. In their capacity as an Insurance Agent, they may
receive commissions or other fees from products sold to Clients. As such, Clients are advised that
they are under no obligation to use any individual associated with CS Planning for insurance
products or services, and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CS Planning are
separate and distinct from the commissions earned by any individual in connection with the sale
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of insurance or other securities products and CS Planning does not receive any compensation for
products sold by these Advisory Affiliates.
Because CS Planning is not involved in the sale of insurance products, we do not know the actual
dollar amount of any commission payment to an Insurance Agent. Also, because CS Planning is
neither a broker dealer nor an insurance agency, we do not have the ability to rebate commissions
received for the sale of a product and cannot discount the price of a product to make up for any
commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
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Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, and money market funds when suitable and appropriate. In
limited circumstances, and only when suitable and appropriate, we may offer advice on digital
assets and cryptocurrency. Each type of security has its own unique set of risks associated with it,
and it would not be possible to disclose all of the specific risks of every type of investment in this
brochure. In those limited situations where it is suitable and appropriate to meet a particular
Client’s needs, we may also utilize margin to manage an account. Margin occurs when a client
pays for part of a purchase and borrows the rest from the brokerage firm that custodies the account.
If our Clients have any questions regarding the risks associated with a particular investment, they
are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
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such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
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not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
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or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CS Planning may also be independently
licensed as insurance agents with other agencies. Affiliates may recommend the purchase and sale
of certain insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the
benefit of CS Planning Clients and will only transact insurance related business with Clients when
the products are fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify
the implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
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and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (214) 417-8841. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
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representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CS Planning and Common
Sense Portfolios shall not buy or sell securities for his personal portfolio where his
decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable
inquiry. No person associated with CS Planning and Common Sense Portfolios
shall prefer his or her own interest to that of the advisory Client.
•
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
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•
•
•
•
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CS Planning occur, we shall take any steps necessary to put the Client in the
position it should have been as if the trade error never occurred. In the event we determine that a
bona fide trade error has occurred which is attributable to CS Planning, we will correct the trade
error using funds from our error account. Depending on the internal trade error policies and
procedures of the particular custodian, our error account may be debited if the correction results
in a loss. Likewise, our error account may be credited if the correction results in a gain. This
situation creates a conflict of interest as CS Planning has an incentive to recommend particular
custodians over others that may not have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
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Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CS Planning may also be licensed to
sell insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
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loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CS Planning will still have complete discretion to implement its trading
strategies to update the portfolio allocation within that stated investment strategy, without the
Client’s prior approval. In this type of situation, CS Planning will require authorization from the
Client before making any changes to a Client’s investment strategy.
CS Planning will act in accordance with any agreed upon investment strategy, regardless of
whether authority is discretionary or non-discretionary. Further, we make it a practice to question
Clients to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
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We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CS Planning, nor any of the principals, nor James Michael Plumlee, have been the subject
of a bankruptcy petition at any time in the past. We have no financial conditions that would impair
our ability to meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
We have made the following material changes to this Brochure since the last annual amendment
dated March 31, 2025:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is
#149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may further
provide other ongoing disclosure information about material changes as necessary and will further
provide you with a new Brochure as necessary based on changes or new information, at any time,
without charge.
Currently, our Brochure may be requested by contacting us at (214) 417-8841 or
mike@commonsenseportfolio.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CSP DBA REDSTONE CAPITAL MANAGEMENT- FORM ADV 2A (2026-04-30)
View Document Text
Redstone Capital Management
Part 2A of Form ADV – Brochure
CS PLANNING CORP
DOING BUSINESS AS:
REDSTONE CAPITAL MANAGEMENT
7231 E. Princess Blvd. Suite 201
Scottsdale, AZ 85255
Phone: (480) 685-2931
www.redstonecapitalmanagement.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Redstone Capital Management. If you have any questions about the contents of this
Brochure or to obtain answers and additional information, you may contact us at (480) 685-2931
or kevin@redstonecapitalmanagement.com. CS Planning Corp is a registered investment adviser
with the United States Securities and Exchange Commission (“SEC”). Registration of an
investment adviser does not imply any level of skill or training. The information in this Brochure
has not been approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (480) 685-2931 or
kevin@redstonecapitalmanagement.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 4
Item 5 – Fees and Compensation ................................................................................................................... 5
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 9
Item 7 – Types of Clients ................................................................................................................................ 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 9
Item 9 – Disciplinary Information ............................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 12
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 13
Item 12 – Brokerage Practices ..................................................................................................................... 14
Item 13 – Review of Accounts ..................................................................................................................... 15
Item 14 – Client Referrals and Other Compensation .............................................................................. 16
Item 15 – Custody ........................................................................................................................................... 17
Item 16 – Investment Discretion ................................................................................................................. 17
Item 17 – Voting Client Securities .............................................................................................................. 17
Item 18 – Financial Information .................................................................................................................. 18
Exhibit A – Summary of Material Changes ................................................................................................ 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm. We provide fee-only
investment supervisory, portfolio management, investment consulting and financial planning
services. The firm has been in business since 2009. CSP is owned by Christopher K. Hicks,
President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Redstone Capital Management, LLC, an
Arizona limited liability company, managed by Kevin Canterbury. Mr. Canterbury is an
Investment Advisor Representative associated with CSP, offers investment advisory services
exclusively through CSP, and only utilizes Redstone Capital Management for marketing purposes.
Redstone Capital Management is not a registered investment advisor and is not affiliated with
CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, non-traded securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory services to Clients pursuant to an Investment Management
Agreement and primarily under the following fee schedules below:
ACTIVELY MANAGED ACCOUNTS
Balanced Accounts:
$0 to $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 and Up
1.25%
1.10%
0.85%
0.75%
0.60%
Actively Managed Fixed Income Only Accounts:
$0 to $500,000
$500,001 to $3,000,000
$3,000,001 to $6,000,000
$6,000,001 to $10,000,000
Greater than $10,000,000
0.85%
0.70%
0.60%
0.50%
0.40%
Concentrated Aggressive Growth Strategy
$0 to $3,000,000
$3,000,001 to $10,000,000
1.50%
1.25%
Fee-Based Variable Annuity:
Greater than $50,000
0.70%
Short-Term Cash Management Accounts:
$0 to $500,000
Greater than $500,000
0.75%
0.60%
In addition to the fees set-forth above, Clients may be charged an additional investment manager
fee of 0.50%. All fees are calculated based upon the fee schedule provided at the opening of the
initial account.
Client’s asset management accounts are billed monthly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
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on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Under certain circumstances, Clients may pay commissions and trading fees on trades initiated by
us, in addition to other agreed upon fees. Clients may also be charged up to $35.00 per trade as an
administrative fee for Client directed trades. Notwithstanding the foregoing, fees follow the
prevailing fee schedule.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”), investment manager or sub-advisor. These
arrangements are more fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in advance. All Wealth
Management Agreements may be terminated at any time by providing us with 30 days written
notice. If an account is terminated during a month after fees have been deducted, the client will
be refunded a prorated portion based on the number of days the account was open during the
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month. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers. CSP is a fee only registered investment adviser and does not act as an
insurance brokerage or agency and is not otherwise affiliated with any insurance brokerages or
agencies. However, a conflict of interest arises when insurance related business is transacted with
advisory Clients, because certain individual Advisory Affiliates of CSP are independently licensed
to sell insurance products through various carriers. In their capacity as an Insurance Agent, they
may receive commissions or other fees from products sold to Clients. As such, Clients are advised
that they are under no obligation to use any individual associated with CSP for insurance products
or services, and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products, we do not know the actual dollar
amount of any commission payment to an Insurance Agent. Also, because CSP is neither a broker
dealer nor an insurance agency, we do not have the ability to rebate commissions received for the
sale of a product and cannot discount the price of a product to make up for any commission that
may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests ahead of yours.
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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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
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Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, non-traded securities, and money market funds when
suitable and appropriate. In limited circumstances, and only when suitable and appropriate, we
may offer advice on digital assets and cryptocurrency. Each type of security has its own unique
set of risks associated with it, and it would not be possible to disclose all of the specific risks of
every type of investment in this brochure. In those limited situations where it is suitable and
appropriate to meet a particular Client’s needs, we may also utilize margin to manage an account.
Margin occurs when a client pays for part of a purchase and borrows the rest from the brokerage
firm that custodies the account. If our Clients have any questions regarding the risks associated
with a particular investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
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ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Non-traded Securities can include non-exchanged traded REIT’s, Private Equity, Private Debt,
BDC’s, and Preferred Securities. These types of securities have unique and complex risk profiles
which are differentiated from exchange-traded securities. These investments are characterized by
limited liquidity, high internal fees, and lack of transparency.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies or 1X inverse ETF’s in order to
mitigate market risk when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
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Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
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Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
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PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage affiliated and unaffiliated Third Party Asset
Managers (TPAM), investment managers, or sub-advisors who provide customized investment
portfolio management services. These services may include the construction of investment
portfolios, execution of securities purchase and sale transactions, and portfolio administration,
including tracking of and reporting on portfolio performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs,
investment managers, or sub-advisors for the purpose of managing their portfolios. However we
require any TPAM or sub-advisor to execute a confidentiality agreement and not share non-public
personal information with any unauthorized person or entity.
Clients may be required to enter into a separate advisory agreement with any TPAM, investment
manager or sub-advisor. The use of TPAMs, investment managers, or sub-advisors may cause
Clients to incur additional fees. If applicable, any additional fees will be fully disclosed to Clients
in an Investment Management Agreement, or a separate agreement with the TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available free of
charge to any Client or prospective Client upon request by contacting us at (480) 685-2931.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
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sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Redstone Capital
Management shall not buy or sell securities for his personal portfolio where his
decision is substantially derived, in whole or in part, by reason of his employment
unless the information is also available to the investing public on reasonable
inquiry. No person associated with CSP and Redstone Capital Management shall
prefer his or her own interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
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•
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
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More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
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Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
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behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Kevin Canterbury, have been the subject of a
bankruptcy petition at any time in the past. We have no financial conditions that would impair our
ability to meet contractual commitments to our Clients.
Part 2A - 18
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Part 2A of Form ADV – Brochure
Exhibit A – Summary of Material Changes
Since the last annual amendment to this Brochure for CS Planning Corp dba Redstone Capital
Management dated April 1, 2025, we have made the following material changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (480) 685-2931 or
kevin@redstonecapitalmanagement.com. Our Brochure is provided free of charge.
Ex. A
Additional Brochure: CSP DBA SEVEN SUMMITS CAPITAL (CURRY) - FORM ADV 2A (2026-04-30)
View Document Text
Seven Summits Capital
Part 2A of Form ADV – Brochure
CS PLANNING CORP
DOING BUSINESS AS:
SEVEN SUMMITS CAPITAL
1853 William Penn Way, Suite 9
Lancaster, PA 17601
Phone: (717) 735-0013
MARTIN J. CURRY, DC, CFP®, ChFC®, CLU®
631 North Park Drive
Salisbury, MD 21804
Phone: (410) 430-9966
www.ssummitscapital.com
April 29, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Seven Summits Capital. If you have any questions about the contents of this Brochure
or to obtain answers and additional information, you may contact us at (717) 877-7422 or
cstauffer@ssummitscapital.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
Part 2A - i
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Part 2A of Form ADV – Brochure
Item 2 – Material Changes
The following material changes have been made to this Brochure since the last annual
amendment dated April 10, 2025:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc.,
The H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer
affiliated entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (717) 735-0013 or
cstauffer@ssummitscapital.com.
Part 2A - ii
Seven Summits Capital
Part 2A of Form ADV – Brochure
Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 6
Item 7 – Types of Clients ................................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 6
Item 9 – Disciplinary Information ............................................................................................................... 10
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 10
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 11
Item 12 – Brokerage Practices ..................................................................................................................... 12
Item 13 – Review of Accounts ..................................................................................................................... 13
Item 14 – Client Referrals and Other Compensation .............................................................................. 13
Item 15 – Custody ........................................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................................. 15
Item 17 – Voting Client Securities .............................................................................................................. 15
Item 18 – Financial Information .................................................................................................................. 15
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm. We provide fee-only
investment supervisory, portfolio management, investment consulting and financial planning
services. The firm has been in business since 2009. CSP is owned by Christopher K. Hicks,
President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Seven Summits Capital, LLC, a
Pennsylvania limited liability company, managed by Curt Stauffer. Mr. Stauffer is an Investment
Advisor Representative associated with CSP, offers investment advisory services exclusively
through CSP, and only utilizes Seven Summits Capital for marketing purposes. Seven Summits
Capital is not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
In addition to wealth management services, we offer financial planning services to Clients under
a separate Financial Planning Agreement.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, non-traded securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
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CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
Item 5 – Fees and Compensation
Investment Advisory services are provided to Client pursuant to an Investment Management
Agreement and primarily under the following fee schedules below:
ACTIVELY MANAGED ACCOUNTS
Balanced Accounts:
$0 to $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $20,000,000
Greater than $20,000,000
1.50%
1.25%
1.00%
0.85%
0.75%
0.50%
Actively Managed Fixed Income Only Accounts:
$0 to $500,000
$500,001 to $3,000,000
$3,000,001 to $6,000,000
$6,000,001 to $10,000,000
Greater than $10,000,000
1.00%
0.85%
0.75%
0.60%
0.40%
Fee-Based Variable Annuity:
Greater than $50,000
0.85%
Short-Term Cash Management Accounts:
$0 to $500,000
Greater than $500,000
0.85%
0.60%
Note: All fees represented are “not to exceed” levels.
We also provide stand-alone Financial Planning/Consulting services on a fixed fee or hourly rate
under a separate Financial Planning Agreement. Our fixed fee pricing is quoted for each project
and is priced based on the scope and complexity of the project. Our maximum hourly rate is $500
per hour. Notwithstanding the above, fees are generally negotiable.
In addition to the fees set-forth above, Clients may be charged an additional investment manager
fee of 0.50%. All fees are calculated based upon the fee schedule provided at the opening of the
initial account.
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Client’s asset management accounts are billed monthly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Unless otherwise agreed, advisory fees on
alternative investments are charged based on their fair market value of the alternative investment
as reported by the issuer, sponsor, or independent auditor of the alternative investment. Where
market value of the alternative investments is not provided by the issuer, we will make a good faith
effort to obtain pricing, either through an independent third party pricing source or through our
own independent determination.
The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Under certain circumstances, clients may pay commissions and trading fees on trades initiated by
us, in addition to other agreed upon fees. Clients may also be charged up to $35.00 per trade as an
administrative fee for Client directed trades. Notwithstanding the foregoing, fees follow the
prevailing fee schedule.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
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In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”), investment manager, or sub-advisor. These
arrangements are more fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in advance. All Wealth
Management Agreements may be terminated at any time by providing us with 30 days written
notice. If an account is terminated during a month after fees have been deducted, the client will
be refunded a prorated portion based on the number of days the account was open during the
month. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers. CSP is a fee only registered investment adviser and does not act as an
insurance brokerage or agency and is not otherwise affiliated with any insurance brokerages or
agencies. However, a conflict of interest arises when insurance related business is transacted with
advisory Clients, because certain individual Advisory Affiliates of CSP are independently licensed
to sell insurance products through various carriers. In their capacity as an Insurance Agent, they
may receive commissions or other fees from products sold to Clients. As such, Clients are advised
that they are under no obligation to use any individual associated with CSP for insurance products
or services, and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Martin J. Curry, DC, CFP®, ChFC®, CLU® is an Investment Advisor Representative of CSP and
is dually registered as an Investment Advisor Representative of First Shore Private Wealth LLC,
a Maryland state-registered investment advisory firm. CSP and First Shore Private Wealth LLC
are separate entities with no common ownership or management affiliation.
Because CSP is not involved in the sale of insurance products, we do not know the actual dollar
amount of any commission payment to an Insurance Agent. Also, because CSP is neither a broker
dealer nor an insurance agency, we do not have the ability to rebate commissions received for the
sale of a product and cannot discount the price of a product to make up for any commission that
may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
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Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests 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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
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educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, non-traded securities, and money market funds when
suitable and appropriate. In limited circumstances, and only when suitable and appropriate, we
may offer advice on digital assets and cryptocurrency. Each type of security has its own unique
set of risks associated with it, and it would not be possible to disclose all of the specific risks of
every type of investment in this brochure. In those limited situations where it is suitable and
appropriate to meet a particular Client’s needs, we may also utilize margin to manage an account.
Margin occurs when a client pays for part of a purchase and borrows the rest from the brokerage
firm that custodies the account. If our Clients have any questions regarding the risks associated
with a particular investment, they are encouraged to contact us.
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Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Non-traded Securities can include non-exchanged traded REIT’s, Private Equity, Private Debt,
BDC’s, and Preferred Securities. These types of securities have unique and complex risk profiles
which are differentiated from exchange-traded securities. These investments are characterized by
limited liquidity, high internal fees, and lack of transparency.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
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fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies or 1X inverse ETF’s in order to
mitigate market risk when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
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Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
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Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Martin J. Curry, DC, CFP®, ChFC®, CLU® is an Investment Advisor Representative of CSP and
is dually registered as an Investment Advisor Representative of First Shore Private Wealth LLC,
a Maryland state-registered investment advisory firm. CSP and First Shore Private Wealth LLC
are separate entities with no common ownership or management affiliation.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage affiliated and unaffiliated Third Party Asset
Managers (TPAM), investment managers or sub-advisors who provide customized investment
portfolio management services. These services may include the construction of investment
portfolios, execution of securities purchase and sale transactions, and portfolio administration,
including tracking of and reporting on portfolio performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs,
investment managers, or sub-advisors for the purpose of managing their portfolios. However we
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require any TPAM or sub-advisor to execute a confidentiality agreement and not share non-public
personal information with any unauthorized person or entity.
Clients may be required to enter into a separate advisory agreement with any TPAM, investment
manager, or sub-advisor. The use of TPAMs, investment managers, or sub-advisors may cause
Clients to incur additional fees. If applicable, any additional fees will be fully disclosed to Clients
in an Investment Management Agreement, or a separate agreement with the TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available free of
charge to any Client or prospective Client upon request by contacting us at (717) 735-0013.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases, we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Seven Summits
Capital shall not buy or sell securities for his personal portfolio where his decision
is substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP and Seven Summits Capital shall prefer his or her own
interest to that of the advisory Client.
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•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients; however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
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It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
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As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
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Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. However, Clients direct us to receive
proxy materials from the custodian. When we receive those materials we review the information
pertinent to investment decision making, and then dispose of it.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Curt Stauffer, have been the subject of a bankruptcy
petition at any time in the past. We have no financial conditions that would impair our ability to
meet contractual commitments to our Clients.
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Additional Brochure: CSP DBA SEVEN SUMMITS CAPITAL - FORM ADV 2A (2026-04-30)
View Document Text
Seven Summits Capital
Part 2A of Form ADV – Brochure
CS PLANNING CORP
DOING BUSINESS AS:
SEVEN SUMMITS CAPITAL
1853 William Penn Way, Suite 9
Lancaster, PA 17601
Phone: (717) 735-0013
www.ssummitscapital.com
April 28, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Seven Summits Capital. If you have any questions about the contents of this Brochure
or to obtain answers and additional information, you may contact us at (717) 877-7422 or
cstauffer@ssummitscapital.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
This Item discusses only specific material changes that have been made to our Brochure since our
prior annual update dated April 10, 2025. Since that date, we have made the following material
changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The H
Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated entities of
CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is 149937. We may further provide other ongoing disclosure information about material changes
as necessary and will further provide you with a new Brochure as necessary based on changes or
new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (717) 735-0013 or
cstauffer@ssummitscapital.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 6
Item 7 – Types of Clients ................................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 6
Item 9 – Disciplinary Information ................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 9
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 10
Item 12 – Brokerage Practices ..................................................................................................................... 11
Item 13 – Review of Accounts ..................................................................................................................... 12
Item 14 – Client Referrals and Other Compensation .............................................................................. 13
Item 15 – Custody ........................................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................................. 14
Item 17 – Voting Client Securities .............................................................................................................. 14
Item 18 – Financial Information .................................................................................................................. 15
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm. We provide fee-only
investment supervisory, portfolio management, investment consulting and financial planning
services. The firm has been in business since 2009. CSP is owned by Christopher K. Hicks,
President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Seven Summits Capital, LLC, a
Pennsylvania limited liability company, managed by Curt Stauffer. Mr. Stauffer is an Investment
Advisor Representative associated with CSP, offers investment advisory services exclusively
through CSP, and only utilizes Seven Summits Capital for marketing purposes. Seven Summits
Capital is not a registered investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, and exchange-listed equity securities, certificates of deposit, municipal securities,
U.S. government securities, non-traded securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory services to Clients pursuant to an Investment Management
Agreement and primarily under the following fee schedules below:
ACTIVELY MANAGED ACCOUNTS
Balanced Accounts:
$0 to $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 and Up
1.25%
1.10%
0.85%
0.75%
0.60%
Actively Managed Fixed Income Only Accounts:
$0 to $500,000
$500,001 to $3,000,000
$3,000,001 to $6,000,000
$6,000,001 to $10,000,000
Greater than $10,000,000
0.85%
0.70%
0.60%
0.50%
0.40%
Concentrated Aggressive Growth Strategy
$0 to $3,000,000
$3,000,001 to $10,000,000
1.50%
1.25%
Fee-Based Variable Annuity:
Greater than $50,000
0.70%
Short-Term Cash Management Accounts:
$0 to $500,000
Greater than $500,000
0.75%
0.60%
Fees are calculated based upon the fee schedule provided at the opening of the initial account.
Client’s asset management accounts are billed monthly in advance. Fees are paid to us directly
from the client’s account by the custodian upon our submission of an invoice. Payment of fees
may result in the liquidation of Client’s securities if there is insufficient cash in the account. The
fee is based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Unless otherwise agreed, advisory fees on
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alternative investments are charged based on their fair market value of the alternative investment
as reported by the issuer, sponsor, or independent auditor of the alternative investment. Where
market value of the alternative investments is not provided by the issuer, we will make a good faith
effort to obtain pricing, either through an independent third party pricing source or through our
own independent determination.
The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Under certain circumstances, clients may pay commissions and trading fees on trades initiated by
us, in addition to other agreed upon fees. Clients may also be charged up to $35.00 per trade as an
administrative fee for Client directed trades. Notwithstanding the foregoing, fees follow the
prevailing fee schedule.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in advance. All Wealth
Management Agreements may be terminated at any time by providing us with 30 days written
notice. If an account is terminated during a month after fees have been deducted, the client will
be refunded a prorated portion based on the number of days the account was open during the
month. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
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termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers. CSP is a fee only registered investment adviser and does not act as an
insurance brokerage or agency and is not otherwise affiliated with any insurance brokerages or
agencies. However, a conflict of interest arises when insurance related business is transacted with
advisory Clients, because certain individual Advisory Affiliates of CSP are independently licensed
to sell insurance products through various carriers. In their capacity as an Insurance Agent, they
may receive commissions or other fees from products sold to Clients. As such, Clients are advised
that they are under no obligation to use any individual associated with CSP for insurance products
or services, and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products, we do not know the actual dollar
amount of any commission payment to an Insurance Agent. Also, because CSP is neither a broker
dealer nor an insurance agency, we do not have the ability to rebate commissions received for the
sale of a product and cannot discount the price of a product to make up for any commission that
may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
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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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
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Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, equity securities, debt securities, certificates of deposit, municipal
securities, U.S. government securities, non-traded securities, and money market funds when
suitable and appropriate. In limited circumstances, and only when suitable and appropriate, we
may offer advice on digital assets and cryptocurrency. Each type of security has its own unique
set of risks associated with it, and it would not be possible to disclose all of the specific risks of
every type of investment in this brochure. In those limited situations where it is suitable and
appropriate to meet a particular Client’s needs, we may also utilize margin to manage an account.
Margin occurs when a client pays for part of a purchase and borrows the rest from the brokerage
firm that custodies the account. If our Clients have any questions regarding the risks associated
with a particular investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
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ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Non-traded Securities can include non-exchanged traded REIT’s, Private Equity, Private Debt,
BDC’s, and Preferred Securities. These types of securities have unique and complex risk profiles
which are differentiated from exchange-traded securities. These investments are characterized by
limited liquidity, high internal fees, and lack of transparency.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies or 1X inverse ETF’s in order to
mitigate market risk when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
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Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
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Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
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PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available free of
charge to any Client or prospective Client upon request by contacting us at (717) 735-0013.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
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sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases, we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Seven Summits
Capital shall not buy or sell securities for his personal portfolio where his decision
is substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP and Seven Summits Capital shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients; however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
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•
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
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More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. The conflicts of interest these types of arrangements present and how we deal with
these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they
have any questions about the foregoing arrangements.
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Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. However, Clients direct us to receive
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proxy materials from the custodian. When we receive those materials we review the information
pertinent to investment decision making, and then dispose of it.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Curt Stauffer, have been the subject of a bankruptcy
petition at any time in the past. We have no financial conditions that would impair our ability to
meet contractual commitments to our Clients.
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Additional Brochure: NINE PINES VENTURES-CSP FORM ADV PART 2A (2026-04-30)
View Document Text
CS Planning Corp dba Nine Pines Ventures
Part 2A of Form ADV – Brochure
CS PLANNING CORP DBA NINE PINES VENTURES
15 Stow Court
San Ramon, CA 94583
(925) 548-3957
April 27, 2026
This Brochure provides information about the qualifications and business practices of CS Planning
Corp. dba Nine Pines Ventures. If you have any questions about the contents of this Brochure or
to obtain answers and additional information, you may contact us at (925) 548-3957 or
ron.moore@ninepinesventures.com. CS Planning Corp is a registered investment adviser with the
United States Securities and Exchange Commission (“SEC”). Registration of an investment
adviser does not imply any level of skill or training. The information in this Brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about CS Planning Corp. is available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp. is 149937.
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Item 2 – Material Changes
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will be included as “Exhibit A” to this Brochure and
will be available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD
number for CS Planning Corp. is 149937. We may further provide other ongoing disclosure
information about material changes as necessary and will further provide you with a new Brochure
as necessary based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting us at (925) 548-3957 or
ron.moore@ninepinesventures.com.
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Item 3 – Table of Contents
Page
Item 1 – Cover Page ......................................................................................................................... i
Item 2 – Material Changes .............................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................ 1
Item 5 – Fees and Compensation .................................................................................................... 2
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 6
Item 7 – Types of Clients ................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................ 6
Item 9 – Disciplinary Information .................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations .................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ... 11
Item 12 – Brokerage Practices ...................................................................................................... 12
Item 13 – Review of Accounts ...................................................................................................... 13
Item 14 – Client Referrals and Other Compensation .................................................................... 13
Item 15 – Custody ......................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................... 14
Item 17 – Voting Client Securities................................................................................................ 15
Item 18 – Financial Information ................................................................................................... 15
Exhibit A – Summary of Material Changes .................................................................................... 1
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Item 4 – Advisory Business
CS Planning Corp (“CSP”) is an SEC registered investment advisory firm located in Portland,
Oregon. We provide fee-only investment supervisory, portfolio management, investment
consulting and financial planning services. The firm has been in business since 2009. CSP is
owned by Christopher K. Hicks, President and Chief Compliance Officer.
Our investment advisory services are coordinated through our network of Advisory Affiliates.
Advisory Affiliates may have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials or client statements. The
Client should understand that the businesses are legal entities of the Advisory Affiliate and not of
our firm, CSP, and the advisory services of the Advisory Affiliate are provided through our firm,
CSP. CSP has the arrangement described above with Ronald D. Moore, a sole proprietor doing
business as Nine Pines Ventures. Ronald D. Moore is an Investment Advisor Representative
associated with CSP, offers investment advisory services exclusively through CSP, and only
utilizes Nine Pines Ventures for marketing purposes. Nine Pines Ventures is not a registered
investment advisor and is not affiliated with CSP.
Our investment approach utilizes broadly diversified portfolios and a systematic strategy to
manage client portfolios. Through our Advisory Affiliates, we help Clients coordinate and
prioritize their financial lives with all aspects of their life goals. Integrating investments across all
individual retirement accounts, taxable accounts, and employee retirement accounts is crucial to
the process. Client input and involvement are critical parts of the financial planning process and
implementation of investment decisions. After Client assets are invested, we continuously monitor
their investments and provide advice related to ongoing financial and investment needs.
Advice and services are tailored to the stated objectives of the Client(s). Our Advisory Affiliates
discuss with the Client critically important information such as the Client’s risk tolerance, time
horizon, and projected future needs, to formulate an investment strategy. This information and
strategy guides us in objectively and suitably managing the Client’s account. Our Advisory
Affiliates meet with Clients as needed to review portfolio performance, discuss current issues, and
re-assess goals and plans.
Our investment recommendations include mutual funds and other investments such as exchange-
traded funds, closed-end funds, and exchange-listed equity securities, certificates of deposit,
municipal securities, U.S. government securities and money market funds when suitable and
appropriate for a Client’s particular situation. If Clients hold other types of investments, we will
advise them on those investments also. Clients may impose restrictions on investing in certain
securities or types of securities. We consider such restrictions when formulating the Client’s
investment strategy. See Item 8 for a description of our investment strategy.
We do not manage Wrap Fee programs.
CS Planning manages $1,960,873,373 of Client assets on a discretionary basis and $0 of Client
assets on a non-discretionary basis. These amounts were calculated as of December 31, 2025.
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Item 5 – Fees and Compensation
We provide investment supervisory, financial planning and investment consulting services to
Clients primarily under the following fee schedule below:
We may also provide standalone consulting or financial planning services to Clients on a fixed fee
or hourly rate. Our fixed fee pricing is quoted for each project, and is based on the scope and
complexity of the project. Our maximum hourly rate is $250 per hour. Consulting or financial
planning services Prior to commencing planning services, Clients enter into a Consulting or
Financial Planning Agreement which sets forth the services being provided and the fees being
charged. Notwithstanding the above, fees are generally negotiable.
Client’s asset management accounts are billed monthly in arrears. Fees are paid to us directly from
the client’s account by the custodian upon our submission of an invoice. Payment of fees may
result in the liquidation of Client’s securities if there is insufficient cash in the account. The fee is
based on the market value of the Client’s account on the last trading day of the prior month.
Market value includes all account values and transaction information as of the end of each month
(not adjusted by any margin debit). To determine value, securities and other instruments traded
on a market for which actual transaction prices are publicly reported are generally valued at the
last reported sale price on the principal market in which they are traded. Mutual Funds are only
valued once per day after the close of the market. Whenever valuation information for specific,
illiquid, foreign, private or other investments is not available through the custodian, our approach
will be to value at zero. We do this in order to not overvalue a position which could potentially
over inflate billing calculations. Alternatively, we may also seek to obtain and document price
information from at least one independent source, whether it be a broker-dealer, bank, pricing
service or other source.
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The monthly fee will be equal to the agreed upon annual rate, multiplied by the market value of
the account for that month. This number is then divided by twelve.
Fees for a partial month at the commencement or termination of an agreement will be prorated
based on the number of days the account was open during the month. Monthly fee adjustments
for additional assets received into an account during a month or for partial withdrawals may also
be provided as negotiated. We may modify the terms of the fee agreement by giving Clients 30
days written notice in advance.
Clients may pay commissions and trading fees on trades initiated by us, in addition to other agreed
upon fees. Clients may also be charged up to $35.00 per trade as an administrative fee for Client
directed trades. Notwithstanding the foregoing, fees are generally negotiable.
Clients may be required to pay other miscellaneous charges or fees directly to the custodian (e.g.
wire fees) as stated in the custodial agreements. Additionally, mutual funds and/or exchange
traded funds have additional internal expenses which generally include a fund management fee,
other fund expenses, and a possible distribution fee. In addition, some funds charge a redemption
fee on shares bought and sold within a short period. Funds describe their expenses in their
prospectuses, summary prospectuses, or product descriptions. Clients are advised that these fees
are separate and additional expenses incurred by the Client. See Item 12 for additional information
on Brokerage Practices.
Our fees include the time necessary to work with Client’s attorney, accountant or other third party
professionals in reaching agreement on financial planning or investment solutions, as well as
assisting those advisors in implementation of all appropriate documents. However, we are not
responsible for attorney, accountant or other third party professional fees charged to Client as a
result of these activities.
In some instances, we may recommend that all or a portion of Client assets be managed by an
unrelated Third Party Asset Manager (“TPAM”) or sub-advisor. These arrangements are more
fully disclosed in Item 10, below.
Generally, Clients pay all Wealth Management Retainer fees monthly in arrears. All Wealth
Management agreements may be terminated at any time by providing us with 30 days written
notice. Upon termination, any fees that have been earned by us but not yet paid will be
immediately due and payable. Clients are also responsible for all applicable charges including,
but not limited to, account administrative fees, account closure fees and all trading costs due to the
termination, including any fees the mutual funds may assess. Upon request, we will provide a
good-faith estimate of these fees.
Payment of fixed fee projects shall be made as agreed by the parties. Hourly rate projects are
generally invoiced by us with payment due by the Client upon receipt of the invoice. We may
estimate the number of hours necessary to complete a project, and we may collect a portion of this
estimate up front and invoice the balance. Upon termination of any hourly or fixed fee project,
any prepaid but unearned fees will be promptly refunded to the Client.
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Certain Advisory Affiliates of CSP are also independently licensed to sell insurance products
through various carriers.
CSP is a fee only registered investment adviser and does not act as an insurance brokerage or
agency and is not otherwise affiliated with any insurance brokerages or agencies. However, a
conflict of interest arises when insurance related business is transacted with advisory Clients,
because certain individual Advisory Affiliates of CSP are independently licensed to sell insurance
products through various carriers. In their capacity as an Insurance Agent, they may receive
commissions or other fees from products sold to Clients. As such, Clients are advised that they are
under no obligation to use any individual associated with CSP for insurance products or services,
and may use any insurance firm or agent they choose.
Clients are also advised that the Wealth Management Retainer fees paid to CSP are separate and
distinct from the commissions earned by any individual in connection with the sale of insurance
or other securities products and CSP does not receive any compensation for products sold by these
Advisory Affiliates.
Because CSP is not involved in the sale of insurance products or securities, we do not know the
actual dollar amount of any commission payment to an Insurance Agent or Registered
Representative. Also, because CSP is neither a broker dealer nor an insurance agency, we do not
have the ability to rebate commissions received for the sale of a product and cannot discount the
price of a product to make up for any commission that may be received from its sale.
Rollover Recommendations
As part of our investment advisory services to you, we may recommend that you roll assets from
your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively,
a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA,
Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your
behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan
Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts. When we provide any of
the foregoing rollover recommendations we are acting as fiduciaries within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code
(“IRC”), as applicable, which are laws governing retirement accounts.
If you elect to roll the assets to an IRA that is subject to our management, we will charge you an
asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a
conflict of interest because it creates a financial incentive for our firm to recommend the rollover
to you (i.e., receipt of additional fee-based compensation). You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover,
you are under no obligation to have the assets in an IRA managed by our firm. Due to the
foregoing conflict of interest, when we make rollover recommendations, we operate under a
special rule that requires us to act in your best interests and not put our interests ahead of yours.
Under this special rule’s provisions, we must:
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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);
avoid misleading statements about conflicts of interest, fees, and investments;
follow policies and procedures designed to ensure that we give advice that is in your best
interests;
charge no more than a reasonable fee for our services; and
give you basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company plan.
Also, current employees can sometimes move assets out of their company plan before they retire
or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the
following options are available, you should consider the costs and benefits of a rollover.
Note that an employee will typically have four options in this situation:
1. leaving the funds in your employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance of
understanding the differences between these types of accounts, we will provide you with a written
explanation of the advantages and disadvantages of both account types and the basis for our belief
that the rollover transaction we recommend is in your best interests.
As an alternative to providing you with a rollover recommendation, we may instead take an
entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive
Bulletin 96-1. Under this approach, our role will be limited only to providing you with general
educational materials regarding the pros and cons of rollover transactions. We will make no
recommendation to you regarding the prospective rollover of your assets and you are advised to
speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this
educational approach, we may provide you with materials discussing some or all of the following
topics: the general pros and cons of rollover transactions; the benefits of retirement plan
participation; the impact of pre-retirement withdrawals on retirement income; the investment
options available inside your Plan Account; and high level discussion of general investment
concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical
returns of certain asset classes, etc.). We may also provide you with questionnaires and/or
interactive investment materials that may provide a means for you to independently determine
your future retirement income needs and to assess the impact of different asset allocations on your
retirement income. You will make the final rollover decision.
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Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees for our services or engage in side-by-side
management.
Item 7 – Types of Clients
We provide investment advice to high net worth individuals, individuals, businesses, pension and
profit sharing plans, foundations, trusts, estates, and charitable organizations. Because each Client
is unique, they must be willing to be involved in the planning and ongoing processes. Such
involvement does not have to be time consuming, however we want our Clients to remain informed
about their overall financial situation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We create broadly diversified portfolios in the worldwide fixed-income and equity markets,
combined with periodic rebalancing. Our Advisory Affiliates create an investment strategy with
each Client, outlining the investment philosophy, management procedures, and long-term goals
for the investor. Portfolio design is tailored to each Client’s risk tolerance and preferences.
Types of Investments
As part of our core investment approach, we offer advice on investments including mutual funds,
exchange-traded funds, closed end funds, equity securities, debt securities, certificates of deposit,
municipal securities, U.S. government securities, and money market funds when suitable and
appropriate. In limited circumstances, and only when suitable and appropriate, we may offer
advice on digital assets and cryptocurrency. Each type of security has its own unique set of risks
associated with it, and it would not be possible to disclose all of the specific risks of every type of
investment in this brochure. In those limited situations where it is suitable and appropriate to meet
a particular Client’s needs, we may also utilize margin to manage an account. Margin occurs when
a client pays for part of a purchase and borrows the rest from the brokerage firm that custodies the
account. If our Clients have any questions regarding the risks associated with a particular
investment, they are encouraged to contact us.
Mutual funds are professionally managed collective investment companies that pool money from
many investors and invest in stocks, bonds, short-term money market instruments, other mutual or
exchange traded funds, other securities or any combination thereof. The fund will have a manager
that trades the fund’s investments in accordance with the fund’s investment objective. While
mutual funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a
particular type of security (i.e., equities) rather than balancing the fund with different types of
securities. Other fund risks include foreign securities and currency risk, emerging markets risk,
small-cap, mid-cap and large-cap risk, trading risk, and turnover risk that can increase fund
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expenses and may decrease fund performance. Brokerage and transactions costs incurred by the
fund will reduce returns.
ETFs are investment funds traded on stock exchanges, much like stocks or equities. An ETF holds
assets such as stocks, commodities, or bonds and trades at approximately the same price as the net
asset value of its underlying assets over the course of the trading day. Most ETFs track an index,
such as the S&P 500. However, some ETFs are fully transparent actively managed funds. Market
risk is, perhaps, the most significant risk associated with ETFs. This risk is defined by the day to
day fluctuations associated with any exchange traded security, where fluctuations occur in part
based on the perception of investors.
Individual equity securities (also known simply as “equities” or “stock”) are assessed for risk in
numerous ways. Price fluctuations and market risk are the most significant risk concerns. As
such, the value of your investment can increase or decrease over time. Furthermore, you should
understand that stock prices can be affected by many factors including, but not limited to, the
overall health of the economy, the health of the market sector or industry of the issuing company,
and national and political events. When investing in stock, it is important to focus on the average
returns achieved over a given period of time, across a well-diversified portfolio.
Individual debt securities (or “bonds”) are typically safer investments than equity securities, but
their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be “called” prior
to maturity. When a bond is called, it may not be possible to replace it with a bond of equal
character paying the same rate of return.
Primarily we invest with a focus on Long Term Purchases, where securities are purchased with the
expectation that the value of those securities will grow over a relatively long period of time,
generally greater than one year. Sometimes we will employ a Short Term Purchase strategy where
securities are purchased with the expectation that they will be sold within a relatively short period
of time, generally less than one year, to take advantage of the securities’ short term price
fluctuations. Short-term trading (in general, selling securities within 30 days of purchasing the
same securities) is not a fundamental part of our overall investment strategy.
In limited situations we may utilize put and call option strategies in order to mitigate market risk
when suitable and appropriate for an individual client’s portfolio.
Digital Asset Risk: From time-to-time, and only where suitable for clients, we may recommend
investments in certain digital currencies, including, without limitation, Bitcoin, Ethereum,
Litecoin, and others (collectively, “Cryptocurrency”). Where exposure to this asset class is
appropriate, we will typically, if not exclusively, obtain such exposure through purchases and sales
of ETFs and other publicly traded securities available through the Fidelity Digital Assets platform.
Investment in Cryptocurrency involves an extremely high degree of risk and is more speculative
than an investment in publicly-traded securities like stocks, bonds, mutual funds, and ETFs. Unlike
the market valuations of publicly-traded stocks and bonds which can be objectively valued on the
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basis of the issuer’s assets, income, debts, liabilities, operations, history of credit-worthiness and
other factors, prices of Cryptocurrency are based entirely on the market’s perception of value and
are subject to rapid changes in market sentiment. Accordingly, Cryptocurrency is subject to an
extremely high level of price volatility, including “flash crashes,” and may lose significant value
in a matter of minutes, hours, or days. It is not uncommon for the value of Cryptocurrency to move
as much as twenty percent (20%) or more in a single day. The ownership of particular
Cryptocurrency is opaque and therefore certain Cryptocurrency may be owned and controlled by
relatively small number of individuals, increasing the potential for fraud and market-manipulation
such as pump-and-dump schemes and other fraudulent criminal schemes.
Evaluation and understanding of the features, functions, and other properties of Cryptocurrency
requires a high level of technical knowledge and sophistication. The market for Cryptocurrency is
in its infancy, is rapidly evolving, and its future is unknown. Governments and central banks do
not create, sponsor, support, back, insure, or control Cryptocurrencies and there is no guarantee of
their future viability as a store of value or a means of exchange. Federal, state, or foreign
governments may restrict the use and exchange of cryptocurrency, and regulation in the United
States is still developing. Cryptocurrency is not legal tender in most jurisdictions, including the
United States. No laws require individuals or businesses to accept Cryptocurrency as a form of
payment and Cryptocurrency does not have any intrinsic value. Its value derives entirely from
market forces of supply and demand.
Cryptocurrency exchanges and other trading venues on which Cryptocurrencies trade are relatively
new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers, or malware. Due to relatively recent launches, most Cryptocurrencies have a
limited trading history, making it difficult for investors to evaluate investments. Generally,
Cryptocurrency transactions are irreversible, such that an improper transfer can only be reversed
by the receiver of the cryptocurrency agreeing to return the cryptocurrency to the sender.
Accordingly, investment in Cryptocurrency is not appropriate for all investors and you should only
invest “risk capital” in such asset class (e.g., funds, the complete and total loss of which, would
have insubstantial effect on your overall financial circumstances and financial goals).
Methods of Analysis
We may use one or more of the following methods of analysis when formulating investment
advice:
Top-Down Global Macro-Economic Analysis involves a big-picture analysis of the prevailing
economic, demographic and social trends followed by a more focused analysis at the country level,
then the industry level and ultimately the specific security level.
Mutual Fund/Exchange Traded Fund Analysis involves qualitative analysis looking at factors such
as the background and experience of the fund manager and/or the fund company (style,
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consistency, risk-adjusted performance, management expenses, average daily trading volume,
etc.).
Fundamental analysis involves the analysis of financial statements, the general financial health of
companies, and/or the analysis of management or competitive advantages. This type of analysis
concentrates on factors that determine a company’s value and expected future earnings. This
strategy would normally encourage equity purchases in stocks that are undervalued or priced below
their perceived value. The risk assumed is that the market will fail to reach expectations of
perceived value.
Investment Risk of Loss
As indicated in the descriptions above, investing in securities involves risk of loss that you should
be prepared to bear. We do not represent or guarantee that our services or methods of analysis can
or will predict future results, successfully identify market tops or bottoms, or insulate Clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future
performance.
Except as may otherwise be provided by law, we are not liable to Clients for:
• Any loss that a Client may suffer by reason of any investment decision made or other action
taken or omitted in good faith by us with that degree of care, skill, prudence and diligence
under the circumstances that a prudent person acting in a fiduciary capacity would use;
• Any loss arising from our adherence to a Client’s instructions, or the disregard of our
recommendations made to a Client; or
• Any act or failure to act by a custodian or other third party to a Client’s account.
It is the responsibility of the Client to give us complete information and to notify us of any changes
in financial circumstances or goals.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of or the integrity of the firm’s
management. CS Planning Corp. has no information applicable to this Item.
Nine Pines Ventures Principal, Ronald D. Moore, has never been subject to any legal or
disciplinary proceedings which would be considered material (or otherwise) to a Client’s
evaluation of him or any of the services he provides. Nine Pines Ventures is an assumed business
name registered by Ronald D. Moore. Ronald D. Moore is an Investment Advisor Representative
registered with CSP effective November 2025.
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Item 10 – Other Financial Industry Activities and Affiliations
Affiliated Entities:
CSP is affiliated through common ownership and control with Palouse Capital Management, Inc.
(“PCM”). PCM and CSP are under common control of Christopher K. Hicks who is considered a
control person of each firm because he holds more than 25% ownership interest in each firm.
PCM is an investment advisor registered with the Securities and Exchange Commission. PCM
offers investment advisory services through numerous Advisory Affiliates to the firm.
Outside Business Activities of Advisory Affiliates:
As disclosed in Item 5, above, Advisory Affiliates of CSP may also be independently licensed as
insurance agents with other agencies. Affiliates may recommend the purchase and sale of certain
insurance products to Clients. As a fiduciary, the Affiliate must act primarily for the benefit of
CSP Clients and will only transact insurance related business with Clients when the products are
fully disclosed, suitable, and appropriate to fit their needs, and in order to simplify the
implementation of various wealth management strategies.
Broker-Dealer Affiliation
Certain Advisory Affiliates of CSP are Dually Registered Persons of broker dealer firms
unaffiliated with CSP. In their separate capacity as registered representatives, these Advisor
Affiliates will typically receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation
provided by Advisory Affiliates of CSP.
Promotor Relationships
We may enter into promoter agreements with individuals or other registered investment advisors.
Promoter arrangements and requirements are more fully described in Item 14 (“Client Referrals
and Other Compensation”), below. We do not believe this arrangement creates any conflicts of
interest with any of our Clients.
Other Investment Managers:
On occasion, we may recommend and engage unaffiliated Third Party Asset Managers (TPAM)
or sub-advisors who provide customized investment portfolio management services. These
services may include the construction of investment portfolios, execution of securities purchase
and sale transactions, and portfolio administration, including tracking of and reporting on portfolio
performance and investment results.
We are authorized by our Clients to share non-public, personal information with TPAMs or sub-
advisors for the purpose of managing their portfolios. However we require any TPAM or sub-
advisor to execute a confidentiality agreement and not share non-public personal information with
any unauthorized person or entity.
Clients are generally required to enter into a separate advisory agreement with any TPAM or sub-
advisor. The use of TPAMs or sub-advisors may cause Clients to incur additional fees. If
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applicable, any additional fees will be fully disclosed to Clients in a separate agreement with the
TPAM or sub-advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading
We have a Code of Ethics which all employees are required to follow. The Code of Ethics outlines
our high standard of business conduct, and fiduciary duty to Clients. The Code of Ethics includes
provisions relating to the confidentiality of Client information, a prohibition on insider trading,
personal securities trading procedures, improper use of Firm property, and diversion of investment
and business opportunities, among other things. A copy of the code of ethics is available to any
Client or prospective Client upon request by contacting us at (925) 548-3957. Brochures are
provided free of charge.
We or individuals associated with our firm may buy and sell some of the same securities for their
own account that we buy and sell for Clients. When appropriate we will purchase or sell securities
for Clients before purchasing the same for our account or allowing representatives to purchase or
sell the same for their own account. However, we do allow the accounts of employees to be
included in block trading alongside the accounts of Clients. In some cases we or our
representatives may buy or sell securities for our own account for reasons not related to the
strategies adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or purchased
for Clients. The Code of Ethics is designed to assure that the personal securities transactions will
not interfere with decisions made in the best interest of advisory Clients while at the same time,
allowing employees to invest their own accounts.
In the event a material conflict of interest not already discussed in this document should arise, we
will disclose to our advisory Clients any material conflict of interest relating to us, our
representatives, or any of our employees which could reasonably be expected to impair the
rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the following
restrictions to ensure our fiduciary responsibilities:
•
A director, officer, associated person, or employee of CSP and Nine Pines Ventures
shall not buy or sell securities for his personal portfolio where his decision is
substantially derived, in whole or in part, by reason of his employment unless the
information is also available to the investing public on reasonable inquiry. No
person associated with CSP and Nine Pines Ventures shall prefer his or her own
interest to that of the advisory Client.
•
We maintain a list of all securities holdings for the firm and for anyone associated
with its advisory practice who has access to advisory recommendations. An
appropriate officer reviews these holdings on a regular basis.
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•
Any individual not in observance of the above may be subject to discipline up to
and including termination.
Item 12 – Brokerage Practices
Our Clients’ assets are held by independent third-party qualified custodians. We do recommend
certain custodians to Clients, however, Clients are not obligated to use any particular custodian
recommended by us. We reserve the right to decline acceptance of any Client account for which
the Client directs the use of a particular custodian if we believe that this choice would hinder either
our fiduciary duty to the Client or our ability to service the account.
In recommending custodians, we will comply with its fiduciary duty to seek best execution and
with the Securities Exchange Act of 1934. We will take into account such relevant factors as:
•
•
•
•
Price;
The custodian’s facilities, reliability and financial responsibility;
The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order;
The research and related brokerage services provided by such custodian to us,
notwithstanding that the account may not be the direct or exclusive beneficiary of
such services; and
Any other factors that we consider to be relevant.
•
We may aggregate trades for Clients. The allocations of a particular security will be determined
by us before the trade is placed with the broker. When practical, Client trades in the same security
will be bunched in a single order (a “block”) in an effort to obtain best execution at the best security
price available. When employing a block trade:
•
•
•
•
•
We will make reasonable efforts to attempt to fill Client orders by day-end.
If the block order is not filled by day-end, we will allocate shares executed to
underlying accounts on a pro rata basis, adjusted as necessary to keep Client
transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed;
All participants receiving securities from the block trade will receive the average
price.
Multiple blocks may be executed within a single day. However, only trades
executed within the block on the single day may be combined for purposes of
calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or all of
our Clients, we may deviate from this policy.
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Finally, it is our policy to minimize the occurrence of trade errors. Should any trade errors which
are attributable to CSP occur, we shall take any steps necessary to put the Client in the position it
should have been as if the trade error never occurred. In the event we determine that a bona fide
trade error has occurred which is attributable to CSP, we will correct the trade error using funds
from our error account. Depending on the internal trade error policies and procedures of the
particular custodian, our error account may be debited if the correction results in a loss. Likewise,
our error account may be credited if the correction results in a gain. This situation creates a conflict
of interest as CSP has an incentive to recommend particular custodians over others that may not
have a similar policy.
Item 13 – Review of Accounts
Client accounts are formally reviewed at least annually. Accounts are reviewed in the context of
each Client’s stated investment objectives and guidelines.
We have a number of Advisory Affiliates who are assigned as the primary representative to a
particular Client’s account. The Advisory Affiliate assigned to a particular Client’s account will
be responsible for the periodic reviews to that account. Clients will be provided the Supplemental
Brochure (Form ADV Part 2B) of any Advisory Affiliate providing advice related to their account.
More frequent reviews may be triggered by a number of reasons including: a change in Client’s
investment objectives; tax considerations; large deposits or withdrawals; large sales or purchases;
or changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of their
accounts generally on a monthly basis, but in any event, no less than quarterly. Advisor Affiliates
may also provide Clients with periodic written reports summarizing the account activity and
performance. Along with these reports, we discuss the asset allocation of the portfolio compared
to the portfolio target allocations.
Financial Planning Clients will typically receive a completed written financial plan unless
otherwise agreed at the start of the engagement. Dependent upon the level and scope of Financial
Planning services being provided, Advisor Affiliates will meet with clients at least twice per year
or more often as a major life event occurs.
Item 14 – Client Referrals and Other Compensation
As disclosed under Item 12 (above), we (or our Affiliates) may receive “soft dollars” from certain
custodians. Further, The conflicts of interest these types of arrangements present and how we deal
with these conflicts are described in detail under Item 12, above.
As disclosed under Items 5 and 10 above, representatives of CSP may also be licensed to sell
insurance. The conflicts of interest these arrangements present and how we deal with these
conflicts are described in detail under Item 5, above.
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Promoter Relationships
Certain Advisory Affiliates of CSP may enter into promoter agreements that pay cash
compensation to third-party intermediaries in exchange for their promotion, referral, and
endorsement of our advisory services to prospective clients. The cash compensation paid to such
promoters may take the form of a retainer, a flat advertising fee, a fee per referral, and/or a
percentage of the advisory fees we collect from referred client accounts. These fees may be paid
to the promoter on a one-time or recurring basis. Unless otherwise explicitly disclosed in writing
to the client, the cash compensation paid to a promoter will be borne entirely by CSP and the
Advisory Affiliate. Referred clients do not pay any additional or increased advisory fees as a result
of having been referred to our firm by a paid third-party promoter.
We will only engage third-party promoters in accordance with the requirements of the SEC’s
“marketing rule” (SEC Rule 206(4)-1), promulgated under the Investment Advisers Act of 1940.
Any promoters engaged for this purpose will disclose to you at or reasonably prior to the time of
their referral or endorsement of CSP (i) that they will receive compensation from CSP as a result
of their endorsement of our firm; (ii) a description of the material terms of the compensation they
will receive; and (iii) a brief statement discussing the conflicts of interest arising out of the
compensation arrangement and/or the relationship between CSP and the third-party promoter.
Clients referred to our firm by a third-party promoter are encouraged to inquire with us if they have
any questions about the foregoing arrangements.
Item 15 – Custody
We have the ability to debit fees, and we may have the ability to disburse or transfer certain client
funds pursuant to Standing Letters of Authorization executed by Clients. We do not otherwise
have custody of the assets in the account.
We shall have no liability to a Client for any loss or other harm to any property in the account,
including any harm to any property in the account resulting from the insolvency of the custodian
or any acts of the agents or employees of the custodian and whether or not the full amount or such
loss is covered by the Securities Investor Protection Corporation (“SIPC”) or any other insurance
which may be carried by the custodian. The Client understands that SIPC provides only limited
protection for the loss of property held by a custodian.
Clients receive standard account statements from the custodian of their accounts generally on a
monthly basis, but in any event, no less than quarterly. Our Advisory Affiliate’s may also provide
Clients with periodic written reports summarizing the account activity and performance. We urge
all Clients to carefully review statements from the custodian and compare these to any reports that
we may provide to you. Our reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Generally, Clients grant us and our Advisory Affiliates ongoing and continuous discretionary
authority to execute investment recommendations in accordance with an agreed upon investment
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strategy or plan without the Client’s prior approval of each specific transaction. Under
discretionary authority, Client allows us to purchase and sell securities and instruments in their
account(s), arrange for delivery and payment in connection with the foregoing, select and retain
sub-advisors, and act on behalf of the Client in matters necessary or incidental to the handling of
the account, including monitoring certain assets. The only restrictions on this discretionary
authority are those set by the Client on a case by case basis.
In limited circumstances, an Advisory Affiliate will not have discretionary authority to determine
or make changes to a Client’s stated investment strategy without the Client’s prior
approval. However, CSP will still have complete discretion to implement its trading strategies to
update the portfolio allocation within that stated investment strategy, without the Client’s prior
approval. In this type of situation, CSP will require authorization from the Client before making
any changes to a Client’s investment strategy.
CSP will act in accordance with any agreed upon investment strategy, regardless of whether
authority is discretionary or non-discretionary. Further, we make it a practice to question Clients
to determine if there are any limitations to our authority on such matters.
Item 17 – Voting Client Securities
We do not have authority to vote and therefore do not vote Client securities. Additionally, we do
not provide advice to Clients on how the Client should vote. Clients will receive proxies and other
solicitations directly from the custodian or transfer agent. If any proxy materials are received on
behalf of a Client, they will be sent directly to the Client who remains responsible to vote the
proxy.
Item 18 – Financial Information
A portion of hourly rate or fixed fee projects are generally required to be paid in advance, however
under no circumstances will we retain more than $1,200.00, more than six months in advance from
any Client.
We do have discretionary authority over Client funds or securities, but we have no financial
commitments that would impair our ability to meet contractual and fiduciary commitments to
Clients.
Neither CSP, nor any of the principals, nor Ronald D. Moore, have been the subject of a bankruptcy
petition at any time in the past. We have no financial conditions that would impair our ability to
meet contractual commitments to our Clients.
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Exhibit A – Summary of Material Changes
This item discusses only specific material changes that have been made to our Brochure since our
prior annual amendment. Since our initial Brochure filed November 14, 2025 we report the
following material changes:
Item 10, Item 12 and Item 14 have been updated to reflect that The H Group, Inc., The
H Group Washington, Inc., and FocusPoint Solutions, Inc. are no longer affiliated
entities of CSP under the common control of Christopher K. Hicks.
We will ensure that when required, all current clients will receive a Summary of Material Changes
to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. When
required, a Summary of Material Changes will also be included with our Brochure on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CS Planning Corp.
is #149937. The Summary of Material Changes is listed as “Exhibit A” to our Brochure. We may
further provide other ongoing disclosure information about material changes as necessary and will
further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, our Brochure may be requested by contacting us at (925) 548-3957 or
ron.moore@ninepinesventures.com. Our Brochure is provided free of charge.
Exh. A