View Document Text
CX Institutional, LLC
ADV Part 2A, Firm Brochure
Dated: October 14, 2025
Contact: Kyle B. Osting, Chief Compliance Officer
200 East 7th Street
Auburn, IN 46706
260-927-1830
http://www.credentwealth.com
kyle.osting@credentwealth.com
This brochure provides information about the qualifications and business practices of CX Institutional, LLC.
If you have any questions about the contents of this brochure, please contact Kyle B. Osting at 260- 927-
1830 or kyle.osting@credentwealth.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities
authority.
Additional information about CX Institutional, LLC is also available on at the SEC’s website at:
www.adviserinfo.sec.gov.
References herein to CX Institutional, LLC as a “registered investment adviser” or any reference to being
“registered” does not imply a certain level of skill or training
Item 2 – Material Changes
There have been no material changes made to our Brochure since our last Annual Amendment filing made
on February 20, 2025.
2
CX Institutional
ADV Part 2A, Firm Brochure
Item 3 – Table of Contents
Item 1 – Cover Page ....................................................................................................................................... 1
Item 2 – Material Changes .............................................................................................................................. 2
Item 3 – Table of Contents .............................................................................................................................. 3
Item 4 – Advisory Business ............................................................................................................................. 4
Item 5 – Fees and Compensation ................................................................................................................. 12
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 15
Item 7 – Types of Clients .............................................................................................................................. 15
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 15
Item 9 – Disciplinary Information ................................................................................................................... 20
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................ 20
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ................................. 21
Item 12 – Brokerage Practices ...................................................................................................................... 22
Item 13 – Review of Accounts....................................................................................................................... 25
Item 14 – Client Referrals and Other Compensation .................................................................................... 25
Item 15 – Custody ......................................................................................................................................... 26
Item 16 – Investment Discretion ................................................................................................................... 26
Item 17 – Voting Client Securities ................................................................................................................. 27
Item 18 – Financial Information ..................................................................................................................... 27
3
CX Institutional
ADV Part 2A, Firm Brochure
Item 4 – Advisory Business
CX Institutional, LLC (“CX Institutional”) was formed in 2018 in the state of Delaware through the
combination of two existing SEC-Registered Investment Advisers, Hefty Wealth Partners, Inc. established
in 2010 (“HWP”) and Oak Point Wealth Management, LLC established in 2010 (“Oak”). CX Institutional
succeeded to the Registration of HWP and became an SEC-Registered Investment Adviser on March 1,
2018. CX Institutional is owned by Credent Holdings, LLC, which in turn is principally controlled by Hefty
Wealth Partners.
CX Institutional’s main focus is to offer investment portfolios to its clients (individuals, high net worth
individuals, charitable organizations and business entities), on a discretionary and non-discretionary wrap
or non-wrap fee-only basis. In addition, CX Institutional provides financial planning and consulting services.
It is possible that different investment advisor representatives may charge different fees for providing the
same or similar services to clients. The specific level of services you will receive and the fees you will be
charged will be specified in your advisory services agreement. Before engaging CX Institutional to provide
asset management services, clients are required to enter into an agreement with CX Institutional setting
forth the terms and conditions of the engagement (including termination), describing the scope of the
services to be provided, and the fee that is due from the client.
Under each Program, CX Institutional provides investment management services specific to the needs of
each client. Before providing investment management services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, CX Institutional will allocate investment assets
consistent with the client’s designated investment objective(s). CX Institutional primarily allocates client
investment assets among various individual equity (stocks), debt (bonds) and fixed income securities,
structured products, and/or exchange traded funds (“ETFs”). Once allocated, CX Institutional provides
ongoing monitoring and review of account performance, asset allocation and client investment objectives.
Asset Management Services – CX Multi-Strategy Platform Program
CX Institutional provides investment management services on a discretionary and non-discretionary wrap
or non-wrap fee-only basis through our CX Multi-Strategy Platform Program (the “Program”). Program
accounts are established at LPL Financial, a FINRA and SIPC member broker-dealer/custodian and SEC
registered investment advisor (“LPL”) and/or Charles Schwab & Co. Inc. (“Schwab”).
The Program’s discretionary and non-discretionary basis allows for allocating to numerous investments,
including but not limited to, individual equities, individual bonds, open-end mutual funds, closed-end mutual
funds, exchange traded funds (ETFs), and exchange traded notes (ETNs). Asset allocation guidelines
within the Program will be pursuant to the client’s investment objective and may entail an allocation to
multiple strategies within an account. Client understands that achievement of the stated investment
objective is a long-term goal.
Additional deposits in the Program will be invested in securities consistent with the current target allocation
for the model portfolio, but such deposits (or a portion thereof) may remain in cash until certain conditions
are met related to trade size and position deviation from the target allocation. CX Institutional may
accommodate requests for all or a portion of the assets in the account(s) to remain unallocated and
allocated to cash for a period of time.
4
CX Institutional
ADV Part 2A, Firm Brochure
Liquidation requests in connection with withdrawals, and changes to the model portfolios or investment
objective selected may take up to 5 business days to process, and, in certain circumstances, may take
longer.
If client advises CX Institutional that restrictions be placed on certain assets while account(s) are invested
in the Program, CX Institutional will not manage those assets in accordance with the Program’s guidelines.
Those “client restricted” assets will be segregated within an account with other Program assets. However,
CX Institutional will advise and bill an advisory fee on those “client restricted assets” maintained outside of
Program models.
CX Institutional coordinates the trades among the various securities and model portfolio(s) of the
account(s). After the account(s) is opened, and upon deposit of funds or securities by the client, CX
Institutional will invest the assets based on the model portfolio(s) selected. It generally will take up to 5
business days from the date the account(s) is fully funded for all assets to be fully allocated across the
model portfolio(s). In certain cases, it may take longer to allocate assets, for example, depending on the
ability of CX Institutional to liquidate the securities transferred into the account(s).
In the event that the client transfers assets to CX Institutional that are not publicly traded, or when liquidity
is minimal, costs for the liquidation of such assets will be borne by the client and will not be incurred by CX
Institutional. The costs associated with liquidation will be determined by the custodian.
If client transfers into the Program with a previously purchased mutual fund, and there is an applicable
contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the
account is invested in a mutual fund that charges a fee for a redemption made within a specific time period
after the investment, client will be charged a redemption fee.
Wrap Fee Program
The services offered and the corresponding terms and conditions pertaining to the Program are discussed
in the ADV Part 2A, Appendix 1, and Wrap Fee Program Brochure, a copy of which is presented to all
prospective Program participants. Under the Program, CX Institutional is able to offer participants
discretionary and non-discretionary asset management services for a single specified annual Program fee,
inclusive of trade execution, custody, reporting, and investment management fees. All prospective Program
participants are encouraged to review and ask any questions about both this Brochure and the Wrap Fee
Program Brochure before choosing to participate in the Program.
Wrap Program-Conflict of Interest: As discussed above, CX Institutional provides services on a wrap fee
basis as a wrap program sponsor. Under CX Institutional’s wrap offerings, the client generally receives
investment advisory services, the execution of securities brokerage transactions, as well as custody and
reporting services via the account custodian, for a single specified fee. As noted below, CX Institutional
charges other fees, based upon the number of accounts maintained by the client, which are separate and
in addition to CX Institutional’s wrap fee. Participation in a wrap program may cost the client more or less
than purchasing such services separately. The terms and conditions of a wrap program engagement are
more fully discussed in CX Institutional’s Wrap Fee Program Brochure.
Because wrap program transaction fees and/or commissions are being paid by CX Institutional to the
account custodian/broker-dealer, CX Institutional has an economic incentive to maximize its compensation
by seeking to minimize the number of trades in the client's account. See separate Wrap Fee Program
Brochure.
5
CX Institutional
ADV Part 2A, Firm Brochure
Client Experience Program
The Client Experience Program makes available multiple offerings for individuals, high net worth individuals,
charitable organizations and business entities on a discretionary and non-discretionary wrap or non-wrap
fee-only basis. Under the Client Experience Program, CX Institutional is able to offer participants specific
discretionary and non-discretionary asset management portfolios that are offered under the CX Multi-
Strategy Platform Program in combination with specific Financial Planning Services. In addition, specific
client service deliverables are paired with each Client Experience offering. These combinations of
investments, financial planning, and services are intended to deliver the appropriate solutions tailored to
the individual needs of clients. The specific level of services you will receive and the fees you will be
charged will be specified in your investment advisory agreement.
Non-Discretionary Investment Management Services
The client can determine to engage CX Institutional to provide non-discretionary investment advisory
services on a wrap and non-wrap fee-only basis. Clients that determine to engage CX Institutional on a
non-discretionary investment advisory basis must be willing to accept that CX Institutional cannot affect any
account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore,
in the event that CX Institutional would like to make a transaction for a client’s account, and client is
unavailable, CX Institutional will be unable to effect the account transaction (as it would for its discretionary
clients) without first obtaining the client’s consent.
Financial Planning and Consulting Services
Financial planning and consulting services help clients to identify long-term financial goals intended to be
achieved through investments, tax planning, asset allocation, risk management, retirement planning, and
other areas. CX Institutional provides financial planning and consulting services, which focus upon a client’s
overall financial situation. Before engaging CX Institutional to provide financial planning or consulting
services, clients may be required to enter into a Financial Planning and Consulting Agreement with CX
Institutional setting forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the portion of the fee that is due from the client before CX
Institutional commences services. If requested by the client, CX Institutional may recommend the services
of other professionals for implementation purposes. The client is under no obligation to engage the services
of any such recommended professional.
The client retains absolute discretion over all such implementation decisions and is free to accept or reject
any recommendation from CX Institutional.
If the client engages any such recommended unaffiliated professional, and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent,
etc.), and not CX Institutional, shall be responsible for the quality and competency of the services provided.
Each client is advised that it remains the client’s responsibility to promptly notify CX Institutional if there is
ever any change in client’s financial situation or investment objectives for the purpose of reviewing,
evaluating or revising CX Institutional’s previous recommendations and/or services.
Retirement Plan Consulting
CX Institutional also provides non-discretionary pension consulting services, pursuant to which it assists
sponsors of self-directed retirement plans with the selection or monitoring of investment alternatives
(generally open-end mutual funds) from which plan participants shall choose in self-directing the
investments for their individual plan retirement accounts. In addition, to the extent requested by the plan
sponsor, CX Institutional shall also provide participant education designed to assist participants in
6
CX Institutional
ADV Part 2A, Firm Brochure
identifying the appropriate investment strategy for their retirement plan accounts. The terms and conditions
of the engagement shall generally be set forth in a Retirement Plan Consulting Agreement between CX
Institutional and the plan sponsor.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated
above, to the extent requested by a client, CX Institutional may provide financial planning and related
consulting services regarding non-investment related matters, such as estate planning, tax planning,
insurance, etc. CX Institutional does not serve as an attorney or accountant, and no portion of its services
should be construed as legal or accounting services. Accordingly, CX Institutional does not prepare estate
planning documents or tax returns. To the extent requested by a client, CX Institutional may recommend
the services of other professionals for certain non-investment implementation purpose (i.e., attorneys,
accountants, insurance agents, etc.). The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such implementation decisions
and is free to accept or reject any recommendation from CX Institutional and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to
such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent,
etc.), and not CX Institutional, shall be responsible for the quality and competency of the services provided.
Retirement Rollovers-Potential for Conflict of Interest. A client or prospective client leaving an employer
typically has four options regarding an existing retirement plan (and may engage in a combination of these
options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new
employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in
adverse tax consequences). If CX Institutional recommends that a client roll over their retirement plan
assets into an account to be managed by CX Institutional, such a recommendation creates a conflict of
interest if CX Institutional will earn new (or increase its current) compensation as a result of the rollover. If
CX Institutional provides a recommendation as to whether a client should engage in a rollover or not
(whether it is from an employer’s plan or an existing IRA), CX Institutional is acting as a fiduciary within the
meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. No client is under any obligation to roll over
retirement plan assets to an account managed by CX Institutional, whether it is from an employer’s plan or
an existing IRA.
Fee Differentials. As indicated above, CX Institutional shall receive a Program Fee based upon a
percentage (%) of the market value of the assets placed under management (between negotiable and
2.0%) (the “Program Fee” shall consist of an investment advisory fee and strategy fee). However, fees shall
vary depending upon various objective and subjective factors, including but not limited to: the representative
assigned to the account, the amount of assets to be invested, the complexity of the engagement, the
anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated
future additional assets, and negotiations with the client.
Because CX Institutional shall generally price its advisory services based upon various objective and
subjective factors, our clients could pay diverse fees based upon a combination of factors, including but not
limited to the market value of their assets, the complexity of the engagement, the level and scope of the
overall investment advisory services to be rendered, and negotiations. Similarly situated clients could pay
diverse fees, and the services to be provided by CX Institutional to any particular client could be available
7
CX Institutional
ADV Part 2A, Firm Brochure
from other advisers at lower fees.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available
directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by
CX Institutional independent of engaging CX Institutional as an Investment Advisor. However, if a
prospective client determines to do so, he/she will not receive the CX Institutional’s initial and ongoing
investment advisory services.
In addition to CX Institutional’s Program Fee described below, and transaction and/or custodial fees
discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases,
charges imposed at the fund level (e.g. management fees and other fund expenses).
Unaffiliated Private Investment Funds. CX Institutional may recommend that certain qualified clients
consider an investment in unaffiliated private investment funds. CX Institutional’s role relative to the private
investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services.
CX Institutional’s clients are under absolutely no obligation to consider or make an investment in a private
investment fund(s).
Private investment funds generally involve various risk factors, including, but not limited to, potential for
complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is
set forth in each fund’s offering documents, which will be provided to each client for review and
consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement,
pursuant to which the client shall establish that he/she is qualified for investment in the fund, and
acknowledges and accepts the various risk factors that are associated with such an investment.
Fund Valuation: In the event that CX Institutional references private investment funds owned by the client
on any supplemental account reports prepared by CX Institutional, the value(s) for all private investment
funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. However, if
subsequent to purchase, the fund has not provided an updated valuation, the valuation shall reflect the
initial purchase price. If subsequent to purchase, the fund provides an updated valuation, then the statement
will reflect that updated value. The updated value will continue to be reflected on the report until the fund
provides a further updated value.
As result of the valuation process, if the valuation reflects initial purchase price or an updated value
subsequent to purchase price, the current value(s) of an investor’s fund holding(s) could be significantly
more or less than the value reflected on the report. Unless otherwise indicated, CX Institutional shall
calculate its fee based upon the latest value provided by the fund sponsor.
Portfolio Activity. CX Institutional has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, CX Institutional will review client portfolios on an
ongoing basis to determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or
a change in the client’s investment objective. Based upon these factors, there may be extended periods of
time when CX Institutional determines that changes to a client’s portfolio are neither necessary nor prudent.
Of course, as indicated below, there can be no assurance that investment decisions made by CX
Institutional will be profitable or equal any specific performance level(s).
Structured Notes. CX Institutional may purchase Structured Notes for client accounts. A Structured Note
is a financial instrument that combines two elements, a debt security and exposure to an underlying asset
8
CX Institutional
ADV Part 2A, Firm Brochure
or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note
is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is
this latter feature that makes structured products unique, as the payout can be used to provide some degree
of principal protection, leveraged returns (but usually with some cap on the maximum return), and be
tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity
constraints, such that the sale thereof before maturity will be limited and any sale before the maturity date
could result in a substantial loss. There can be no assurance that the Structured Notes investment will be
profitable, equal any historical performance level(s), or prove successful.
If the issuer of the Structured Note defaults, the entire value of the investment could be lost.
eMoney Advisor Platform. CX Institutional may provide its clients with access to an online platform hosted
by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view their complete asset
allocation, including those assets that CX Institutional does not manage (the “Excluded Assets”). CX
Institutional does not provide investment management, monitoring, or implementation services for the
Excluded Assets. Therefore, CX Institutional shall not be responsible for the investment performance of the
Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the
Excluded Assets, and not CX Institutional, shall be exclusively responsible for such investment
performance. The client may choose to engage CX Institutional to manage some or all of the Excluded
Assets pursuant to the terms and conditions of an Investment Advisory Agreement between CX Institutional
and the client.
The eMoney platform also provides access to other types of information, including financial planning
concepts, which should not, in any manner whatsoever, be construed as services, advice, or
recommendations provided by CX Institutional. Finally, CX Institutional shall not be held responsible for any
adverse results a client may experience if the client engages in financial planning or other functions
available on the eMoney platform without CX Institutional’s assistance or oversight.
Pontera Platform: CX Institutional uses an investment platform made available by Pontera Solutions, Inc.
(“Pontera”), a third-party online platform, to assist with management of clients’ “held-away” accounts,
including 401(k)s, 403(b)s, annuities, and 529 education savings plans. The Pontera platform permits
advisers to manage held-away assets without having to reflect that it has custody of such assets on Part 1
of Form ADV. The advisory fee charged by CX Institutional for the management of held-away assets is
established in the client’s Investment Advisory Agreement. Pontera charges CX Institutional an annual fee
based upon the percentage of assets managed in the held- away accounts. Other than CX Institutional’s
advisory fee, clients do not pay any additional fee to Pontera or to CX Institutional in connection with the
use of the Pontera platform.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation
of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence
process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments:
Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in
which a company manages relationships with its employees, customers, and the communities in which it
operates); and Governance (i.e., company management considerations). The number of companies that
meet an acceptable ESG mandate can be limited when compared to those that do not, and could
underperform broad market indices. Investors must accept these limitations, including potential for
underperformance. As with any type of investment (including any investment and/or investment strategies
recommended and/or undertaken by CX Institutional), there can be no assurance that investment in ESG
securities or funds will be profitable, or prove successful. CX Institutional generally relies on the
assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account
9
CX Institutional
ADV Part 2A, Firm Brochure
manager to determine that the fund’s or portfolio’s underlying company securities meet a socially
responsible mandate.
its asset allocation strategies
for diversification purposes.
Investment
Bitcoin, Cryptocurrency, and Digital Assets. For clients who want exposure to Bitcoin, cryptocurrencies, or
digital assets, CX Institutional, will advise the client to consider a potential investment in corresponding
exchange traded securities, or an allocation to separate account managers and/or private funds that provide
cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that can be used for various
purposes, including transactions, decentralized applications, and speculative investments. Most digital
assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and
validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities,
cryptocurrencies generally operate without centralized control, and their value is determined by market
supply and demand. While regulatory oversight of digital assets has evolved significantly since their
inception, they remain subject to variable regulatory treatment globally, which may impact their risk profile
and liquidity. Bitcoin, cryptocurrency, and digital asset investments are speculative and subject to extreme
price volatility, liquidity constraints, and the potential for total loss of principal. The speculative nature of
digital assets notwithstanding, CX Institutional may (but is not obligated to) utilize crypto exposure in one
or more of
in Bitcoin,
cryptocurrencies, or digital assets carry the potential for liquidity constraints, extreme price volatility,
regulatory risk, technological risk, security and custody risk, and complete loss of principal.
Clients can notify CX Institutional, in writing, to exclude cryptocurrency exposure from their accounts.
Absent CX Institutional’s receipt of such written notice from the client, CX Institutional may (but is not
obligated to) utilize cryptocurrency as part of its asset allocation strategies for client accounts.
Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for
liquidity constraints, extreme price volatility and complete loss of principal.
Cash Positions. CX Institutional continues to treat cash as an asset class. As such, unless determined to
the contrary by CX Institutional, all cash positions (money markets, etc.) shall continue to be included as
part of assets under management for purposes of calculating CX Institutional’s advisory fee. At any specific
point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee
that such anticipated market conditions/events will occur), CX Institutional may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market
advances. Depending upon current yields, at any point in time, CX Institutional’s advisory fee could exceed
the interest paid by the client’s money market fund.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other money
market accounts. When this occurs, to help mitigate the corresponding yield dispersion CX Institutional
shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money
market fund (or other type security) available on the custodian’s platform, unless CX Institutional reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase
additional investments for the client’s account. Exceptions and/or modifications can and will occur with
respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount
of dispersion between the sweep account and a money market fund, the size of the cash balance, an
indication from the client of an imminent need for such cash, or the client has a demonstrated history of
writing checks from the account.
10
CX Institutional
ADV Part 2A, Firm Brochure
The above does not apply to the cash component maintained within a CX Institutional actively managed
investment strategy (the cash balances for which shall generally remain in the custodian designated cash
sweep account), an indication from the client of a need for access to such cash, assets allocated to an
unaffiliated investment manager and cash balances maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions and
corresponding transactions for cash balances maintained in any CX Institutional unmanaged accounts.
Sub-Advisor Arrangement. CX Institutional is affiliated with CXI Advisors, a Registered Investment Adviser.
CXI Advisors has engaged CX Institutional to provide investment management services on a sub-advisory
basis according to the terms and conditions of a written Sub-Advisory Agreement. With respect to its sub-
advisory services, CXI Advisors will maintain both the initial and ongoing day-to-day relationship with the
client, including initial and ongoing determination of client suitability for the client’s designated investment
strategies and/or programs.
Client Obligations. In performing its services, CX Institutional shall not be required to verify any information
received from the client or from the client’s other professionals, and is expressly authorized to rely thereon.
Moreover, each client is advised that it remains their responsibility to promptly notify CX Institutional if there
is ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising CX Institutional’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that CX Institutional and its third-
party service providers use to provide services to CX Institutional’s clients employ various controls that are
designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could
cause significant interruptions in CX Institutional’s operations and/or result in the unauthorized acquisition
or use of clients’ confidential or non-public personal information.
In accordance with Regulation S-P, CX Institutional is committed to protecting the privacy and security of
its clients' non-public personal information by implementing appropriate administrative, technical, and
physical safeguards. CX Institutional has established processes to mitigate the risks of cybersecurity
incidents, including the requirement to restrict access to such sensitive data and to monitor its systems for
potential breaches. Clients and CX Institutional are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur financial losses and/or other adverse consequences.
Although CX Institutional has established processes to reduce the risk of cybersecurity incidents, there is
no guarantee that these efforts will always be successful, especially considering that CX Institutional does
not control the cybersecurity measures and policies employed by third-party service providers, issuers of
securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges,
and other financial market operators and providers. In compliance with Regulation S-P, CX Institutional will
notify clients in the event of a data breach involving their non-public personal information as required by
applicable state and federal laws.
Consultant to Third-Party. CX Institutional serves as a consultant with respect to certain retail clients of an
unaffiliated broker-dealer. With respect to this engagement, the unaffiliated broker-dealer maintains both
the initial and ongoing day-to-day relationship with the underlying client, including initial and ongoing
determination of client suitability. Although CX Institutional shall provide information to underlying client, CX
Institutional is not responsible for custodial selection and cannot negotiate commissions and/or transaction
costs, and/or seek better execution on behalf of the underlying clients. The underlying clients with whom
CX Institutional interacts are advised as to the limitations of CX Institutional’s duties.
11
CX Institutional
ADV Part 2A, Firm Brochure
Disclosure Statement. A copy of CX Institutional’s written Brochure as set forth on ADV Part 2A, Wrap Fee
Program Brochure as set forth on ADV Part 2A Appendix 1 (as applicable), ADV Part 2B Brochure
Supplement and, Form CRS shall be provided to each client prior to, or contemporaneously with, the
execution of the applicable form of client agreement.
Client Assets Managed by CX Institutional
As of October 9, 2025, CX Institutional maintained $4,121,239,331 in client assets under management on
a discretionary basis and $0 on a non-discretionary basis.
Item 5 – Fees and Compensation
Asset Management Fees
CX Institutional shall receive a Program Fee based upon a percentage (%) of the market value of the assets
placed under management (between negotiable and 2.0%). The “Program Fee” shall consist of an
investment advisory fee and strategy fee. However, fees shall vary depending upon various objective and
subjective factors, including but not limited to: the representative assigned to the account, the amount of
assets to be invested, the complexity of the engagement, the servicing needs, related accounts, future
earning capacity, anticipated future additional assets, and negotiations with the client. See Fee Differentials
above. As a result, similarly situated clients could pay different fees, which will correspondingly impact an
underlying client’s net account performance. Moreover, the services we provide may be available from other
advisers at lower fees. All clients and prospective clients should be guided accordingly.
It is possible that different investment advisor representatives may charge different fees for providing the
same or similar services to clients. The specific level of services you will receive and the fees you will be
charged will be specified in your Investment Advisory Agreement. Before engaging CX Institutional to
provide asset management services, clients are required to enter into an agreement with CX Institutional
setting forth the terms and conditions of the engagement (including termination), describing the scope of
the services to be provided, and the fee that is due from the client.
Clients may elect to have CX Institutional’s fees deducted from their custodial account or related custodial
account. Both CX Institutional’s Investment Advisory Agreement and the custodial/clearing agreement may
authorize the custodian to debit the account for the amount of CX Institutional’s fee and to directly remit
that fee to CX Institutional in compliance with regulatory procedures. If CX Institutional bills the client
directly, payment is due within 30 days of receipt of the invoice. CX Institutional shall deduct fees and/or
bill clients monthly in arrears, based upon the average daily balance within the account during the previous
month.
If a client determines to engage CX Institutional to provide investment management services on a wrap fee
basis in accordance with the Program, the services offered under, and the corresponding terms and
conditions pertaining to the Program are discussed in the Wrap Fee Program Brochure, a copy of which is
presented to all prospective Program participants.
Other Fee: Clients will pay a $10 quarterly fee per account. Clients will be charged an additional $2.50 per
sleeve per Quarter. Clients may be charged an additional $2.50 per account quarterly for their account
aggregation services within clients’ client portal.
Asset Management Services – CX Multi-Strategy Platform Program Fees
Clients who select the CX Multi-Strategy Platform will pay an additional monthly strategy fee based upon
the percentage (%) of Portfolio Strategy assets under management. The annual Program Fee (investment
advisory fee plus strategy fee) shall not exceed 2.0% based upon a percentage (%) of the market value of
12
CX Institutional
ADV Part 2A, Firm Brochure
the assets placed under management. However, fees shall vary depending upon various objective and
subjective factors, including but not limited to: the representative assigned to the account, the amount of
assets to be invested, the complexity of the engagement, the servicing needs, related accounts, future
earning capacity, anticipated future additional assets, and negotiations with the client. See Fee Differentials
above. As a result, similar clients could pay different fees, which will correspondingly impact an underlying
client’s net account performance. Moreover, the services we provide may be available from other advisers
at lower fees. All clients and prospective clients should be guided accordingly.
It is possible that different investment advisor representatives may charge different fees for providing the
same or similar services to clients. The specific level of services you will receive and the fees you will be
charged will be specified in your Investment Advisory Agreement. Before engaging CX Institutional to
provide asset management services clients are required to enter into an agreement with CX Institutional
setting forth the terms and conditions of the engagement (including termination), describing the scope of
the services to be provided, and the fee that is due from the client.
If a client determines to engage CX Institutional to provide investment management services on a wrap fee
basis in accordance with the Program, the services offered under, and the corresponding terms and
conditions pertaining to the Program are discussed in the Wrap Fee Program Brochure, a copy of which is
presented to all prospective Program participants.
Client Experience Program
The Client Experience Program makes available multiple offerings for individuals, high net worth individuals,
charitable organizations and business entities on a discretionary and non-discretionary wrap or non-wrap
fee-only basis. Under the Client Experience Program, CX Institutional is able to offer participants specific
discretionary and non-discretionary asset management portfolios that are offered under the CX Multi-
Strategy Platform Program in combination with specific Financial Planning Services. In addition, specific
client service deliverables are paired with each Client Experience offering. These combinations of
investments, financial planning, and service are intended to deliver the appropriate solutions tailored to the
individual needs of clients.
CX Institutional shall receive a Program Fee based upon a percentage (%) of the market value of the assets
placed under management (between negotiable and 2.0%), inclusive of investment advisory fee and
strategy fee. However, fees shall vary depending upon various objective and subjective factors, including
but not limited to: the representative assigned to the account, the amount of assets to be invested, the
complexity of the engagement, the servicing needs, related accounts, future earning capacity, anticipated
future additional assets, and negotiations with the client. See Fee Differentials above. As a result, similar
clients could pay different fees, which will correspondingly impact an underlying client’s net account
performance. Moreover, the services we provide may be available from other advisers at lower fees. All
clients and prospective clients should be guided accordingly.
It is possible that different investment advisor representatives may charge different fees for providing the
same or similar services to clients. The specific level of services you will receive and the fees you will be
charged will be specified in your Investment Advisory Agreement. Before engaging CX Institutional to
provide asset management services clients are required to enter into an agreement with CX Institutional
setting forth the terms and conditions of the engagement (including termination), describing the scope of
the services to be provided, and the fee that is due from the client.
If a client determines to engage CX Institutional to provide investment management services on a wrap fee
basis in accordance with the Program, the services offered under, and the corresponding terms and
13
CX Institutional
ADV Part 2A, Firm Brochure
conditions pertaining to the Program are discussed in the Wrap Fee Program Brochure, a copy of which is
presented to all prospective Program participants.
Asset Management: CX Institutional generally requires a minimum asset level of $5,000 for investment
management services. CX Institutional’s fees are billed on a pro-rata annualized basis monthly in arrears
based on the average daily value of the assets maintained in the account during the prior month. Both CX
Institutional’s Investment Advisory Agreement and the custodial/clearing agreement may authorize the
custodian to debit the account or related accounts for the amount of CX Institutional’s Program Fee and to
directly remit that fee to CX Institutional in compliance with regulatory procedures. Fees will generally be
automatically deducted from your managed account or related accounts. However, CX Institutional may
agree to directly invoice a client for services rendered.
Trade Away/Prime Broker Fees. If, in the reasonable determination of CX Institutional that it would be
beneficial for the client, individual equity and/or fixed income transactions may be effected through broker-
dealers other than the account custodian, in which event, the client generally will incur both the fee
(commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “trade Away”
and/or prime broker fee charged by the account custodian (i.e., LPL and/or Schwab).
Financial Planning and Consulting Service Fees
CX Institutional typically requires that its Financial Planning clients pay a retainer equal to fifty-percent (50%)
of the estimated total financial consultation fee in advance of service. The balance of the fee shall generally
be directly billed to the client upon completion of the financial consultation services. Clients will pay a fist
year fee of $6,250. For those clients who choose to engage CX Institutional at the Management Level,
subsequent successive annual fees are subject to a minimum of $3,125.
Retirement Plan Consulting Fees
The terms and conditions of CX Institutional’s retirement plan consulting services shall generally be set
forth in a Retirement Plan Consulting Agreement between CX Institutional and the plan sponsor. CX
Institutional’s negotiable retirement plan consulting fees generally range between 0.25% and 0.80% of the
value of plan assets under advisement, depending upon the level and scope of the service(s) required and
the professional(s) rendering the service(s).
Pension Consultations: CX Institutional’s Pension Consulting fees are billed on a pro-rata annualized
basis monthly in arrears.
Commission Relationships
As discussed below, unless the client directs otherwise or an individual client’s circumstances require, CX
Institutional will generally recommend that LPL Financial (“LPL”) and/or Charles Schwab & Co. Inc.
(“Schwab”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers
such as LPL or Schwab charge brokerage commissions and/or transaction fees for effecting certain
securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions
are charged for individual equity and fixed income securities transactions). Participants in the Program will
not incur brokerage commissions and/or transaction fees in addition to the Program Fees. Clients may also
incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level
(e.g., management fees, IRA and qualified retirement plan fees, surrender charges and other fund
expenses).
The brokerage commissions and/or transaction fees charged by LPL and/or Schwab may be higher or lower
than those charged by other broker-dealers/custodians.
14
CX Institutional
ADV Part 2A, Firm Brochure
Clients in the CX Institutional on a Wrap Fee Program will not incur brokerage commissions and/or
transaction or asset based custodial fees in addition to the Program Fee.
Account Termination Fees: Clients should note that upon the closing of their custodial account certain
termination fees may apply. For example, LPL charges $125 to close an account. Account closure fees are
not absorbed by any wrap fee program offered by CX Institutional.
Asset-Based Fees versus Transaction-Based Fees
Custodians such as LPL and Schwab are compensated for their services which include, but are not limited
to execution, custody and reporting. LPL and Schwab can charge a fixed percentage fee for their services
based upon the dollar amount of the assets placed in their custody and/or on their platform. This is referred
to as an “Asset-Based Fee.” In the alternative, rather than a fixed percentage fee based upon the market
value of the assets in its custody, LPL and Schwab could charge a separate fee for the execution of each
transaction. This is referred to as a “Transaction-Based Fee.” Under a Transaction Based fee, the amount
of total fees charged to the client account for trade execution will vary depending upon the number of
transactions that are placed for the account.
Item 6 – Performance-Based Fees and Side-By-Side Management
Neither CX Institutional, nor any supervised person of CX Institutional accepts performance-based fees.
Item 7 – Types of Clients
CX Institutional’s clients generally include, but not limited to, individuals, high net worth individuals, charitable
organizations, trusts, estates, pension and profit sharing plans, and business entities.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
CX Institutional’s primary method of security analysis is a blend of fundamental, quantitative, and technical
analysis. Each form of analysis is described below:
Fundamental Analysis
This method attempts to measure a security’s intrinsic value by examining related economic, financial and
other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect
the security's value, including macroeconomic factors (like the overall economy and industry conditions)
and individually specific factors (like the financial condition and management of companies). The end goal
of performing fundamental analysis is to attempt to produce a value that an investor can compare with the
security's current price to determine what sort of position to take with that security (underpriced = buy,
overpriced = sell or short). This method of security analysis is considered to be the opposite of technical
analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most
analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any
type of security or index.
Quantitative Analysis
This method attempts to measure a security’s, or indices’, risk and value by analyzing its relative metrics to
the broad market. Such metrics include standard deviation, correlations, expected return metrics, balance
sheet ratio analysis, and overall outputs tied to multiple regression analysis.
Technical Analysis
This method attempts to measure a security’s value by analyzing statistics generated by market activity,
such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value,
but instead use charts and other tools to identify patterns that can suggest future activity. Technical analysts
believe that the historical performance of stocks and markets are indications of future performance.
15
CX Institutional
ADV Part 2A, Firm Brochure
Cyclical Analysis
This method attempts to forecast the direction of prices through analysis performed on historical
relationships between price and market trends.
CX Institutional uses the following investment strategies when implementing investment advice given to
clients:
Long Term Purchases
This refers to investments that are purchased with the intention of being held for at least one year.
Short Term Purchases
This refers to investments that are purchased with the intention of being sold within one year.
Investment Risk. Investing in securities involves risk of loss that clients should be prepared to bear.
Different types of investments involve varying degrees of risk, and it should not be assumed that future
performance of any specific investment or investment strategy (including the investments and/or
investment strategies recommended or undertaken by CX Institutional) will be profitable or equal any
specific performance level(s).
Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to do so
by using:
Margin-The account custodian or broker-dealer lends money to the client. The custodian charges
the client interest for the right to borrow money, and uses the assets in the client’s brokerage
account as collateral; and,
Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the client,
the client pledges its investment assets held at the account custodian as collateral;
These above-described collateralized loans are generally utilized because they typically provide more
favorable interest rates than standard commercial loans. These types of collateralized loans can assist
with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in
lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are
not without potential material risk to the client’s investment assets. The lender (i.e., custodian, bank, etc.)
will have recourse against the client’s investment assets in the event of loan default or if the assets fall
below a certain level. For this reason, CX Institutional does not recommend such borrowing unless it is
for specific short-term purposes (i.e., a bridge loan to purchase a new residence). CX Institutional does
not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market).
Regardless, if the client was to determine to utilize margin or a pledged assets loan, the following
economic benefits would inure to CX Institutional:
by taking the loan rather than liquidating assets in the client’s account, CX Institutional continues
to earn a fee on such Account assets; and,
if the client invests any portion of the loan proceeds in an account to be managed by CX
Institutional, CX Institutional will receive an advisory fee on the invested amount; and,
if CX Institutional’s advisory fee is based upon the higher margined account value (see margin
disclosure at Item 5 below), CX Institutional will earn a correspondingly higher advisory fee. This
could provide CX Institutional with a disincentive to encourage the client to discontinue the use of
margin.
The Client must accept the above risks and potential corresponding consequences associated with the
use of margin or a pledged assets loans.
16
CX Institutional
ADV Part 2A, Firm Brochure
Investment Strategies
When consistent with a particular client’s designated investment objective(s), CX Institutional may
recommend that clients invest in any one or more of the following Strategy Portfolios, which are selected
and managed at the individual client level. CX Institutional may also implement “Custom Strategy
Portfolios,” which are typically comprised of a blend of the holdings contained in one or more of Strategy
Portfolios described below, and may also include additional common stocks, individual bonds, options,
preferred stocks, ETPs, mutual funds, private or direct placements or annuities.
Each Strategy Portfolio carries an additional fee as fully described in Item 5 above.
A list of the relevant investment strategies and their asset minimums are below:
Global Direct Main
The minimum investment requirement for this strategy is $5,000.
Global Direct Growth Focus
The minimum investment requirement for this strategy is $5,000.
Global Direct Value
The minimum investment requirement for this strategy is $5,000.
Global Direct Dividend Focus
The minimum investment requirement for this strategy is $5,000.
Global Direct International
The minimum investment requirement for this strategy is $5,000.
GLOBAL CORE - DOMESTIC FOCUS
The minimum investment requirement for this strategy is $100,000.
GLOBAL CORE – DIVIDEND FOCUS
The minimum investment requirement for this strategy is $100,000.
GLOBAL CORE – GROWTH FOCUS
The minimum investment requirement for this strategy is $100,000.
GLOBAL CORE - INTERNATIONAL
The minimum investment requirement for this strategy is $100,000.
GLOBAL CORE - MAIN
The minimum investment requirement for this strategy is $100,000
GLOBAL CORE - OPPORTUNISIC
The minimum investment requirement for this strategy is $100,000
GLOBAL ENHANCED – DOMESTIC FOCUS
The minimum investment requirement for this strategy is $250,000
GLOBAL ENHANCED – DIVIDEND FOCUS
The minimum investment requirement for this strategy is $250,000
17
CX Institutional
ADV Part 2A, Firm Brochure
GLOBAL ENHANCED – GROWTH FOCUS
The minimum investment requirement for this strategy is $250,000
GLOBAL ENHANCED – INTERNATIONAL
The minimum investment requirement for this strategy is $250,000
GLOBAL ENHANCED – MAIN
The minimum investment requirement for this strategy is $250,000
GLOBAL ENHANCED – OPPORTUNISTIC
The minimum investment requirement for this strategy is $250,000
S&P 500 – Tax Centric
The minimum investment requirement for this strategy is $1,000,000
Large Cap Core – Tax Centric
The minimum investment requirement for this strategy is $100,000
Equal Weight Core – Tax Centric
The minimum investment requirement for this strategy is $100,000
S&P 500 Equal Weight – Tax Centric
The minimum investment requirement for this strategy is $1,000,000
Passive Core
The minimum investment requirement for this strategy is $1,000
Kickstart
The minimum investment requirement for this strategy is $500.
Electric Vehicle
The minimum investment requirement for this strategy is $50,000
Blockchain
The minimum investment requirement for this strategy is $50,000
ESG
The minimum investment requirement for this strategy is $10,000
Global Fixed Income
The minimum investment requirement for this strategy is $1,000
Tax Advantaged – Fixed Income
The minimum investment requirement for this strategy is $1,000.
Once strategies are initially invested based on the pre-determined minimums, all strategies will be allowed
to deviate lower than the stated minimums, which may be caused by market activity or client distributions,
and will remain invested in the assigned strategy as long as the account’s value does not impede the
strategy’s mandate and the account’s ability to appropriately hold all strategy assets.
18
CX Institutional
ADV Part 2A, Firm Brochure
CX Institutional’s methods of analysis and investment strategies do not present any significant or unusual
risks. However, every method of analysis has its own inherent risks. In particular, clients face the following
potential investment risks:
Market Risk: Either the stock market as a whole, or the value of an individual company, goes down resulting
in a decrease in the value of client investments. This is also referred to as systemic risk.
Equity (stock) market risk: Common stocks are susceptible to general stock market fluctuations and to
volatile increases and decreases in value as market confidence in and perceptions of their issuers change.
If you held common stock, or common stock equivalents, of any given issuer, you would generally be
exposed to greater risk than if you held preferred stocks and debt obligations of the issuer.
Company Risk: When investing in stock positions, there is always a certain level of company or industry
specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be
reduced through appropriate diversification. There is the risk that the company will perform poorly or have
its value reduced based on factors specific to the company or its industry. For example, if a company’s
employees go on strike or the company receives unfavorable media attention for its actions, the value of
the company may be reduced.
Fixed Income Risk: When investing in bonds, there is the risk that issuer will default on the bond and be
unable to make payments. Further, individuals who depend on set amounts of periodically paid income face
the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments
that face the same inflation risk.
Options Risk: Options on securities may be subject to greater fluctuations in value than an investment in
the underlying securities. Purchasing and writing put and call options are highly specialized activities and
entail greater than ordinary investment risks.
ETF and Mutual Fund Risk: When CX Institutional invests in an ETF or mutual fund, the client will bear
additional expenses based on its pro-rata share of the ETFs or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities the ETF or mutual fund holds. Clients may also incur brokerage
costs when purchasing ETFs if they do so outside of the Program.
Management Risk: Client investment success varies with the success and failure of CX Institutional’s
strategies, research, analysis and determination of portfolio securities. If CX Institutional’s investment
strategies do not produce the expected returns, the value of the investment will decrease.
CX Institutional primarily allocates client investment assets among various individual equity (stocks), debt
(bonds) and fixed income securities, structured products, closed end mutual funds and/or ETFs.
CX Institutional’s asset allocation strategies have been designed to comply with the requirements of Rule
3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly managed investment programs,
such as CX Institutional’s asset allocation programs, with a non-exclusive safe harbor from the definition of
an investment company. In accordance with Rule 3a-4, the following disclosure is applicable to CX
Institutional’s management of client assets:
19
CX Institutional
ADV Part 2A, Firm Brochure
Individual Treatment - the account is managed on the basis of the client’s financial situation and
Initial Interview – at the opening of the account, CX Institutional, through its designated
1.
representatives, shall obtain from the client information sufficient to determine the client’s financial
situation and investment objectives;
2.
investment objectives;
3. Quarterly Notice – at least quarterly CX Institutional shall notify the client to advise CX Institutional
whether the client’s financial situation or investment objectives have changed, or if the client wants to
impose and/or modify any reasonable restrictions on the management of the account;
4. Annual Contact – at least annually, CX Institutional shall contact the client to determine whether
the client’s financial situation or investment objectives have changed, or if the client wants to impose
and/or modify any reasonable restrictions on the management of the account;
5. Consultation Available – CX Institutional shall be reasonably available to consult with the client
relative to the status of the account;
6. Quarterly Report – the client shall be provided with a quarterly report for the account for the
preceding period;
7. Ability to Impose Restrictions – the client shall have the ability to impose reasonable restrictions
on the management of the account, including the ability to instruct CX Institutional not to purchase
certain mutual funds;
8. No Pooling – the client’s beneficial interest in a security does not represent an undivided interest
in all the securities held by the custodian, but rather represents a direct and beneficial interest in the
securities which comprise the account;
9. Separate Account - a separate account is maintained for the client with the Custodian;
10. Ownership – each client retains indicia of ownership of the account (e. g. right to withdraw
securities or cash, exercise or delegate proxy voting, and receive transaction confirmations).
CX Institutional believes that its annual investment management fee is reasonable in relation to: (1) the
advisory services provided under the Investment Advisory Agreement; and (2) the fees charged by other
investment advisers offering similar services/programs. However, CX Institutional’s annual investment
management fee may be higher than that charged by other investment advisers offering similar
services/programs. In addition to CX Institutional’s annual investment management fee, the client will also
incur charges imposed directly at the mutual and exchange traded fund level (e.g., management fees and
other fund expenses).
CX Institutional’s investment programs may involve above- average portfolio turnover which could
negatively impact upon the net after-tax gain experienced by an individual client in a taxable account
Item 9 – Disciplinary Information
CX Institutional has not been the subject of any disciplinary actions.
Item 10 – Other Financial Industry Activities and Affiliations
A. Neither CX Institutional, nor its representatives are registered or have an application pending to register,
as a broker-dealer or a registered representative of a broker-dealer.
B. Neither CX Institutional, nor its representatives are registered or have an application pending to register,
as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a
representative of the foregoing.
C. Other Investment Advisor. As indicated above, CX Institutional is affiliated with CXI Advisors, a SEC
registered investment adviser firm (CRD# 301321). CXI Advisors has engaged CX Institutional to
20
CX Institutional
ADV Part 2A, Firm Brochure
provide investment management services on a sub-advisory basis. This arrangement does not present
a conflict of interest, because clients do not incur additional or increased advisory fees as a result.
D. CX Institutional does not receive, directly or indirectly, compensation from investment advisors that it
recommends or selects for its clients.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
A. CX Institutional maintains an investment policy relative to personal securities transactions. This
investment policy is part of CX Institutional’s overall Code of Ethics, which serves to establish a
standard of business conduct for all of CX Institutional’s representatives that is based upon fundamental
principles of openness, integrity, honesty and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, CX Institutional also maintains
and enforces written policies reasonably designed to prevent the misuse of material non-public
information by CX Institutional or any person associated with CX Institutional.
B. Neither CX Institutional nor any related person of CX Institutional recommends, buys, or sells for client
accounts, securities in which CX Institutional or any related person of CX Institutional has a material
financial interest.
C. CX Institutional and/or representatives of CX Institutional may buy or sell securities that are also
recommended to clients. This practice may create a situation where CX Institutional and/or
representatives of CX Institutional are in a position to materially benefit from the sale or purchase of
those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e.,
a practice whereby the owner of shares of a security recommends that security for investment and then
immediately sells it at a profit upon the rise in the market price which follows the recommendation)
could take place if CX Institutional did not have adequate policies in place to detect such activities. In
addition, these policies can help detect insider trading, “front-running” (i.e., personal trades executed
prior to those of CX Institutional’s clients) and other potentially abusive practices.
CX Institutional has a personal securities transaction policy in place to monitor the personal securities
transactions and securities holdings of each of CX Institutional’s “Access Persons”. CX Institutional’s
securities transaction policy requires that an Access Person of CX Institutional must provide the Chief
Compliance Officer or his/her designee with a written report of their current securities holdings within
ten (10) days after becoming an Access Person. Additionally, each Access Person must provide or
make available to the Chief Compliance Officer or his/her designee a list of reportable transactions
each calendar quarter as well as a written annual report of the Access Person’s securities holdings;
provided, however that at any time that CX Institutional has only one Access Person, he or she shall
not be required to submit any securities report described above.
D. CX Institutional and/or representatives of CX Institutional may buy or sell securities, at or around the
same time as those securities are recommended to clients. This practice creates a situation where CX
Institutional and/or representatives of CX Institutional are in a position to materially benefit from the sale
or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated
above in Item 11 C, CX Institutional has a personal securities transaction policy in place to monitor the
personal securities transaction and securities holdings of each of CX Institutional’s Access Persons.
21
CX Institutional
ADV Part 2A, Firm Brochure
Item 12 – Brokerage Practices
A.
In the event that the client requests that CX Institutional recommend a broker-dealer/custodian for
execution and/or custodial services (exclusive of those clients that may direct CX Institutional to use a
specific broker-dealer/custodian), CX Institutional generally recommends that investment advisory
accounts be maintained at LPL and/or Schwab. Prior to engaging CX Institutional to provide investment
management services, the client will be required to enter into a formal Agreement with CX Institutional
setting forth the terms and conditions under which CX Institutional shall manage the client’s assets, and
a separate custodial/clearing agreement with each designated broker-dealer/custodian.
Factors that CX Institutional considers in recommending LPL or Schwab (or any other broker-
dealer/custodian to clients) include historical relationship with CX Institutional, financial strength,
reputation, execution capabilities, pricing, research, and service. Although the commissions and/or
transaction fees paid by CX Institutional’s clients shall comply with CX Institutional’s duty to obtain best
execution, a client may pay a commission that is higher than another qualified broker-dealer might
charge to affect the same transaction where CX Institutional determines, in good faith, that the
commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the
lowest possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a broker-dealer’s services, including the value of research provided,
execution capability, commission rates, and responsiveness. Accordingly, although CX Institutional will
seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client
account transactions. Unless otherwise agreed, the brokerage commissions or transaction fees
charged by the designated broker-dealer/custodian are exclusive of, and in addition to, CX
Institutional’s investment advisory fee. CX Institutional’s best execution responsibility is qualified if
securities that it purchases for client accounts are mutual funds that trade at net asset value as
determined at the daily market close.
1. Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a client utilize
the services of a particular broker-dealer/custodian, CX Institutional receives from LPL and Schwab
(or another broker-dealer/custodian, investment platform, unaffiliated investment manager, vendor,
unaffiliated product/fund sponsor, or vendor) without cost (and/or at a discount) support services
and/or products, certain of which assist CX Institutional to better monitor and service client accounts
maintained at such institutions. Included within the support services that may be obtained by CX
Institutional may be investment-related research, pricing information and market data, software and
other technology that provide access to client account data, compliance and/or practice
management-related publications, discounted or gratis consulting services, discounted and/or
gratis attendance at conferences, meetings, and other educational and/or social events,
marketing support, computer hardware and/or software and/or other products used by CX
Institutional in furtherance of its investment advisory business operations.
LPL makes available to CX Institutional various products and services designed to assist CX
Institutional in managing and administering client accounts. Many of these products and services
may be used to service all or a substantial number of CX Institutional’s accounts, including accounts
not held with LPL. These include software and other technology that provide access to client
account data (such as trade confirmation and account statements); facilitate trade execution (and
aggregation and allocation of trade orders for multiple client accounts); provide research, pricing
information and other market data; facilitate payment of CX Institutional’s fees from its clients’
accounts; and assist with back-office functions; recordkeeping and client reporting.
22
CX Institutional
ADV Part 2A, Firm Brochure
LPL also makes available to CX Institutional other services intended to help CX Institutional
manage and further develop its business. Some of these services assist CX Institutional to better
monitor and service program accounts maintained at LPL, however, many of these services benefit
only CX Institutional, for example, services that assist CX Institutional in growing its business.
These support services and/or products may be provided without cost, at a discount, and/or at a
negotiated rate, and include practice management-related publications; consulting services;
attendance at conferences and seminars, meetings, and other educational and/or social events;
marketing support; and other products and services used by CX Institutional in furtherance of the
operation and development of its investment advisory business.
The products and services described above are provided to CX Institutional as part of its overall
relationship with LPL. While as a fiduciary CX Institutional must always act in its clients’ best
interests, the receipt of these benefits creates a conflict of interest because CX Institutional’s
recommendation that clients’ custody their assets at LPL may be based in part on the benefit to CX
Institutional of the availability of the foregoing products and services and not solely on the nature,
cost or quality of custody or brokerage services provided by LPL Financial. CX Institutional’s receipt
of some of these benefits may be based on the amount of advisory assets custodied on the LPL
platform.
Schwab Advisor Services provides CX Instititional and its clients with access to their institutional
brokerage services (trading, custody, reporting, and related services), many of which are not
typically available to Schwab retail customers. However, certain retail investors may be able to get
institutional brokerage services from Schwab without going through CX Institutional. Schwab also
makes available various support services. Some of those services help CX Institutional manage or
administer its clients’ accounts, while others help CX Institutional manage and grow its business.
Schwab’s support services are generally available on an unsolicited basis (CX Institutional doesn’t
have to request them) and at no charge to CX Institutional.
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products
available through Schwab include some to which CX Institutional might not otherwise have access
or that would require a significantly higher minimum initial investment by clients.
Schwab has also agreed to pay for certain technology, research, marketing, and compliance
consulting products and services on CX Institutional’s behalf. These services are not contingent
upon CX Institutional committing any specific amount of business to Schwab in trading
commissions. The availability of these services from Schwab benefits CX Institutional because it
does not have to produce or purchase them, and it does not have to pay for these additional
services. The fact that CX Institutional receives these services from Schwab is an incentive for CX
Institutional to recommend and request the use of Schwab rather than making such a decision
based exclusively on client’s interest in receiving the best value in custody services and the most
favorable execution of client’s transactions. This is a conflict of interest.
Schwab also provides services intended to help it manage and further develop CX Institutional’s
business. These services include: educational conferences and events, consulting on technology
and business needs, consulting on legal and compliance related needs, publications and
conferences on practice management and business succession, access to employee benefit
providers, human capital consultants, and insurance providers and marketing consulting and
support. Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to CX Institutional. Schwab also discounts or waives its fees for
23
CX Institutional
ADV Part 2A, Firm Brochure
some of these services or pays all or a part of a third party’s fees. If clients do not maintain an
account with Schwab, CX Institutional would be required to pay for those services from its own
resources.
Schwab also makes available to CX Institutional other products and services that benefit CX
Institutional but do not directly benefit clients or clients’ accounts. These products and services
assist CX Institutional in managing and administering client’s accounts and operating the firm. They
include investment research, both Schwab’s own and that of third parties. CX Institutional uses this
research to service all or a substantial number of clients’ accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that: provide access to client account data (such as duplicate trade
confirmations and account statements), facilitate trade execution and allocate aggregated trade
orders for multiple client accounts, provide pricing and other market data, facilitate payment of our
fees from our clients’ accounts, and assist with back-office functions, recordkeeping, and client
reporting.
As indicated above, certain of the support services and/or products that may be received may assist
CX Institutional in managing and administering client accounts. Others do not directly provide such
assistance, but rather assist CX Institutional to manage and further develop its business enterprise.
There is no corresponding commitment made by CX Institutional to LPL, Schwab or any other entity
to invest any specific amount or percentage of client assets in any specific mutual funds, securities
or other investment products as result of the above arrangement.
2. CX Institutional does not receive referrals from broker-dealers.
3. CX Institutional does not generally accept directed brokerage arrangements (when a client requires
that account transactions be affected through a specific broker-dealer). In such client directed
arrangements, the client will negotiate terms and arrangements for their account with that broker-
dealer, and CX Institutional will not seek better execution services or prices from other broker-
dealers or be able to "batch" the client’s transactions for execution through other broker- dealers
with orders for other accounts managed by CX Institutional. As a result, client may pay higher
commissions or other transaction costs or greater spreads, or receive less favorable net prices, on
transactions for the account than would otherwise be the case. Higher transaction costs adversely
impact account performance.
In the event that the client directs CX Institutional to effect securities transactions for the client’s
accounts through a specific broker-dealer, the client correspondingly acknowledges that such
direction may cause the accounts to incur higher commissions or transaction costs than the
accounts would otherwise incur had the client determined to effect account transactions through
alternative clearing arrangements that may be available through CX Institutional.
B. To the extent that CX Institutional provides investment advisory services to its clients, the transactions
for each client account generally will be affected independently, unless CX Institutional decides to
purchase or sell the same securities for several clients at approximately the same time. CX Institutional
may (but is not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate
more favorable commission rates or to allocate equitably among CX Institutional’s clients differences
in prices and commissions or other transaction costs that might have been obtained had such orders
been placed independently. Under this procedure, transactions will be averaged as to price and will be
allocated among clients in proportion to the purchase and sale orders placed for each client account
24
CX Institutional
ADV Part 2A, Firm Brochure
on any given day. CX Institutional shall not receive any additional compensation or remuneration as a
result of such aggregation. Clients wishing to implement CX Institutional’s advice are free to select any
broker they wish and are so informed.
Trade Error Policy
CX Institutional has implemented procedures designed to prevent trade errors; however, trade errors in
client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of CX Institutional
to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes
the trade error, the client will be responsible for any loss resulting from the correction.
Depending on the specific circumstances of the trade error, the client may not be able to receive any gains
generated as a result of the error correction. In all situations where the client does not cause the trade error,
the client will be made whole and any loss resulting from the trade error will be absorbed by CX Institutional
if the error was caused by our Firm. If the error is caused by the broker-dealer, the broker-dealer will be
responsible for covering all trade error costs. If an investment gain results from the correcting trade, the
gain will remain in the client’s account unless the same error involved other client account(s) that should
also receive the gains and it is not permissible for all clients to retain the gain. CX Institutional may also
confer with clients to determine if the client should forego the gain (e.g., due to tax reasons). CX Institutional
and its supervised persons will never retain any portion of any gains made as a result of trade error
corrections or profit in any way from trade errors.
Item 13 – Review of Accounts
A. For those clients who engage in the Program, CX Institutional’s representatives conduct account
reviews on an ongoing basis. All clients are advised that it remains their responsibility to advise CX
Institutional of any changes in their investment objectives and/or financial situation. All clients (in person
or via telephone) are encouraged to review financial planning issues (to the extent applicable),
investment objectives and account performance with CX Institutional on an annual basis.
B. CX Institutional may conduct account reviews on an-other than periodic basis upon the occurrence of
a triggering event, such as a change in client investment objectives and/or financial situation, market
corrections and client request.
C. During any month that there is activity in a CX Institutional Portfolios managed account (and no less
frequently than quarterly); the client receives an account statement, from LPL and/or Schwab showing
account activity as well as positions held in the account at month end. Additionally, the client receives
a confirmation of each transaction that occurs within the account unless the transaction is the result of
a systematic purchase, redemption or exchange. All account data and statements are also generally
available on-line through the account view portal provided by their custodian. In addition, CX
Institutional may provide newsletters covering general financial planning and investment topics.
Item 14 – Client Referrals and Other Compensation
A. CX Institutional receives an economic benefit from Schwab in the form of the support products and
services it makes available to CX Institutional and other independent investment advisors whose clients
maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and
services for which CX Institutional would otherwise have to pay once the value of our clients’ assets in
accounts at Schwab reaches a certain size. Clients do not pay more for assets maintained at Schwab
as a result of these arrangements. However, CX Institutional benefits from the arrangement because
25
CX Institutional
ADV Part 2A, Firm Brochure
the cost of these services would otherwise be borne directly by CX Institutional. Clients should consider
these conflicts of interest when selecting a custodian. The products and services provided by Schwab,
how they benefit CX Institutional, and the related conflicts of interest are described above (see Item
12—Brokerage Practices).There is no corresponding commitment made by CX Institutional to LPL,
Schwab or any other entity to invest any specific amount or percentage of client assets in any specific
mutual funds, securities or other investment products as a result of the above arrangement.
B. CX Institutional may receive sponsorship dollars from Halo Securities LLC, Goldman Sachs & Co. LLC,
and Blackrock Inc. These sponsorship funds may be received in various forms, including but not limited
to direct payments, gifts, or benefits in kind. There is no corresponding commitment made by CX
Institutional to Halo Securities, Goldman Sachs & Co. LLC, Blackrock Inc. or any other entity to invest
any specific amount or percentage of client assets in any specific mutual funds, securities or other
investment products as a result of the above arrangement.
Additional Compensation
These funds may be used for, but not necessarily limited to, offsetting things like ACAT fees, technology
set-up fees, marketing and mailing costs, stationary and licensure transfer fees.
C. CX Institutional does not compensate, directly or indirectly, any person, other than its representatives,
for client referrals.
Item 15 – Custody
CX Institutional shall have the ability to have its fee for each client debited by the custodian on a monthly
basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular
written summary account statements directly from the broker-dealer/custodian and/or program sponsor for
the client accounts. CX Institutional may also provide a written periodic report summarizing account activity
and performance.
To the extent that CX Institutional provides clients with periodic account statements or reports, the client is
urged to compare any statement or report provided by CX Institutional with the account statements received
from the account custodian. Please Also Note: The account custodian does not verify the accuracy of CX
Institutional’s advisory fee calculation.
Custody Situations: CX Institutional engages in other practices and/or services on behalf of its clients that
require disclosure at ADV Part 1, Item 9, but which practices and/or services are not subject to an annual
surprise CPA examination in accordance with the guidance provided in the SEC’s February 21, 2017
Investment Adviser Association No-Action Letter.
Item 16 – Investment Discretion
Through the CX Institutional Portfolios program and upon receiving written authorization from a client, CX
Institutional will maintain trading authorization over client accounts. Upon receiving written authorization
from the client, CX Institutional may implement trades on a discretionary basis. When discretionary authority
is granted, CX Institutional will have the authority to determine the type of securities and the amount of
securities that can be bought or sold for the client’s portfolio without obtaining the client’s consent for each
transaction. However, it is the policy of CX Institutional to consult with the client before making significant
changes in the account even when discretionary trading authority is granted by the client.
All clients have the ability to place reasonable restrictions on the types of investments that may be
26
CX Institutional
ADV Part 2A, Firm Brochure
purchased in an account. Clients may also place reasonable limitations on the discretionary power granted
to our Firm so long as the limitations are specifically set forth or included as an attachment to the client
agreement.
Item 17 – Voting Client Securities
A. CX Institutional does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing
the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be
voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy
proceedings or other type events pertaining to the client’s investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact
CX Institutional to discuss any questions they may have with a particular solicitation.
Item 18 – Financial Information
A. CX Institutional does not solicit fees of more than $1,200, per client, six months or more in advance.
B. CX Institutional is unaware of any financial condition that is reasonably likely to impair its ability to meet
its contractual commitments relating to its discretionary authority over certain client accounts.
C. CX Institutional has not been the subject of a bankruptcy petition.
CX Institutional’s Chief Compliance Officer, Kyle B. Osting, remains available to address any questions
that a client or prospective client may have regarding the above disclosures and arrangements.
27
CX Institutional
ADV Part 2A, Firm Brochure