Castleview Partners, LLC (“Castleview”, the “firm” or “we”) is registered with the Securities and
Exchange Commission (“SEC”) as a Registered Investment Adviser (“RIA”) with our principal place of
business located in Dallas, Texas. We began conducting business in October 2015. Castleview is
majority owned by Gill Capital Management, Inc. Douglas Gill is the sole owner of Gill Capital
Management, Inc. The other two principals with management influence are Umberto Perez and
David Fajardo.
DIRECT ADVISORY SERVICES
Our main investment advisory business is to manage the investment portfolios of individuals, high-
net- worth individuals, corporations, non-profits, and retirement plans (each a “Client” and
collectively the “Clients”). Our investment advisory services are tailored to the individual needs of our
Clients and are based on the Client’s goals, investment objectives, time horizon, and risk tolerance. In
this capacity, we and our Investment Advisor Representatives (each an “IAR” and collectively “IARs”),
act as fiduciaries to our Clients, always acting in the best interest of our Clients.
We offer the following investment advisory services through our IARs:
1) ADVISOR DIRECTED MANAGED ACCOUNTS
IARs provide continuous investment advice to our Clients regarding the investment of the
Clients’ portfolio holdings based on the individual needs of each Client. The IAR and the Client
discuss the Client’s particular financial circumstances and establish goals, investment objectives,
time horizons, and risk tolerance. The IAR reviews and discusses the Client’s prior investment
experience, in an effort to properly complete the Risk Tolerance Questionnaire (“RTQ”) and
develop a personalized Investment Policy Statement (“IPS”), both of which are utilized to
manage the Client’s portfolio.
An Advisor Directed Managed Account is one in which the account and the selected investments
are managed by the IAR. The IAR conducts research, assesses prevailing economic and market
conditions, weighs the Client’s objectives, and then makes investment decisions as to securities
to be bought and sold, as well as the timing of such purchases and sales, within the Client
portfolio of holdings, on a discretionary basis.
Our IARs utilize a variety of investments including, but not limited to: stocks; bonds; open- and
closed- end mutual funds; no-load or load-waived mutual funds; Unit Investment Trusts
(“UITs”); Exchange Traded Funds (“ETFs”); and derivative instruments such as index and stock
options; Certificates of Deposit (“CDs”); and non-traded alternative asset class holdings, such as
Limited Partnerships, Business Development Corporations, and Real Estate Investment Trusts.
Because each type of investment holding or security involves a varying degree of risk, a
particular security, and the associated weighting to that security, is only selected when it is
Part 2A: Brochure – 03/31/2024 Page 5
determined to be consistent with and fit into the overall strategy for achieving the Client’s stated
goals, investment objectives, risk tolerance, time horizon, and liquidity needs.
Our Clients may impose reasonable restrictions on investing in certain securities, types of
securities, companies, and/or industry sectors. However, Castleview will refuse to accept or to
continue management of the account or program, if your IAR determines that such restrictions
imposed by the Client cannot be honored. If the Client refuses to modify or withdraw such
restrictions after we have notified the Client that the restrictions cannot be honored, and given
the Client an opportunity to withdraw or modify the restrictions, then an account will not be
opened or, in the case of an existing account, the account will be closed. We will no longer be
responsible for providing investment advice and implementing investment decisions to manage
the account and the Investment Advisory Fee will cease. At that time, the account will become a
retail brokerage account under the control of the Client.
2) THIRD PARTY MONEY MANAGER ACCOUNTS
After gathering information about a Client’s financial circumstances, investment objectives, risk
tolerance, and other data, our IAR assists the Client in selecting a particular Third-Party Money
Manager (“TPMM”) to deliver an investment model (“strategy”) or manage a separate account for
the Client. IARs utilize multiple factors in selecting a prudent TPMM to recommend to a Client,
including but not limited to performance, investment objectives, and fees. These factors are
considered in relation to the Client’s specific goals and objectives to help determine suitability of
the TPMM. Clients referred to a TPMM for the management of a separate account are directed to
the disclosure documents and separate written agreements of the TPMM for more complete
information regarding the terms and conditions of the relationship between the Client and the
TPMM. When a Client engages a TPMM we recommended, we do not directly manage that portion
of the Client’s portfolio assets and are not involved in selecting the securities to be bought and
sold, or the timing of same. The day-to-day portfolio management decisions are provided by the
TPMM, and then executed by us at the Client’s custodian or executed directly by the TPMM if
managed in a separate account.
In the event multiple TPMMs are recommended to a Client, each TPMM has differing minimum
account requirements as well as a variety of fee ranges. If a Client uses a TPMM in a separate
account, we periodically review the Client’s financial situation, objectives, and restrictions; and
communicate relevant information to the TPMM, and assist the Client in understanding and
evaluating the services provided by the TPMM. Some TPPMs maintain their own separate
execution, clearing, and custodial relationships.
If we determine that a selected TPMM is not managing the Client’s portfolio in a manner
consistent with the Client’s IPS and investment objectives, or if the financial situation of the
Client changes, we recommend a different TPPM.
If we recommend the use of one of the strategies we manage internally, a conflict of interest may
arise because we benefit from earning an additional fee, above the advisory fees, to manage the
Part 2A: Brochure – 03/31/2024 Page 6
Castleview investment model to which Client funds are allocated.
3) COMBINED ADVISOR DIRECTED AND MONEY MANAGER MODEL ACCOUNTS
In some cases, a Client account is managed as a blend of Advisor Directed and TPMM Models in
which there are both selected investments managed by us and allocations to models that are
managed by the TPMM in one single account.
4) FINANCIAL PLANNING
Some of our IARs provide financial planning services. Fees are
charged as a flat dollar amount or
an hourly fee. Financial planning is a comprehensive evaluation, using assumptions and analysis
of a Client’s current and future financial situation and needs, using variable data such as current
and future income, expenses, investment growth, and performance, cash flows, asset values, and
withdrawal plans. Through the financial planning process, questions, information, and analysis
are considered as to how they may impact the current and future financial situation of the Client.
To prepare a financial plan or analysis, we gather information from the Client though personal
interviews. Information may include the Client’s tax status, current assets and liabilities,
expenses, investment portfolio, future goals, investment return expectations, and attitudes
towards risk. The financial plan or analysis is provided to help our Client make informed
decisions with their financial resources in an effort to achieve their financial goals and
objectives. In general, the financial plan or analysis may address any or all of the following areas:
Asset allocation, education planning, estate planning, financial, insurance needs, retirement
planning, and business retirement planning.
The financial plan or analysis does not always contain our recommendations to purchase or sell
specific securities. When investment recommendations are included, the Client decides whether
or not to implement the recommendations we make, and whether they will implement such
recommendations through Castleview or elsewhere. The services provided in the Financial
Planning Agreement terminate upon the delivery of the financial plan or analysis to the Client,
unless the IAR and Client enter into an On-going Planning Agreement.
To the extent the Client implements recommendations contained in the financial plan, the IAR
could be acting in the capacity of a registered representative of a broker-dealer. The IAR is
limited to soliciting, offering, and selling only those investments approved through their broker-
dealer. This may create a conflict of interest, as the IAR may be compensated for
recommending specific investments in addition to the financial planning fee. Similarly,
insurance product recommendations are limited to the insurance companies with which the IAR
is appointed as a licensed insurance agent or broker. Your IARs Brochure 2B will provide details
if he or she is registered with a broker-dealer or licensed as an insurance agent.
Castleview both sponsors and provides investment management services through a wrap fee
program called the Multiple Strategy Portfolio Program. Regardless of whether an account is
Advisor Directed or utilizes TPMMs, as described above, there is no difference in how we
manage accounts between the wrap and non-wrap format. Accounts in the wrap program have
Part 2A: Brochure – 03/31/2024 Page 7
the cost of custody/execution (whether transaction-based or asset-based) included in the
overall “wrap fees” charged to the account. As such, we receive a portion of the overall wrap fees
charged on such accounts.
See Item 5 of this brochure for additional information on Wrap Program Fees
PLATFORM SERVICES – AlphaPort
In addition to the Direct Advisory Services detailed above, we provide advisory, sub-advisory, and
operational support services to other investment advisory firms (“RIA Clients”) through our aiAlpha
platform. aiAlpha provides RIA Clients with a cloud-based practice management system and a model
marketplace with access to model portfolios and strategies of TPMMs.
Designed to be an end-to-end solution for advisory firms, the aiAlpha platform delivers a
comprehensive suite of administrative, operational, and trading services to RIA Clients. aiAlpha’s
open architecture is custodian agnostic and customizable/scalable to the specific business needs of
each RIA Client. aiAlpha’s practice management system can be engaged in a variety of ways: (1)
administered and operated by the RIA Client’s internal staff, (2) account administration and
operational support services provided by Castleview’s aiAlpha Service Team, or (3) a combination of
both (1) and (2).
RIA Clients utilize the models provided by the TPMMs, through aiAlpha, for the allocation of their
client (“End Clients”) portfolios and/or offer RIA Advisor Directed services in which the RIA Client’s
internal investment professionals work individually with the End Clients. The RIA Client’s financial
professionals provide the specific advice concerning the selection of TPMMs, separately managed
accounts, ETFs, or mutual funds that are available on AlphaPort. RIA Clients are responsible for
ensuring that their financial professionals provide regular and ongoing contact with End Clients,
allowing End Clients the opportunity to update and change their financial or personal profiles. The
RIA Client’s financial professionals are responsible for informing us of any restrictions which End
Clients wish to impose regarding the management of their accounts. The RIA Clients retain sole
responsibility for determining whether a TPMM’s or RIA Advisor Directed portfolio or strategy is
suitable and appropriate for the End Clients. We reserve the right to cancel services if we are not able
to accommodate the restrictions requested by an End Client.
TPMMs available on aiAlpha are either internally-sourced by Castleview or added at the request of an
RIA Client. We perform initial and ongoing due-diligence on internally-sourced TPMMs and such
TPMMs are made available to Clients. RIA Clients that request to have specific TPMMs added to aiAlpha
bear all responsibility for the due diligence of requested TPMMs and the related suitability for their
Clients. Such TPMMs are not endorsed by Castleview. We reserve the right to add or remove TPMMs
from the in our sole discretion. TPMMs provide trade signals to us through aiAlpha for us to facilitate
trades in the Client accounts.
Our internal IARs utilize the aiAlpha Platform for Client portfolio management and administration.
While aiAlpha is designed and intended to provide efficiency to our overall advisory practice, and our
Clients incur no additional cost as a result of our use of aiAlpha, Clients should consider it when
Part 2A: Brochure – 03/31/2024 Page 8
evaluating us due to the resources and human capital required for its operation.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, the firm had approximately $1,512,645,382 in total assets, of which
$269,982,571 constitutes Regulatory Assets Under Management (“RAUM”) and $1,242,662,811
represents Assets Under Administration (“AUA”) for RIA Clients of the AlphaPort platform.