Description of the Advisory Firm
Founded in 2015, CreativeOne Wealth, LLC (hereinafter “we”, “us”, the “Firm” or “C1W”) is an
investment advisory firm providing fee-based asset management services for clients, as well
as comprehensive financial planning services. C1W is a Limited Liability Company organized
in the State of Kansas.
The primary owners of C1W are CM2 Holding Company, Inc., See Also, LLC, and JRC Equity
Partners, LLC.
Advisory Services Offered
The Firm provides Asset Management and Financial Planning Services through its Investment
Adviser Representatives (“IARs”). for its clients, each of which is described below. IARs are
generally independent contractors of the Firm. They may have their own business entities with
trade names, logos, and websites that they use in marketing the services they provide through
C1W. Such business entities are generally owned by one or more IARs of the Firm, not the
Firm itself. The names of these business entities are set out in the IAR’s ADV 2B Brochure
Supplement. Clients should understand that the businesses are generally legal entities of the
IAR and not of the Firm or the custodian. Additionally, the business entities owned by the IAR
may provide services other than investment advice. IARs may choose to use the CreativeOne
Wealth name instead of setting up their own business entity. In this case, the IARs are not
owners of CreativeOne Wealth. All IARs are under the supervision of the Firm and the advisory
services of the IAR are provided through the Firm.
Clients collaborate with a C1W IAR to determine which services to employ to best help clients
reach their financial goals. The Firm will maintain the direct contractual relationship with each
client and obtain, through such agreements, the authority to engage independent third-party
managers, as applicable.
Asset Management Services
The Firm’s principal service is fee-based investment advisory services (“Asset Management
Services”). We manage investment portfolios on a discretionary basis consistent with clients’
investment objectives and guidelines. Prior to engaging C1W to provide Asset Management
Services, the client is required to enter into a written agreement (titled a “Discretionary
Investment Management Agreement” or “DIMA”) with the Firm setting forth the terms and
conditions under which the firm shall render its services. The DIMA grants us discretionary
authority to manage the client’s investments based on the individual needs, goals, objectives,
investment time horizon, and risk tolerance of each client. The Firm will not assume any
responsibility for the accuracy of information provided by the client, and we are not obligated
to verify any information received from the client or from the client’s other professionals (e.g.,
attorney, accountant, etc.) and is expressly authorized to rely on such information.
The Firm uses documents designed to ascertain client suitability which is analyzed by our
IARs. Once the analysis is complete, the IAR develops an investment strategy with the
prospective client that addresses specific investment criteria and allocation of the client’s
assets. Asset management services include but are not limited to the development of an
Investment Strategy; analysis and monitoring of Asset Allocation; Risk Tolerance evaluation;
Personal Investment Policy for Model Portfolios; Asset Selection; and Regular Portfolio
Monitoring. The IAR evaluates the current investments of each client, with respect to their risk
tolerance levels and time horizon. We request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction when investing in model strategies. In certain circumstances, however, the clients’
accounts may be administered by the IAR on a non-discretionary basis.
The Firm offers a discretionary management program that consists of proprietary models and
partners with various sub-advisory firms to create and manage portfolio strategies. C1W uses
Unified Managed Accounts (“UMA”) when it is in a client’s best interest. This allows for multiple
strategies to be managed and held within the same account. The Investment Proposal
consists of model asset allocation recommendations based on the client's risk tolerance, time
horizon, investment objectives and restrictions, tax status, and financial sophistication. Each
model has a unique objective and strategy, as described in Item 8 Methods of Analysis,
Investment Strategies, and Risk of Loss and may include, but not be limited to, stocks,
exchange-traded funds, and mutual funds. The investment strategy may also include a
recommendation that a percentage of the portfolio be allocated to an Indexed Annuity product
consistent with the client's investment objectives. Indexed Annuities are considered insurance
products and are not sold through C1W, but as indicated in Item 10, Other Financial Industry
Activities and Affiliations, certain C1W IARs are separately licensed insurance agents.
Recommended insurance products are often sold through CreativeOne Marketing, LLC an
insurance broker affiliated with C1W through common ownership and control by CM2 Holding
Company. The IAR does not have discretion over the purchase or sale of the insurance
product. It is at the client's sole discretion to determine whether to include the Indexed Annuity
product from the Investment Proposal within their investment portfolio. If the client chooses to
include an Indexed Annuity product in his or her portfolio, the IAR, in his or her capacity as an
insurance agent, will typically receive a sales commission directly from the insurance carrier
which is separate from and in addition to the advisory fees charged by C1W. However, the
assets invested in the Indexed Annuity will not be included as assets under management when
determining the advisory fee charged to the client’s portfolio. The client's portfolio and its
performance are monitored by the client's IAR. Clients should consider that the potential to
receive additional compensation can create conflicts of interest. Please refer to Item 10, Other
Financial Industry Activities and Affiliations for more information regarding these conflicts and
how C1W seeks to address them.
Investments managed by the Firm through the C1W Platform (C1W’s online portal that
provides performance reporting, proposal generation, and document storage) are custodied
at the brokerage firm ("Custodian") through which transactions are placed. Clients should be
aware that IARs may make different recommendations with respect to the same securities and
insurance products based upon each client’s suitability profile. Rebalancing of the asset
allocation models will occur as necessary. Account rebalancing is accomplished by buying
and selling shares of stocks, mutual funds, or exchange-traded funds to reach target
allocations.
Selection of Other Advisers
The Firm has discretion to choose third-party investment advisers (depending on the
contractual relationship, these third-party advisers may be referred to as “Sub-Advisers” or
“Model Managers”) to manage all or a portion of the client's assets. Third-party advisers
exercise the same degree of discretion as afforded to C1W by the client (see also Item 16).
However, clients may specify from the third-party investment advisers on the C1W platform
which third-party adviser they would like to use. The C1W Investment Committee conducts
due diligence on any third-party investment adviser, which may involve the following: review
of the third-party adviser's performance, reviews of the third-party adviser’s Form ADV,
registration status, disciplinary history, and investment strategy.
Considering the due diligence conducted, the C1W Investment Committee has the ultimate
authority to make available a third-party adviser’s investments to C1W clients. However, the
Committee may delegate some or all of its due diligence requirements to third parties (“Due
Diligence Service Providers” or “Service Providers”) when evaluating investment policies,
strategies, and models developed externally. However, the Investment Committee may only
delegate its duties under this section to an identified Service Provider if the Committee has
reasonably identified and determined through due diligence that outsourcing the functions to
a Service Provider would be appropriate after considering the following: the nature, scope,
and implication of outsourcing investment policies, strategies, and models evaluation; the
potential risks resulting from a Service Provider performing investment due diligence, including
how to mitigate and manage such risks; The Service Provider’s competence, capacity, and
resources necessary to perform the due diligence on investment due diligence; The Service
Provider’s material subcontracting arrangements related to outsourced due diligence
functions; Coordination with the Service Provider for Federal securities law compliance; and
The orderly termination of the performance of the delegated due diligence requirements.
Notwithstanding the foregoing, the Committee is not relieved of its duty to monitor the Service
Provider’s performance and to reassess the selection of the Service Provider.
For those third-party advisers who have been approved, the Investment Committee and C1W
will review their ongoing performance and reevaluate the adviser’s inclusion on the Platform
when necessary.
We may also refer clients to unaffiliated third-party registered investment advisers, commonly
referred to as a “Solicitor Relationship.” Under these arrangements, the Firm will typically
receive a portion of the ongoing advisory fees collected by the third-party adviser for services
provided to clients. IARs may also assist the third-party adviser with the ongoing management
of the client’s accounts. However, we will only refer clients to third parties if it is in line with
the client’s objectives and best interests. In all instances prior to referring the client, we will
provide the client with a current copy of the third-party investment adviser’s written disclosure
statement identifying C1W as the solicitor, the name of the investment adviser, the nature of
the relationship between C1W and the investment adviser, the terms of the compensation
arrangement, and the amount charged to the client in addition to the advisory fee as a result
of the solicitation activity.
Financial Planning and Investment Consultative Retainer Services
Through C1W IARs, we offer comprehensive financial planning services for individuals,
families, and businesses. Financial Planning services include data gathering and analysis,
along with creating a financial plan with specific recommendations and implementation advice
tailored to client needs. Depending on the individual client’s needs, specific areas of planning
advice can include investment planning, insurance needs assessment and advice, retirement
planning, cash flow management, debt consolidation, capital needs assessments, educational
planning, estate planning, and business planning. Clients must sign a Financial Planning
Services Agreement when contracting with the Firm for this service. The plan must be
delivered no later than six (6) months after the Agreement has been signed and payment
received by the Firm.
The IAR may also, as requested, recommend changes to the client’s investment portfolio or
plan in writing. Changes in the client’s financial condition, personal circumstances, goals, or
general economic conditions may trigger changes in the plan. To the extent material changes
have occurred to a client’s circumstances or goals, or to the extent a client requests a new
strategy or project, thereby causing a significant change to the existing plan, the client will be
asked to sign a new Financial Planning Services Agreement. The client may contact the IAR
as often as needed.
Clients decide which investment recommendations to accept and implement in connection
with the financial plan. Clients are also free to select any brokerage, insurance, or other
product provider to purchase (or sell) the investments, insurance, or other products discussed
with the IAR.
All planning is based on information provided by the client. It is the client’s responsibility to be
certain the Firm has current and accurate information to enable to prepare the initial plan. It
is the client’s responsibility to inform the IAR of material changes affecting the investments
and planning strategies implemented.
The client is under no obligation to act on the IAR’s financial planning recommendations. If
the client elects to act on any of the recommendations made in a financial plan, the client is
under no obligation to effect such recommendations through C1W, or our affiliated insurance
broker, CreativeOne Marketing ,LLC, or our affiliated broker-dealer, CreativeOne Securities,
LLC, as applicable, or through the IAR in his or her capacity as an insurance agent or
registered representative of a broker-dealer as applicable. Please refer to Item 10, Other
Financial Industry Activities and Affiliations for more information. The Firm’s financial planning
services or any products recommended within a financial plan are not necessarily at the lowest
available cost.
We also offer investment consultative retainer services. Similar to financial planning
arrangements, our retainer service does not include active management of client assets.
Rather, the Firm’s investment consultative services include providing client with ongoing and
continuous consultative support addressing the client's financial circumstances and goals
based on the client's current financial situation and the client's future needs and objectives.
Through this service, clients will receive copies of notes from meetings and/or consultations
with the C1W IAR and a written summary of the advice provided if requested. Our consultation
agreements automatically terminate at the earlier of (i) the client’s assets becoming actively
managed by C1W or (ii) after six months since execution of the contract.
Retirement Plan Consulting Services
A C1W IAR may provide consulting services for an employer-sponsored retirement plan
(“Sponsor”). Per the Retirement Plan Consulting Agreement, C1W agrees to provide non-
fiduciary investment related educational information and related services to the Sponsor. Plan
participants should not assume that general informational materials or educational sessions
devised and/or provided by the Firm on behalf of the Sponsor serves as the receipt of, or as a
substitute for, personalized investment advice from the Firm, or from any other investment
professional. To the extent that any participant requires initial or ongoing personalized
investment advice, he/she is encouraged to consult with the investment professional of his/her
choosing. C1W shall have no discretionary authority or discretionary responsibility in the
administration of the Sponsor’s plan.
Serving as a Sub-Adviser to Independently Sponsored Advisory Programs
We may participate as a sub-adviser under other firms’ advisory programs. In these
arrangements, a Registered Investment Adviser (“RIA”), for which we are providing sub-
advisory services, would recommend to a client that the client invests in models available on
the C1W platform. The Firm receives a fee from the RIA. The RIA may choose the investment
strategies implemented which may or may not include C1W’s proprietary models. The RIA
collects the client’s investment objectives for which we are providing sub-advisory services.
Clients of third-party RIAs using the Firm’s sub-advisory services should evaluate whether this
program is suitable for their needs and objectives, and whether comparable or similar services
are available at a lower cost elsewhere.
We serve as sub-adviser to the AdvisorShares STAR™ Global Buy Write Exchange Traded
Fund (“ETF”) (Ticker: VEGA) for which it earns a management fee of 55 basis points (bps).
C1W invests client assets in the VEGA ETF. In such situations, C1W will earn 55 bps more
on the client’s assets so invested, in addition to the fees paid directly from the client to C1W
on those same assets. In the STAR™ Spectrum VEGA Core Plus Model, C1W will earn 55
bps more on the client’s assets so invested but charges a lower fee on the same assets paid
directly by the client. C1W will honor any written client request to not purchase the VEGA ETF
within the client's account wherein C1W is also receiving an advisory fee. Unless an
exemption exists under applicable ERISA or Employee Benefits Security Administration
guidance, C1W will not retain both a management fee from the VEGA ETF and an advisory
fee for and services provided with respect to any ERISA-qualified plan. Refer to Item 5 – Fees
and Compensation for further description of fees.
Services Limited to Specific Types of Investments
The Firm generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including traded REITs), variable annuities, equities, exchange-traded funds,
options, corporate bonds, treasury inflation protected/inflation linked bonds and non-U.S.
securities. We may use other securities as well to help diversify a portfolio when applicable.
A. Client Tailored Services & Client Imposed Restrictions
Specific client investment strategies and their implementation are dependent upon each
client’s current financial situation (including, but not limited to income, tax levels, and risk
tolerance levels). Clients may impose restrictions on investing in certain securities or types of
securities in accordance with their values or beliefs. To implement such restrictions, the client
must inform his or her IAR of the restrictions in writing. If, for any reason, we are unable to
meet the client restrictions, the firm and/or IAR will notify the client. If the restrictions prevent
the Firm from properly servicing the client account, or if the restrictions would require us to
deviate from our standard suite of services, we reserve the right to end the relationship.
B. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative fees.
The Firm does not sponsor any wrap fee programs. However, we have a sub-advisory
relationship with Betterment, LLC/MTG LLC (aka “Betterment Securities”). Betterment
sponsors a wrap fee program named “Betterment for Advisors.” Betterment manages the
accounts in the wrap program and remits a portion of the fee collected to the Firm.
C. Assets Under Management
C1W has the following regulatory assets under management:
Discretionary Amounts: Non-discretionary Amounts: Calculated As Of:
$ 3,430,274,684.00 $0.00 December 31, 2023