Cannon Capital Management, Inc. (“CCM” or “the Firm”) is a fee-based investment advisor that offers two
types of advisory services: 1) Portfolio Management and Financial Planning and 2) Pension Consulting and
Advisory Services.
CCM has been in business since January of 2008 and is solely owned by Clinton C. Cannon. The experience,
education and background of Clinton C. Cannon and the investment advisor representatives of CCM can be
found in the accompanying Brochure Supplement document.
Portfolio Management and Financial Planning
CCM will provide the Client a free initial consultation. Among the purposes served by the initial
consultation is to:
□ Introduce the Client to CCM’s firm, its services and staff;
□ Gather applicable information about the Client’s investment objectives, financial condition and risk
tolerance that CCM will use in establishing the parameters around which CCM will develop the
Client’s investment portfolio and financial plan; and
□ Reach an agreement on the terms of service and compensation for CCM’s services.
If the Client elects to use CCM’s portfolio management services, the Client will sign CCM’s Investment
Advisory Agreement. The Client will also sign any custodial agreements necessary to establish a custodial
account with a brokerage firm and authorize CCM to execute trades in the account for the Client. Clients
will be notified of all transactions by trade confirmations from their broker-dealer/custodian and through
communication with CCM.
CCM will also request—through the investment Advisory Agreement—that the Client provide written
authorization to allow CCM to automatically deduct its advisory fee from the Client’s account (please refer
to the “Fees and Compensation” section on pages 7-8 of this Firm Brochure). CCM will not have the authority
to make any other withdrawals from the Client’s account(s) under management.
Client accounts are managed on a discretionary basis, meaning CCM will buy or sell securities in the Client’s
account without obtaining prior approval of trades from the client. Clients may impose restrictions on
investing in certain securities or types of securities. CCM monitors Client accounts on a daily basis so that it
may make any necessary transactions to keep the Client’s account in line with its investment objectives.
CCM and the Client will establish a formal review schedule to discuss the Client’s investment portfolio, their
financial plan, and to review the investment returns generated in the portfolio and make any changes to the
parameters around which the portfolio is managed.
While CCM will have discretionary authority to execute buy and sell orders in the Client’s account, Clients
should always review their brokerage account statements to verify the trading activity and withdrawals that
occur in their account(s).
CCM uses a wide variety of investment mechanisms to create portfolios for its clients. Included in
the suite of investment choices are the following:
□ Equity or stock tools – publicly traded and exchange-listed securities, securities that are
traded over-the-counter and foreign listed issuers of stock that are American Depository
Receipts (ADR) and therefore listed on the U.S. exchanges
□ Mutual funds and Exchange traded Funds (ETF’s)
□ Corporate debt securities
□ Commercial paper
□ Certificates of deposit (CD’S)
□ Tax free debt securities often referred to as municipal debt
□ Debt issued by the U.S. Government or it’s agencies
□ Mutual funds and ETF’s that invest in similar debt instruments as those listed above
□ Alternative Investments such as Private Equity and Real Estate Investment Trusts (REIT)
There are risks associated with each type of investment vehicle used by CCM in the creation of a
portfolio. Each investment vehicle could face the possibility of bankruptcy and the value of the
underlying security, be it equity or debt, could fall to zero and result in a complete investment
loss. CCM believes that the creation of a diversified portfolio severely limits the possibility of a
complete portfolio loss; but, in an extreme environment such a possibility exists. However, CCM
does not utilize any strategies or invest in any securities in which the loss could be greater than
the investment cost of the security. CCM does not participate in any wrap fee programs.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interests
ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations;
• Never put our financial interests ahead of yours when making recommendations;
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
For more information about our conflicts of interest, please review items 5, 10, 11 and 14 or reach
out to us using the contact information on the cover page of this brochure.
As of December 31, 2023, CCM had total Assets Under Management of $304,159,448, of which
$191,709,702 are Discretionary and $112,449,746 are Non-Discretionary.
Pension Consulting and Advisory Services
CCM serves as an ERISA 3(21) investment co-fiduciary with the Plan Sponsor, a 3(38) investment - fiduciary
or a Plan Consultant for Qualified Retirement Plans at the Plan Sponsor’s direction. CCM’s compensation is
entirely fee based and includes no compensation or revenue sharing from securities used by the Plan.
CCM’s services in this area refer to 401(k) Plans.
CCM’s Pension Consulting and Advisory Services include the following:
□ Developing an Investment Policy Statement (IPS) for the Plan
□ Selecting and monitoring Plan investment options for the Plan consistent with the Plan’s IPS
□ Scheduling and developing Trustee agendas for the Plan
□ Attending, conducting and documenting Trustee meetings
□ Participant investment education – through group and one on one meetings
□ Coordinating Plan administration with the respective Plan service providers
□ Consulting with Plan trustees regarding administration and Plan compliance with rules and
regulations
CCM advocates its Pension Clients use an open architecture investment platform which allows greater
flexibility and control of the investment options used by the Plan Sponsor. When an open architecture
platform is used by the Client, CCM will create “pre-made” risk- based or Target Date investment portfolio
models for the Plan Participants to select from using the Plan investment options. The pre-made risk- based
or Target Date investment portfolios are in addition to the individual fund options from which a Plan
Participant may choose to use as their investment tools in creating their own investment portfolio. CCM will
offer direct advice when asked, but does not have the authority to direct the individual Plan Participants’
investment choices.
As such, CCM does not have discretionary control over individual Plan Participants investment decisions.
CCM’s compensation is not conditional upon the use of the pre-made risk- based or Target Date portfolio
models by the Plan Participant – please refer to the “Fees and Compensation” section on pages 7 - 8 of this
Firm Brochure.
The investment Securities used in the Pension Consulting and Advisory Services by CCM include:
□ Publicly traded Mutual Funds and Exchange Traded Funds
□ Sub-advised funds with relationships through insurance firms such as John Hancock, Principal
Financial, etc.
Funds used by Clients may consist of both actively managed and passive or indexed funds.
CCM does not offer investment advice or use other investment vehicles other than those listed
above in its Pension Consulting and Advisory Services.
There are risks associated with each type of investment vehicle recommended by CCM in the
Pension Consulting and Advisory Services. Each investment vehicle could face the possibility of
bankruptcy and the underlying funds, be it equity or debt, could fall to zero and result in a complete
investment loss. CCM believes that the creation of a diversified portfolio severely limits the
possibility of a complete portfolio loss; but, in an extreme environment such a possibility exists.
However, CCM does not recommend or provide any strategies or funds in which the loss could be
greater than the investment cost of the security.
CCM does not participate in any wrap fee programs.