A. Firm Information
C2C Wealth Management, LLC (“C2C” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under the laws
of the Commonwealth of Massachusetts. C2C was founded in October 2016 and is owned by Crown Canyon Capital,
LLC ("CCC”). CCC is owned by the Groman Family Trust Dated 12/12/12, of which Kevin Groman is a Trustee. Kevin
Groman operates C2C. This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by C2C.
B. Advisory Services Offered
C2C offers investment advisory services to individuals, and high net worth individuals, and pension and profit sharing
plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. C2C's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Wealth Management Services
C2C provides customized wealth management services for its Clients. This is achieved through continuous personal
Client contact and interaction while providing discretionary investment management, financial planning, and related
advisory services. C2C works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. C2C will then construct an investment portfolio,
consisting of low-cost, diversified mutual funds, exchange-traded funds (“ETFs”), options and/or individual stocks and
bonds to achieve the Client’s investment goals. The Advisor may also utilize unaffiliated money managers (See
“Independent Managers” below), and/or other types of investments, as appropriate, to meet the needs of the Client.
The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit
and/or tax considerations.
C2C’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. C2C will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
C2C evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. C2C may recommend, on occasion, redistributing investment allocations to diversify the portfolio. C2C may
recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing
cash positions as a possible hedge against market movement.
C2C may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will C2C accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Use of Independent Managers – C2C may recommend that a Client utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the
Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment
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management and related services. The Advisor may also assist in the development of the initial policy
recommendations and managing the ongoing Client
relationship. The Advisor will perform initial and ongoing
oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The
Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be
provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures).
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
Financial Planning Services
C2C will typically provide a variety of financial planning services to Clients, as a component of wealth management
services. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise
their investment programs, commence or alter retirement savings, establish education savings and/or charitable
giving programs.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients increase the level of investment assets
with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to
implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the
Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement
the transaction through the Advisor.
C. Client Account Management
Prior to engaging C2C to provide wealth management services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – C2C, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Asset Allocation – C2C will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – C2C will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – C2C will provide investment management and ongoing oversight
of the Client’s investment portfolio.
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D. Wrap Fee Programs
C2C does not manage or place Client assets into a wrap fee program. Wealth management services are provided
directly by C2C.
E. Assets Under Management
As of December 31, 2023, C2C manages $190,909,792 in Client assets, all of which are managed on a discretionary
basis. Clients may request more current information at any time by contacting the Advisor.