A. Description of the Advisory Firm
B. Types of Advisory Services
For both sub-advisory and model delivery arrangements, Columbus Macro selects the
securities to be bought or sold in each strategy and manages the holdings on an ongoing
basis. These securities include but are not limited to mutual funds, exchange-traded funds
(ETF), closed-end funds (CEFs), American Depository Receipts (ADRs), and equity and
fixed-income instruments. A percentage of the account may also be allocated to a third-
party asset manager.
Individual client’s open a separate account, designate Columbus Macro to be the money
manager, and select the desired Columbus Macro investment strategy in consultation
with their investment advisor.
Columbus Macro communicates primarily through the program sponsor’s employees or
registered advisors. The program sponsors are responsible for the approval of Columbus
Macro strategies for use by their registered advisors and entering into relationships with
qualified custodians.
The investment advisor representatives (IAR) are responsible for selecting the appropriate
Columbus Macro strategy for use by their clients, communicating client instructions, and
monitoring and evaluating performance of Columbus Macro. Columbus Macro will rely
on that IAR to analyze their client’s goals and needs when recommending a strategy that
we manage. The IAR will collect suitability information and work with the client to
determine which investment strategy is most appropriate for their client.
Direct Advisory
Institutional clients including states, counties, municipalities, and unions as well as
endowments, foundations, hospitals, and universities as well as high net worth families can
enter into an investment advisory agreement with Columbus Macro for customized asset
management services. Our principal responsibility under this arrangement is to manage client
assets on a discretionary basis. In this capacity we initiate and execute transactions through the
independent custodian that holds the client’s assets. We rely on the client to furnish us with
current and accurate information regarding their investment portfolio and financial situation,
including their return objectives, risk tolerance level, tax status, investment time frame and
unique circumstances including instructions to restrict certain securities not to be held within
the client’s account. Columbus Macro then creates and manages a suggested investment
portfolio. In limited circumstances, we provide the same direct advisory services to “friends
and family” at a discounted fee arrangement.
Columbus Macro may provide advisory services to retirement investors. For example,
Columbus Macro may recommend a rollover of a client’s retirement assets into an IRA
account that is managed by Columbus Macro or may recommend Columbus Macro
manage the assets of an existing IRA.
A client considering an in-service or post-employment rollover may elect to leave the
assets in the employer’s plan (if permitted); rollover the assets to a new employer’s plan
(if available and permitted); rollover the assets to an IRA; or cash out the plan assets and
pay required taxes on the distribution.
When considering a rollover to an account managed by Columbus Macro, retirement
investors should consider fees and expenses, investment options, advisory services to be
provided, the availability of penalty-free withdrawals, protection from creditors and
legal judgments, required minimum distributions, and the ability to transact in
employer stock. Additional information is available to investors through FINRA’s web
site at
www.finra.org.
By recommending the rollover of retirement plan assets to an IRA, Columbus Macro
will earn an asset-based fee for the management of the IRA account, which fee should be
expected to be higher than fees charged within a retirement plan. Opening an IRA
account may also result in additional charges such as custody fees, trading commissions
and fees charged by the underlying investments (e.g., mutual fund and ETF
management fees). Leaving assets in a retirement plan or rolling the assets to a plan
sponsored by a new employer will avoid the payment of compensation to Columbus
Macro. As a result, the Company has an incentive to encourage investors to rollover
retirement plan assets into an IRA account it will manage.
Financial Planning
Columbus Macro offers customized financial planning services to its direct advisory clients.
This service includes a wholistic approach to looking at a direct advisory client’s whole
financial picture, including the analysis of certain investments managed by Columbus Macro
as well as assets maintained outside our firm. This service is offered as part of our advisory
services and does not have an additional cost associated with it.
Commentary and Reports
Columbus Macro provides economic and market commentary. These materials include
detailed market information as well as investment/economic perspectives
and review of
Columbus Macro investment strategies.
Columbus Macro offers customized portfolio solutions for high net worth families and
institutional clients. These programs incorporate client’s unique needs, goals, and
restrictions in a personalized, holistic framework.
However, the majority of our management is through pre-defined strategies. While clients
within the same investment product are managed similarly, these clients are free to
impose reasonable restrictions that would preclude us from investing their assets in
certain securities or sectors. However, if the restrictions prevent Columbus Macro from
properly servicing the client account, or if the restrictions would require Columbus Macro
to deviate from its standard suite of services, Columbus Macro reserves the right to reject
the restriction or end the relationship.
C. Client Tailored Services and Client Imposed Restrictions
D. Wrap Fee Programs
Columbus Macro acts as a sub-advisor to a number of wrap fee programs offered by wrap
program sponsors.
These wrap fee programs are arrangements in which investment advisory services,
brokerage execution services and custody are provided by a sponsor (wrap program
sponsor) for a single predetermined fee (regardless of the number of trades executed by a
client). Generally, clients participating in a wrap fee program pay this single, all-inclusive
fee quarterly in advance to the program sponsor, based on the net assets under
management. Columbus Macro receives from the wrap program sponsor a portion of the
wrap fee for the portfolio management services it provides. For more information on the
fees, expenses, and other details of the program, clients should refer to the Wrap Fee
Program Brochure for their respective program which can be obtained from the program
sponsor or on the SEC’s websit
e www.adviserinfo.sec.gov. Columbus Macro manages the
investments in the wrap fee program but does not manage those wrap fee accounts any
differently than non-wrap fee accounts.
Columbus Macro does not sponsor any wrap fee programs.
As of December 31, 2022, Columbus Macro’s manages client assets in the amount of
$290,808,687. All of these assets under management (AUM) are discretionary.
E. Assets Under Management
Fees for asset management services provided by Columbus Macro vary depending on the
level and type of service provided and are clearly defined in each client’s advisory
agreement with the firm. These fees are generally based on the scope of engagement,
account strategy and value of assets being managed and the annual fee ranges from:
Services Annual Fee
Sub-Advisory 0.05% to 0.45%
Model Provider 0.40% to 0.50%
Direct Advisory 0.20% to 1.00%
Columbus Macro acts as a sub-advisor to program sponsors. The sub-advisory fees that
we receive are negotiated between us and the program sponsors and vary for each
relationship and strategy. The fees charged will not exceed any limit imposed by any
regulatory agency. The notice of termination requirement and payment of fees for sub-
advisor services will depend on the specific program sponsors engaging Columbus Macro
as its sub-advisor. Both the program sponsor fee and the manager’s portion are calculated
using the value of the assets in the account on the last business day of the prior billing
period.
For a certain sub-advised program (Portfolio Advisory Services), Columbus Macro
receives fixed annual fees from the program sponsor for model development and
maintenance which are not related to the level of client assets in those programs. Clients
of the sponsoring firm are not assessed a separate charge for Columbus Macro services.
Columbus Macro also participates in certain SMA/UMA programs as a model provider
for select strategies, in which Columbus Macro provides model portfolios. Generally,
clients participating in these programs pay a single, all-inclusive wrap fee quarterly in
advance to the program sponsor, based on the asset value of their account. Columbus
Macro receives from the wrap program sponsor a portion of the quarterly wrap fee for
the model provider services it provides.
Institutional and high net worth clients enter into an investment advisory agreement with
Columbus Macro for customized asset management services which specifies the fee
arrangement. These fees are negotiable. Fees assessed for direct advisory are typically
higher than sub-advisory due to the fact that clients are not represented by a separate
financial advisor. Therefore, Columbus Macro provides a higher level of client interaction,
communication, customization, and advice.
When Columbus Macro acts as a model provider, as well as in most sub-advisory cases,
program sponsors are responsible for calculating asset-based fees on the market value (as