Prime Capital Investment Advisors, LLC (referred to as “PCIA”, “Adviser”, “Firm”, “Prime Capital Investment
Advisors” or “we” throughout this document) is an investment adviser registered with the United States Securities
and Exchange Commission. PCIA is a limited liability company (“LLC”) formed in May 2017 under the laws of the
state of Kansas. PCIA offers investment advisory and investment management services including asset
management (wrap fee management program) and allocation services, qualified retirement plan sponsor and
trustee services, financial planning services, business planning services, and consulting services. PCIA has been
registered as an investment adviser since June 23, 2017.
Our Principal Owners
Prime Capital Investment Advisors, LLC (“Firm” “PCIA”) is 100% owned by CHHSZ Holdings, LLC. CHHSZ Holdings,
LLC is a limited liability company “LLC” formed in October 2019 under the laws of the state of Delaware. The major
decisions of a strategic and administrative nature for the Firm are made by Scott Colangelo – Chairman, Brian
Dillbeck – Chief Financial and Operations Officer (“CFO”, “COO”), Scott Duba – Chief Investment Officer (“CIO”),
Tim Hakes – Vice Chairman and President, Glenn Spencer – Chief Executive Officer (“CEO”), and Anthony Woodard
– Chief Risk and Compliance Officer (“CRO”, “CCO”).
Client Assets Managed by Adviser
The amount of clients’ assets managed by Adviser (PCIA) totaled $16,687,174,483 as of December 31, 2022 of
which $7,880,967,915 was managed on a discretionary basis and $8,806,206,568 was managed on a non‐
discretionary basis. The total assets under management (“AUM”) for PCIA and all affiliates under common control
with PCIA was $18,467,623,683 as of December 31, 2022. This figure includes the aforementioned amount of
clients’ assets managed by PCIA.
Advisory and Investment Management Services Offered
Asset Management Services (“Wrap Fee Management Program”)
PCIA offers asset management services to advisory clients through wrap fee management programs. In
our wrap fee management programs, the fee for advisory services (including asset management) and
transaction costs (including ticket charges and commissions on purchase and sales of stocks, bonds,
exchange‐traded funds and options) are “wrapped” into one fee. Such Asset Management Services are
considered a wrap fee program. Whenever a fee is charged for such services, we will receive all or a
portion of the fee charged. Participants in our wrap fee management programs will receive a separate
Wrap Fee Brochure for Asset Management Services. PCIA offers asset management services to advisory
clients, which involves PCIA providing clients with continuous and ongoing supervision over their
accounts. In providing asset management services, PCIA will continuously monitor a client’s account and
make trades in his (her) accounts when necessary. PCIA will assist clients in determining their
objective(s), investment strategy, and investment suitability, prior and subsequent to opening an Asset
Management account. Through personal discussions and other means in which goals and objectives
based on a client's particular circumstances are established and after the client provides PCIA with specific
details concerning his or her current financial situation, investment objectives, and risk tolerance, PCIA
develops a client's Investment Policy Statement “IPS” or other such investment objectives. A client’s
account will be managed by PCIA based on this policy and his (her) financial situation, investment
objectives and risk tolerance. Clients may impose restrictions on investing in certain securities or types of
securities. Clients must contact us to notify of any changes in their investment objective(s), restriction(s),
and/or financial situation. PCIA will actively monitor a client’s account and will make management
recommendations and decisions regarding buying, selling, reinvesting or holding securities, cash or other
investments. PCIA provides this service to individuals, trusts, estates, charitable organizations,
corporations, qualified and non‐qualified retirement programs and deferred compensation programs.
When making the determination of whether one of the advisory programs available through PCIA is
appropriate for a client’s needs, client should bear in mind that fee‐based accounts, when compared with
commission‐based accounts, often result in lower costs during periods when trading activity is heavier,
such as the year an account is established. However, during periods when trading activity is lower, the
fee‐based account arrangements may result in a higher annual cost for transactions. Thus, depending on
a number of factors, the total cost for transactions under a fee account versus a commission account can
vary significantly. Factors which affect the total cost include account size, amount of turnover, type and
quantities of securities purchased or sold, commission rates and your tax situation. It should also be
noted that lower fees for comparable service may be available from other sources. The exact fees and
other terms will be outlined in the agreement between the client and PCIA. Clients should discuss the
advantages and disadvantages of fee‐based and commission‐based accounts with their investment
adviser representative (“IAR”) and clients should also read the Wrap Fee Disclosure Brochure carefully as
it explains, in detail, our Asset Management Services. PCIA requires that wrap‐fee clients establish
brokerage accounts with a PCIA‐approved registered broker‐dealer or qualified custodian (together
“qualified custodian”), such as Fidelity, Goldman Sachs, Schwab Advisor Services or TD Ameritrade, Inc.,
both divisions of Charles Schwab & Co., Inc. (together "Schwab"), all registered broker‐dealers, members
SIPC, to maintain custody of clients’ assets and to effect trades for their accounts participating in this
Program. The qualified custodian is the custodian for accounts established through our Asset
Management Services Program. The client will appoint PCIA as his (her) investment adviser of record on
specified accounts. The client’s account will consist only of separate account(s) held by said qualified
custodian under his (her) name. PCIA does not act as custodian and does not have direct access to client
funds and securities except to have advisory fees deducted from client’s account with the client’s prior
written authorization. The qualified custodian will maintain physical custody of all funds and securities of
a client’s account, and client will retain all rights of ownership (e.g., right to withdraw securities or cash,
exercise or delegate proxy voting and receive transaction confirmations) for his (her) account. PCIA
provides such services subject to the limitations and restrictions imposed by the custodial platform
chosen by the client. Other advisers may provide such advisory services to clients through programs,
platforms, and custodians not available to PCIA. The client will authorize PCIA to have trading
authorization on his (her) account and we will provide asset management services. The client will
authorize either discretionary or non‐discretionary management in his (her) agreement for our Asset
Management Services. If the client has authorized us to provide asset management services on a
discretionary basis, we will make all decisions to buy, sell or hold securities, cash or other investments in
the client’s managed account in our sole discretion without consulting with the client before making any
transactions. The client must provide us with written authorization to exercise this discretionary
authority, and he (she) can place reasonable restrictions and limitations on our discretionary authority.
The investment recommendations and any decisions of PCIA on behalf of participants in any strategy,
allocation, or portfolio offered by PCIA are subject to various market, currency, economic, political and
business risks, and will not necessarily be profitable or meet the needs of the client. There are risks and
loss of principal is one of those risks. The following strategies, allocations, and portfolios are available
through and are pursuant to the Firm’s Wrap Fee Management Program Wealth Management Client
Agreement:
Core Portfolios
Elements Series – Passive, index‐based strategies designed and intended for advisory accounts
with an initial investment amount, or an ongoing balance, below $2,500.
Genesis Series – Passive, index‐based strategies.
Generations Series – Passive, index‐based strategies offering a more focused equity component
across specific sub‐asset classes.
Ambassador Series – Actively managed risk‐based strategies.
Diversified Income Strategy
Satellite Strategies
Sector Rotation Strategy
Focused Equity Strategy
Tactical U.S. Equity Strategy
Tactical International Equity Strategy
Focused Yield Strategy
Select Alternative Strategy – Liquid
Total Stock Portfolio (Core‐Focused)
Covered Calls Strategy
Custom Strategies and Rep‐managed Accounts
Focused Yield PLUS Strategy
Alternative Investments
Private Offerings (available to clients who meet the definition of an “accredited investor” as
defined in Rule 501(a) of Regulation D under the Securities Act of 1933 and a "qualified client"
under Advisers Act Rule 205‐3)
Custom IPS
Custom IPS PLUS
Rep‐managed Accounts
The following strategies are pursuant to the Firm’s Performance‐Based Advisory Services Agreement and is
only available to natural individual clients meeting the SEC's definition of "qualified clients" under
Advisers Act Rule 205‐3.
Absolute Return Strategy
Opportunistic Growth Strategy
Further descriptions of the above programs are provided in the Firm’s Wrap Fee Brochure for Asset
Management Services. Strategy availability can and does change, at the sole discretion of PCIA.
Asset Management Services (using Transaction‐based Pricing Custodial Platforms)
PCIA also offers asset management services to advisory clients through “transaction‐based pricing
custodial platforms”. Such clients do not participate in the Firm’s aforementioned Wrap Fee Programs
and therefore will also pay transaction costs (including ticket charges and commissions on purchase and
sales of stocks, bonds, exchange‐traded funds and options) in addition to PCIA advisory fees. PCIA
recognizes that each client has unique investment objectives, tax considerations, income and liquidity
needs, and investment preferences. With that in mind, PCIA manages the investment process with each
client by jointly developing or utilizing a tailored investment plan or IPS that addresses those issues. The
portfolios for the client are individually invested and administered according to the client's specific plan.
Clients may impose restrictions on investing in certain securities or types of securities. Such Managed
Account Services are offered through platforms made available by PCIA‐approved custodians and mutual
funds (including mutual fund’(s) transfer agent), and certain PCIA‐approved annuity providers (insurance
companies). PCIA provides such services subject to the limitations and restrictions imposed by the
custodial platform chosen by the client. Other advisers may provide such advisory services to clients
through platforms and custodians not available to PCIA. The following strategies, allocations, and
portfolios are currently available through and are pursuant to the Firm’s transaction‐based‐pricing Wealth
Management Client Agreement:
Core Portfolios
Elements Series – Passive, index‐based strategies. This Series is designed and intended for
advisory accounts with an initial investment amount, or an ongoing balance, below $2,500.
These strategies use a mix of exchange‐traded funds (ETFs) and/or mutual funds.
Genesis Series – Passive, index‐based strategies. These strategies use a mix of exchange‐traded
funds (ETFs) and/or mutual funds.
Generations Series – Passive, index‐based strategies offering a more focused equity component
across specific sub‐asset classes. These strategies use a mix of exchange‐traded funds (ETFs)
and/or mutual funds.
Ambassador Series – Actively managed risk‐based strategies. These strategies use a mix of
mutual funds and/or ETFs. PCIA offers two subsets of Ambassador asset allocations, Standard
and Tax‐aware. Standard Ambassador asset allocations are generally recommended for qualified
accounts, such as IRAs. Tax‐aware Ambassador asset allocations seek to achieve greater tax
efficiency and are generally recommended for non‐qualified or “taxable” accounts.
Diversified Income Strategy
PCIA has developed the Diversified Income Strategy to provide clients with a tailored allocation
specifically designed for the “distribution or decumulation phase” of their retirement. The
strategy seeks to provide client with both access to the required current income and the
opportunity to meet their long‐term financial objectives through retirement. The Diversified
Income Strategy is intended for investors who need to both pay for financial goals in the near
term and who seek capital appreciation in their investments yet are reluctant to risk substantial
short‐term losses. The Diversified Income Strategy seeks to generate above‐average current
income using a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF”
covering a diverse group of asset classes. Asset classes may include dividend paying common
equity, preferred stock, publicly traded Real Estate Investment Trusts “REIT”, master limited
partnerships “MLP”, and various types of bonds. Total equity exposure, including REITs and
MLPs but excluding preferred stock, will generally target a range of 40‐50%. Total fixed income
exposure, including preferred stock and cash, will generally target a range of 50‐60%. Account
supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk
tolerance of the client.
Satellite Strategies
Sector Rotation Strategy
The Sector Rotation strategy is a sector‐based price momentum allocation that seeks to
capitalize on the continuance of existing trends in the market. The Strategy utilizes sector‐based
mutual funds and models offered by Guggenheim Partners, LLC ("Guggenheim"). The underlying
mutual funds are focused on the following eighteen (18) sectors as defined by Guggenheim:
Banking, Basic Materials, Biotechnology, Consumer Products, Electronics, Energy, Energy
Services, Financial Services, Health Care, Internet, Leisure, Precious Metals, Real Estate, Retailing,
Technology, Telecommunications, Transportation, and Utilities. PCIA evaluates the
aforementioned mutual funds on a quarterly basis using a Six (6)‐Month Lookback and a Three
(3)‐Month Holding Period. The Strategy is reallocated quarterly as needed across the three (3)
mutual funds that represent the top three (3) performing sectors as defined and determined by
Guggenheim based upon the aforementioned Lookback and Holding Periods. PCIA and
Guggenheim are not affiliated. Account supervision is guided by the stated objectives
(Investment Policy Statement “IPS”) and risk tolerance of the client.
Tactical U.S. Equity Strategy
The Tactical U.S. Equity strategy is an aggressive domestic equity strategy with a tactical, flexible
mandate that seeks to identify U.S. equity market segments most likely to outperform in the
short to intermediate terms using a “top‐down approach” consisting of a blend of mutual funds,
closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes
comprises of U.S. equities. While this strategy generally utilizes a top‐down approach, it may
also employ “thematic investing.” Asset classes may include dividend paying common equity,
U.S. domestic equity ranging across all market capitalizations, publicly traded Real Estate
Investment Trusts “REIT”, master limited partnerships “MLP”, preferred stock, and fixed income.
Total U.S. equity exposure, including REITs, MLPs, and thematic investments will generally target
a 99% allocation. Given the strategy’s objective to achieve capital appreciation, total fixed
income, including preferred stock and cash, will generally target a 1% allocation weighting, with
the ability to hold up to 25% during times of extreme volatility or rapidly declining market
environments. The strategy is reviewed on a frequent basis (no less than monthly) with a
shorter‐term (3‐6‐month forward looking) tactical allocation outlook perspective.
Tactical International Equity Strategy
The Tactical International Equity strategy is an aggressive foreign equity strategy with a tactical,
flexible mandate that seeks to identify foreign equity market segments most likely to outperform
in the short to intermediate terms using a “top‐down approach” consisting of a blend of mutual
funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset
classes comprises of non‐U.S. equities. While this strategy generally utilizes a top‐down
approach, it may also employ “thematic investing.” Asset classes may include dividend paying
common equity, foreign equity ranging across all market capitalizations, publicly traded Real
Estate Investment Trusts “REIT”, master limited partnerships “MLP”, preferred stock, and fixed
income. Total foreign equity exposure, including REITs, MLPs, and thematic investments will
generally target a 99% allocation. Given the fund’s objective to achieve capital appreciation,
total fixed income, including preferred stock and cash, will generally target a 1% allocation
weighting, with the ability to hold up to 25% during times of extreme volatility or rapidly
declining market environments. The strategy is reviewed on a frequent basis (no less than
monthly) basis with a shorter‐term (3‐6‐month forward looking) tactical allocation outlook
perspective.
Focused Equity Strategy
Focused Equity is an aggressive equity strategy with a flexible mandate that seeks to identify
market segments most likely to outperform in the short to intermediate term using a “top‐down
approach” consisting of a blend of mutual funds, closed‐end funds, and exchange‐traded funds
“ETF” covering a diverse group of asset classes. While this strategy generally utilizes a top‐down
approach, it may also employ “thematic investing”. Asset classes may include dividend paying
common equity, U.S. domestic equity ranging across all market capitalizations, international
equity, publicly traded Real Estate Investment Trusts “REIT”, Master Limited Partnerships “MLP”,
preferred stock, and fixed income. Total equity exposure, including REITs, MLPs, will generally
target a 99% allocation weighting. Given the strategy’s objective to outperform the S&P 500 TR,
total fixed income, including preferred stock and cash, will generally target a 1% allocation
weighting, with the ability to increase to a 25% weighting during times of extreme volatility or
rapidly declining market environments. This strategy is reviewed on a monthly basis and has a
shorter‐term (6‐month forward looking) tactical outlook. Account supervision is guided by the
stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client.
Focused Yield Strategy
The Focused Yield strategy is designed to aggressively pursue a high level of current income using
a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse
group of asset classes. Asset classes may include dividend paying common equity, U.S. domestic
equity ranging across all market capitalizations, international equity, publicly traded Real Estate
Investment Trusts “REIT”, Master Limited Partnerships “MLP”, preferred stock, fixed income, and
alternative investments. Generally, the strategy will seek globally geographic and asset type
diversification, but given the fund’s objective to produce a high level of current income with a
minimum target of 6%, the strategy typically will have a larger allocation to fixed income
instruments. Account supervision is guided by the stated objectives (Investment Policy
Statement “IPS”) and risk tolerance of the client.
Select Alternative Strategy – Liquid
The Select Alternative Strategy ‐ Liquid is designed to generate capital appreciation and capital
preservation in all market conditions, with low volatility and low correlation to the U.S. domestic
equity markets (reference S&P 500 Total Return “TR”). This strategy utilizes a blend of mutual
funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset
classes. This strategy primarily invests in the non‐Traditional or alternative asset classes as listed
below. This strategy may also invest a portion of assets in traditional fixed income. While the
portfolio is reviewed periodically, in general 60% of the portfolio will remain relatively static,
with either negative or very low correlation to the S&P 500 TR. The remaining 40% will be more
opportunistic, focusing on a relatively short‐term market outlook of six (6) to nine (9) months.
Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and
risk tolerance of the client.
Total Stock Portfolio (Core‐Focused)
A Core‐Focused Total Stock Portfolio is designed to generate returns greater than the S&P 500
Total Return “TR” using a blend of stocks (common and preferred) covering a diverse group of
asset classes. A Core‐Focused Total Stock Portfolio generally utilizes a “top‐down approach” and
may also employ a “bottom‐up approach” and “thematic investing”. Asset classes may include
common equity, U.S. domestic equity ranging across all market capitalizations, international
equity, publicly traded Real Estate Investment Trusts “REIT”, Master Limited Partnerships “MLP”,
and preferred stock. A Core‐Focused Total Stock Portfolio is generally reviewed on a quarterly
basis and has a shorter‐term (12‐month forward looking) tactical outlook. A Core‐Focused Total
Stock Portfolio is generally to be diversified or invested across a minimum of three (3) different
Sectors as defined by GICS. A Core‐Focused Total Stock Portfolio is generally required to hold a
minimum of fifteen (15) separate positions wherein a single position should not account for
more than twelve‐percent (12%) of the overall Portfolio allocation. The “universe” of companies
whose stock is available for inclusion in a Core‐Focused Total Stock Portfolio is subject to the
following parameters:
Minimum of 50% from S&P 500*
Maximum of 20% from S&P Mid‐Cap 400*
Maximum of 15% from S&P Small‐Cap 600*
Maximum of 15% from MSCI EAFE*
* Index references a respective iShares Exchange Traded Fund (“ETF”) as defined and determined by
BlackRock, Inc. Differences in the underlying constituents/components of an actual current index as
constructed by Standard & Poor’s Financial Services LLC (“S&P”) or MSCI Inc. (“MSCI”) and an iShares ETF are
possible. PCIA and BlackRock, Inc. (iShares) are not affiliated.
A Core‐Focused Total Stock Portfolio will generally invest in a balanced blend of “Value” stocks,
“Blend/Core” stocks, and “Growth” stocks, as defined and classified by Morningstar. As such,
this Strategy will generally target an overall “Value to Growth” ratio of 1:1 (+/‐ 10%) as
determined by Morningstar. For purposes of this Strategy, stocks that are classified by
Morningstar as “Blend/Core” will generally be considered to have a “Value to Growth” ratio of
1:1. Given the Strategy’s objective to outperform the S&P 500 TR, cash/money market will
generally maintain an allocation weighting of less than 5%, with the ability to increase to a 25%
weighting during times of extreme volatility or rapidly declining market environments. Account
supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk
tolerance of the client. PCIA and Morningstar are not affiliated.
Custom Strategies
Alternative Investments
From time to time, PCIA makes certain alternative investments available to clients who want to
(1) have exposure to non‐correlated asset classes and/or (2) aggressively pursue growth or a high
level of current income through access to non‐traditional asset classes. Alternative investments
include certain open‐end and closed‐end mutual funds, interval funds, Master Limited
Partnership (“MLP”) shares and non‐traded securities (i.e., Real Estate Investment Trusts “REITS”
and Business Development Companies “BDC”). PCIA may recommend alternative investments as
part of a custom portfolio (see below) or as a “stand‐alone” sleeve or account. Investments by a
client in an alternative investment may be on a non‐discretionary basis. In these situations,
clients must affirmatively subscribe for any such investment. Investors in such alternative
investments must meet specific suitability and investor eligibility requirements in order to invest
and specific opportunities may require higher levels of investment. PCIA recommends that
investment into alternative investments and other such asset classes/types that are not readily
(daily) liquid, in aggregate, encompass no more than 20% of an investor’s total investable net
worth (INW). Furthermore, the alternative investment component of a custom portfolio
managed by PCIA will comprise no more than 40% of the portfolio’s overall allocation, with no
more than 20% allocated to a single offering. The solicitation or allocation of alternative
investments across client portfolios is on a “client‐by‐client” basis and is generally not
accomplished or executed on a pro rata basis as a number of factors will determine whether the
alternative investment is appropriate or suitable for a client. Factors which impact the
solicitation or allocation of such investments, include but are not limited to, account size,
liquidity, investor qualification, and risk tolerance. Investing in alternative investments is
aggressive, involves a high degree of financial risk, and therefore should always be considered a
long‐term investment, many times with an indeterminate holding period and with no or very
limited liquidity. Interests in non‐traded securities are generally not transferable or assignable.
Any repurchase features detailed in offering documents are not a guarantee that any of your
non‐traded shares will be repurchased at your request and should such repurchase take place,
there likely will be an early redemption penalty. There are risks associated with alternative
investments and entire loss of principal is one of those risks. PCIA believes alternative
investments are generally best‐suited for investors who have either a Balanced, Growth, or an
Aggressive risk profile as indicated by the Risk Tolerance Survey Questionnaire, but may be
utilized in combination with less aggressive investment strategies to further increase
diversification. However, investors who choose to participate in alternative investments and
whom have a risk profile that differs from the recommended profile(s) listed above should
understand that they will be subject to a different degree of risk exposure.
Private Offerings
From time to time, PCIA makes certain private offerings available to clients who (1) meet the
definition of an “Accredited Investor” as such term is defined in Rule 501(a) of Regulation D
under the Securities Act of 1933, (2) meet the definition of a "Qualified Client" under Investment
Advisers Act of 1940 Rule 205‐3, and (3) want to aggressively pursue growth or a high level of
current income through access to private markets. To be considered a qualified client, the client
must have, or we must have reasonable belief that the client has, a net worth of more than
$2,200,000 (excluding the client’s primary residence) at the time the investment advisory
agreement is executed. Sponsors of private offerings may impose additional, more restrictive
standards for eligibility. A private offering or placement is an offering of unregistered securities
to a limited pool of investors. In a private offering, a company sells shares of stock in the
company or other interest in the company, such as warrants, limited partnerships interests, or
bonds, in exchange for cash. Hedge funds and other private funds also engage in private
offerings. Such offerings are not and will not be registered under the Securities Act of 1933, state
securities laws, or the securities laws of any other jurisdiction. PCIA may recommend private
offerings as part of a custom portfolio (see below) or as a “stand‐alone” sleeve or account.
Investments by a client in a private offering will be on a non‐discretionary basis. As a result,
clients must affirmatively subscribe for any such investment. Investors in such private offerings
must meet specific suitability and investor eligibility requirements in order to invest and specific
opportunities may require higher levels of investment. PCIA generally recommends an
investment amount of no more than 20% of total investable net worth (in aggregate) in private
offerings and other such asset classes/types that are not readily (daily) liquid. Furthermore, the
private offering component of a custom portfolio managed by PCIA will comprise no more than
40% of the portfolio’s overall allocation, with no more than 20% allocated to a single private
offering. PCIA also generally recommends that investment into private offerings that are
classified as, or primarily act as, “venture capital”, in aggregate, encompass 5%, or less,
(maximum of 10% in certain circumstances) of a client’s total investable net worth, due to the
higher level of inherent risk. Should client desire PCIA to manage the portion of his or her
investment into a private offering (“committed capital”) that is considered “uncalled capital”,
PCIA recommends that such portion remain invested into the following standard mutual fund
and exchange‐traded fund allocation: 1/9 "Short‐Term" Treasury Bond Fund (i.e. remaining
maturities 1 to 3 years) + 1/9 "Intermediate‐Term" Treasury Bond Fund (i.e. remaining maturities
3 to 7 years) + 1/9 "Intermediate‐Term" Treasury Bond Fund (i.e. remaining maturities 7 to 10
years) + 6/9 “2/3” into the Firm’s Genesis Conservative, Genesis Balanced, or Genesis Aggressive
allocation. Clients also have the option to manage or self‐direct their uncalled capital. Please
note that investing uncalled capital into a separate allocation that involves asset types other than
money market funds, adds additional layers of risk, including loss of principal, and that any such
loss will require client to commit additional assets or monies in order to fulfill his or her private
offering obligations and commitments. The solicitation or allocation of these offerings across
qualified client portfolios is on a “client‐by‐client” basis and is generally not accomplished or
executed on a pro rata basis as a number of factors will determine whether the private offering is
appropriate or suitable for a client. Factors which impact the solicitation or allocation of such
offerings, include but are not limited to, account size, liquidity, investor qualification, and risk
tolerance. Please see the section below titled “Additional Compensation, Economic and Non‐
Economic Benefits” under Item 4 of this Brochure for a description of our conflict(s) of interest
associated with certain Private Offerings. Investing in private offerings is speculative, involves a
high degree of financial risk, and therefore should always be considered a long‐term investment,
with an indeterminate holding period and with no or very limited liquidity. Interests in such
offerings are generally not transferable or assignable. Any repurchase features detailed in an
offering memorandum are not a guarantee that any of your private offering shares will be
repurchased at your request and should such repurchase take place, there likely will be an early
redemption penalty. There are risks associated with private offerings and entire loss of principal
is one of those risks. PCIA believes private offerings are generally best‐suited for investors who
have either a Growth or an Aggressive risk profile as indicated by the Risk Tolerance Survey
Questionnaire, but may be utilized in combination with less aggressive investment strategies to
further increase diversification. However, investors who choose to participate in private
offerings and whom have a risk profile that differs from the recommended profile(s) listed above
should understand that they will be subject to a different degree of risk exposure.
Custom IPS, Custom IPS PLUS, and Rep‐managed Accounts
Portfolio Corridors
Most portfolios by nature have a basic “Equity to Fixed Income” composition. “Equity”
asset types generally include stocks and equity‐based mutual funds or exchange‐traded
funds “ETF”. “Fixed Income” asset types generally include bonds, bond mutual funds or
exchange‐traded funds/notes “ETF”/ “ETN”, and cash equivalents, such as money
market instruments. Therefore, your PCIA Custom IPS, Custom IPS PLUS, or Rep‐
managed Account portfolio will generally adhere to one of the following Portfolio
Corridors and their corresponding base “Equity to Fixed Income” guidelines.
Conservative (1)
Conservative portfolios will adhere to a base 25/75 “Equity to Fixed
Income” guideline with a tolerance of (+/‐ 10).
Moderately Conservative (2)
Moderately Conservative portfolios will adhere to a base 40/60
“Equity to Fixed Income” guideline with a tolerance of (+/‐ 10).
Balanced (3)
Balanced portfolios will adhere to a base 60/40 “Equity to Fixed
Income” guideline with a tolerance of (+/‐ 10).
Growth (4)
Growth portfolios will adhere to a base 75/25 “Equity to Fixed
Income” guideline with a tolerance of (+/‐ 10).
Aggressive (5)
Aggressive portfolios will adhere to a base 90/10 “Equity to Fixed
Income” guideline with a tolerance of (+/‐ 10).
As a reminder, the private offering or alternative investment component of a custom portfolio
managed by PCIA will generally comprise no more than 40% of the portfolio’s overall allocation,
with no more than 20% allocated to a single private offering or alternative investment.
Rep‐managed Accounts
Your PCIA rep‐advisor provides discretionary asset management services to your advisory
account(s) and asset(s), including solely selecting and trading the specific securities that make up
your investment allocation(s) or portfolio(s).
Note: Core Portfolios and Satellite Strategies are only available on or through a brokerage custodian.
Such items cannot be used with annuities or direct‐held mutual funds. Strategy availability can and does
change, at the sole discretion of PCIA.
Asset Management Services (Discretionary) through Pontera (formerly FeeX)
Certain client accounts receiving PCIA’s asset management services through transaction‐based pricing
custodial platforms may be held at a custodian that is not directly accessible to our firm (“Held Away
Accounts”). We can manage these Held Away Accounts using a third‐party platform called Pontera Order
Management System (“Pontera”) (formerly FeeX). Specifically, PCIA uses Pontera to implement ongoing
tax‐efficient asset allocation and opportunistic
rebalancing strategies for held away assets such as defined
contribution plan participant accounts (e.g., 401(k) accounts) and HSAs, with discretion. All clients
engaging in Asset Management Services for Held Away Assets must either engage in Comprehensive
Financial Planning with discretionary investment (asset) management (as described in this Brochure) or
meet a $100,000 minimum of assets under management. Pontera allows PCIA to avoid being considered
to have custody of Client funds since we do not have direct access to Client log‐in credentials to affect
trades or withdraw funds. We are not affiliated with Pontera in any way and receive no compensation
from Pontera for using its platform. A link will be provided to clients allowing them to connect their
account(s) to the platform. Once client account(s) are connected to the platform, PCIA will review the
current account allocations. When deemed necessary, our firm will rebalance the account considering
client investment goals and risk tolerance, and any change in allocations will consider current economic
and market trends. The goal is to improve account performance over time, minimize loss during difficult
markets, and manage internal fees that harm account performance. No guarantees expressed or implied.
Managed Account Allocations for Plan Participants
PCIA also offers its discretionary investment advisory services to 401(k), 403(b), Employee Stock
Ownership Plans (ESOP), profit sharing, defined benefit pension and deferred compensation plans and
their participants. These services are currently offered through platforms made available by firms that
include, but are not limited to Ascensus, Empower Retirement, Fidelity, Newport Group, OneAmerica,
Principal Financial, Prudential, TIAA‐CREF, Transamerica Retirement Solutions, and through other Plan
administrator firms, custodians, and record keepers that clear through Fidelity, Matrix Financial Solutions,
Inc., Mid Atlantic Trust Company, Reliance Trust Company, Schwab, State Street, and Wilmington Trust.
In some instances, PCIA will work with a designated subadvisor or co‐fiduciary to provide these services.
PCIA provides such qualified retirement plan services subject to the limitations and restrictions imposed
by the applicable platform chosen by the client. Other advisers may provide such advisory services to
retirement plans through platforms and custodians not available to PCIA. By electing these investment
advisory services, Plan(s) and Plan participants are offered either risk based managed account allocations
(Conservative Income/Conservative, Income/Moderately Conservative, Conservative Growth/Balanced,
Growth and Aggressive/Aggressive Growth) or goals‐based managed account allocations. Goals‐based
managed account allocations are based primarily on a plan participant's years until retirement and
desired retirement income, but can be further personalized based on a plan participant's individual
circumstances. These allocations are comprised of investment options made available through and
custodied by the applicable platform provider. As part of its Qualified Plan Investment Advisory
recommendations, PCIA may from time‐to‐time cover expenses incurred by Qualified Plan participants as
part of any investment option change, transfer or rebalance which triggers a charge, adjustment or fee to
the participant. The facts and circumstances of any type of expense coverage by PCIA will be fully
disclosed to the applicable Qualified Plan Sponsor and Qualified Plan participant(s) prior to payment by
PCIA and crediting to the respective participant account.
Qualified Retirement Plan Sponsor and Trustee Services
PCIA, doing business as, Qualified Plan Advisors (“QPA”), also offers Qualified Retirement Plan services to
Plan Sponsors and/or Plan Trustees. These services include design, implementation, monitoring and
reporting of a Plan's Investment Policy Statement; analysis, monitoring and reporting of investment
options made available to Plan participants; ERISA Section 3(38) investment manager services; Pension
consulting; Plan design consulting; Form 5500 review; Plan trustee fiduciary communication and training;
Plan benchmarking reporting; Plan Participant enrollments and education; Plan Health; a stream‐lined
ERISA Section 3(38) plan‐level fiduciary service engagement named Fiduciary Complete. Such services do
not constitute accounting or legal advice. PCIA does not custody plan assets and is not a recordkeeper or
third‐party administrator. PCIA provides qualified retirement plan advisory, plan sponsor and trustee
services subject to the limitations and restrictions imposed by the applicable platform chosen by the
client. Other advisers may provide such advisory services to retirement plans through platforms and
custodians not available to PCIA.
Collective Investment Funds Services
A collective investment fund also known as a collective investment trust is a bank‐maintained fund that is
exempt from registration as a mutual fund under the Investment Company Act of 1940 and only available
to qualified retirement plans. PCIA offers investment advisory services by serving as an investment
adviser to the Fiduciary Investment Trust (including Core Series) funds (also referred to as the Funds
throughout this brochure). The Funds are organized as collective investment trusts. Comerica Bank &
Trust, National Association (“Comerica”) serves as the Funds’ trustee and administrator, hires and fires
the investment adviser of the Funds and selects the qualified custodian. Comerica has established
accounts for the Funds at its bank, which serves as the qualified custodian. UMB Fund Services provides
the Funds with fund administration and accounting, omnibus transfer agency and sales support. As
investment adviser PCIA provides investment advice and management services to the Funds. The Funds
are available only to retirement plans as an investment option: Aggressive; Growth; Balanced; Moderately
Conservative; Conservative; and Core Series: Large Cap; Mid Cap; Small Cap; International Equity; Bond;
Opportunistic Global Yield. Some retirement plans investing in the Funds could also be clients of PCIA.
Where such a plan is otherwise a client of PCIA, PCIA may perform Fiduciary Consulting Services, except
for selecting, monitoring or recommending any Funds, in which case it will receive a fee for such plan‐
level service. The plan sponsor is responsible for selecting and monitoring Funds. The investment
management fee paid by the Funds to PCIA may be at a rate that is higher than the fee PCIA typically
receives from the plan for the plan‐level Fiduciary Consulting Services. Please refer to Item 5 of this
Brochure for a description of our fees. Increases in Funds assets will result in increases in total
management fees paid to PCIA. In recognition of that incentive and to avoid any potential conflict of
interest, any retirement plan utilizing PCIA’s Fiduciary Consulting Services will need to make its own
independent investigation and evaluation of the Funds. The Funds currently compose the sole collective
investment fund client advised by PCIA. PCIA maintains limited power of attorney to act on a discretionary
basis when managing the investments of the Funds. PCIA is responsible for investment selection, asset
allocation, and asset management decisions regarding the Funds. PCIA does not have authority to
disburse assets or securities from the Funds.
Financial Planning Services
PCIA also offers financial planning services for individuals, families, estates, and businesses including
investment advice. An agreement is executed by the client and PCIA outlining the terms and fees
associated with developing a client's financial plan. The purpose of this service is solely to create a
financial plan for the client. The planning process focuses on such areas as developing a comprehensive
financial plan, portfolio evaluation, cash flow analysis, education planning, retirement account investment
analysis, retirement planning, tax projections and planning, risk management, including a review of
insurance coverage (which will exclude property and casualty insurance), estate analysis and planning,
planning for special needs family members, negotiation of the purchase of substantial assets, and
budgeting. This service may or may not grant discretionary power to PCIA or IAR. Fees for financial
planning services may be charged when assets are not under management of PCIA and depend on the
nature and complexity of the client's circumstances and needs. Clients may also elect to receive certain
financial planning services on a monthly subscription basis. The exact fees and other terms (including
discretion) will be outlined in the agreement between you and PCIA. A client’s IAR may be a Registered
Representative of Private Client Services (“Broker‐Dealer”), which is a Broker‐Dealer registered with the
Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority
(“FINRA”). PCIA and Private Client Services are not affiliated. A client’s IAR as a Registered Representative
is capable of effecting on the client’s behalf transactions in various securities products, including stocks,
bonds, mutual funds, variable annuities, and variable life insurance. However, a client is always free to
execute securities transactions and purchase insurance products through someone other than his or her
PCIA IAR. If a client chooses to purchase securities products through his or her PCIA IAR in the capacity as
a Registered Representative, then all such transactions will be placed through Private Client Services.
Broker‐Dealers are required to supervise the securities trading of their representatives. In this event,
Private Client Services and Client’s Registered Representative will receive compensation, including
commissions and possible 12b‐1 fees normally paid in connection with the sale of securities products. If a
client elects to purchase insurance products through his or her PCIA IAR, IAR will receive commissions
normally paid in connection with these products in a separate capacity as a licensed insurance agent. The
aforementioned compensation will be in addition to the fees a client will pay for “Financial Planning
Services”. Please see Item 14 of this Brochure for more information about the conflicts of interest
associated with this arrangement. PCIA provides the following types of financial planning services:
Custom Financial Planning Services
Available Financial Planning Services
Retirement Planning
College/Education Saving
Major Purchases
Budget/Cash‐flow Analysis
Investment Management
Tax Planning, Projection
Risk/Insurance Analysis
Estate Review & Analysis
Caring for parents / special needs planning
Charitable Giving
Business valuations and buy/sell planning (for business owners)
Special Notice regarding Estate Planning and Tax Planning Services
Since PCIA does not practice law or accountancy, this work will generally be done in coordination
with lawyers and accountants separately selected and employed by the client.
Business Planning Services and Consulting Services
Business planning services include working with a client's legal and accounting professionals to gather and
analyze the client's current circumstances, to help define the client's cash flow management, company
financing, business valuation, succession planning, qualified corporate risk management and choice of
entity. Consulting services provided by PCIA include but are not limited to monitoring and performance
reporting, investment manager review and selection, documentation review and analysis of general
financial markets, public security markets and sector industries, and financial education and/or coaching.
In addition, consulting services could include review and analysis of qualified and non‐qualified retirement
program design, operations, fee and/or expense structure and investment options. Since PCIA does not
practice law or accountancy, this work will generally be done in coordination with lawyers and
accountants separately selected and employed by the client. These services may or may not grant
discretionary power to PCIA or IAR. Fees for business planning services or consulting services may be
charged when assets are not under management of PCIA and depend on the nature and complexity of the
client's circumstances and needs. The exact fees and other terms (including discretion) will be outlined in
the agreement between you and PCIA. A client’s IAR may be a Registered Representative of Private Client
Services (“Broker‐Dealer”), which is a Broker‐Dealer registered with the Securities Exchange Commission
(“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”). PCIA and Private Client
Services are not affiliated. A client’s IAR as a Registered Representative is capable of effecting on the
client’s behalf transactions in various securities products, including stocks, bonds, mutual funds, variable
annuities, and variable life insurance. However, a client is always free to execute securities transactions
and purchase insurance products through someone other than his or her PCIA IAR. If a client chooses to
purchase securities products through his or her PCIA IAR in the capacity as a Registered Representative,
then all such transactions will be placed through Private Client Services. Broker‐Dealers are required to
supervise the securities trading of their representatives. In this event, Private Client Services and Client’s
Registered Representative will receive compensation, including commissions and possible 12b‐1 fees
normally paid in connection with the sale of securities products. If a client elects to purchase insurance
products through his or her PCIA IAR, IAR will receive commissions normally paid in connection with these
products in a separate capacity as a licensed insurance agent. The aforementioned compensation will be
in addition to the fees a client will pay for “Business Planning Services” or “Consulting Services”. Please
see Item 14 of this Brochure for more information about the conflicts of interest associated with this
arrangement.
Consulting services to an Exchange Traded Fund (ETF)
PCIA established and maintains a consulting arrangement with the sponsor company of, and related
advisory firm for, B.A.D. ETF (“Fund Sponsor”). Certain PCIA employees and representatives, including
members of PCIA’s ownership and leadership, also acquired and maintain an ownership stake in the Fund
Sponsor. Please see Item 14 of this Brochure for more information about the conflicts of interest
associated with this arrangement.
Seminar(s) for Fee(s)
Please note that this section refers to educational seminars for individuals and does not refer to
retirement plan sponsor/participant education. The intent of an educational seminar is to provide the
attendee with various educational topics that are general in nature. The educational seminar will be
impersonal and not take into account the individual circumstances of the attendee. As such, the
educational seminar should not be considered a comprehensive review, analysis or customized advice in
regards to the attendee’s individual situation. The educational seminar is not a substitute for or the same
as a consultation with an investment adviser in a one‐on‐one context whereby all the facts of the
attendee’s situation can be considered in their entirety and the investment adviser can provide
individualized investment advice or a customized financial plan. It is important the attendee understands
that the services of PCIA under this type of agreement do not include any financial planning, investment
management, or supervision with respect to the attendee’s assets. In the event that attendee desires
such financial planning, investment management, or supervision services, attendee will be required to
execute a separate agreement and pay fees in addition to the fees paid by attendee to PCIA for a seminar.
PCIA requires a written Seminar Attendee Agreement to be completed for each seminar attendee before
a seminar fee may be charged. This agreement is intended to be used for public seminars and not for
client events. Again, public seminars are those seminars that are educational in nature and provided to
the general public. Conversely, a Seminar Attendee Agreement is not required when a seminar fee is not
being charged.
Third‐Party Asset Management Services
PCIA engages in the selection of third‐party money managers. Specifically, the Firm generally offers
clients access to professional third‐party money managers (“TPMM”) by means of “turnkey asset
management programs”, or TAMPs. A TAMP is a program sponsored by a third‐party that provides a wide
range of services for a program fee. Services vary depending on the program and may include one or
more of the following:
Asset allocation models
Money manager due diligence
Market and manager analysis
Client proposals and risk tolerance tools
Account administration
Performance reporting
Training and education support
Under such programs, we assist you with identifying your risk tolerance and investment objectives.
Clients who participate in a TAMP typically will complete a program questionnaire that helps to identify
their investment needs and tolerance for risk. Based on the responses to the questionnaire, client assets
will be invested in a portfolio of securities that is designed to meet their investment objectives. Clients
who wish to participate in a TAMP or use a TPMM will receive additional material about it that is prepared
by the sponsor of the TAMP (“TAMP Sponsor”) or TPMM. The additional material must be reviewed by a
client before a TAMP or TPMM account can be opened. You must enter into an agreement directly with
the TAMP Sponsor or TPMM who provides your designated account with asset management services. In
general, sponsors of TAMP programs and TPMMs are given the authority to place trades on behalf of
clients, a practice known as “discretion.” But some programs permit clients to impose reasonable
restrictions on the management of their accounts. For example, the client may be able to specify that the
client’s assets not be invested in certain types of securities, such as securities issued by tobacco
companies. The TAMP Sponsor or the TPMM determines the reasonableness of the restrictions. TAMP
Sponsors and TPMMs are responsible for continuously monitoring client accounts and making trades in
client accounts when necessary. Some TAMP Sponsors and TPMMs will not open an account unless a
specified minimum amount of money will be invested, but they usually reserve the right to waive the
requirement, and often do so. The Firm’s involvement in third‐party asset management services is
generally limited to acting as either a (1) “promoter” (formerly solicitor) or (2) “co‐advisor” for third‐party
program sponsors. The Firm’s obligations will vary to some extent depending on the nature of its role,
and also will vary from one TAMP to another or from one TPMM to another. When the Firm acts as a
promoter, it refers clients to unaffiliated investment advisers who are TAMP Sponsors or TPMMs that
offer asset management and other investment advisory services or sponsor so‐called wrap fee programs.
As a result of the referral, we are paid a portion of the fee charged and collected by the TAMP Sponsor or
TPMM in the form of promoter fees. Each solicitation arrangement is performed pursuant to a written
agreement and is in compliance with SEC Rule 206(4)‐1 and applicable state securities rules and
regulations. Clients referred by the Firm enter into an investment advisory agreement directly with the
TAMP Sponsor or TPMM, which typically may be terminated by either party upon written notice. PCIA is
not a party to this agreement and does not have investment management responsibility for the provision
of TAMP or TPMM services. Rather, the Firm’s role is limited to referring clients to the TAMP or TPMM
and performing limited advisory services, assisting with certain administrative functions, and acting as a
liaison between the client and the TAMP Sponsor or TPMM. Again, we do not have any trading authority
with respect to your designated account managed by the TAMP Sponsor or TPMM. The Firm’s rep‐advisor
will provide the client with a copy of the TAMP Sponsor’s or TPMM’s brochure describing the program, as
well as appropriate disclosure, including with regards to compensation and conflicts of interest, as
applicable. The TAMP Sponsor’s or TPMM’s brochure and investment advisory agreement should
describe its responsibilities and PCIA’s responsibilities, and should be reviewed carefully before investing
in the program. Under a typical co‐advisory arrangement, the joint client “client” enters into an
agreement with both the Firm and the TAMP Sponsor or TPMM, which may be terminated by any party
upon written notice. PCIA’s rep‐advisor performs non‐discretionary advisory tasks in addition to the
ministerial or other tasks provided in some referral or promoter arrangements, including assisting the
client with determining the appropriate asset allocation model, reviewing the client’s account activity,
and reviewing the account with the client at least annually to identify any changes in the client’s
information, financial situation, investment objectives or restrictions placed on the account. Under a co‐
advisory arrangement, PCIA and its rep‐advisors are responsible for recommending TAMP or TPMM
model allocations to clients and for determining if such recommendations are suitable for and in the best
interest of clients. To the extent the client is a “Retirement Client”, PCIA acknowledges that it is a
“fiduciary” (as defined by Employee Retirement Income Security Act of 1974 (“ERISA”) with respect to
such Account, Securities, or other Investment Property that are subject to ERISA. As a result of the co‐
advisory arrangement, we are paid a portion of the fee charged and collected by the TAMP Sponsor or
TPMM in the form of advisory fees. For all clients with TAMP or TPMM accounts, the Firm’s rep‐advisors
will, at least once per year, contact the client to review and update the client’s investment objectives and
account restrictions, investment programs or asset allocation models based on changes in the client’s
goals, objectives and/or financial situation. For more information about such programs, the fees
applicable to them, and other matters of interest, please review Item 5 of this Brochure and the
investment advisory or wrap program disclosure document of the relevant program sponsor, which will
be provided to you before an account is opened.
AssetMark, Inc.
PCIA, as a Promoter, may offer advisory services to Clients by selecting the AssetMark Platform.
For more information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure
Brochure. The minimum investment required on the AssetMark Platform depends upon the
Investment Solution chosen for a Client’s account and is generally $10,000] for Mutual Fund and
$25,000 for ETF Accounts, and from $25,000 to $1,000,000 for Privately Managed and Unified
Managed Accounts, depending on the investment strategy selected for the account. These
minimums are described in more detail in the Fees & Minimums Page in the AssetMark Platform
Disclosure Brochure. Accounts below the stated minimums may be accepted on an individual
basis at the discretion of AssetMark.
Although we review the performance of numerous third‐party investment adviser firms, we enter into
only a select number of relationships with third‐party investment adviser firms that have agreed to pay us
a portion of the overall fee charged to our clients. Therefore, PCIA has a conflict of interest in that it will
only recommend third‐party investment advisors that will agree to compensate us for referrals of our
clients. Clients are advised that there may be other third‐party managed programs not recommended by
our firm, that are suitable for the client and that may be more or less costly than arrangements
recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be
achieved by a third‐party investment adviser recommended by our firm. Further, no guarantees of
performance can ever be offered by our firm (Please refer to Item 8 of this Brochure for more details.)
Investment Advisory Services for Sub‐Advisory Relationships
PCIA may appoint a sub‐advisor to manage the assets of a client’s advisory account(s) on a discretionary
basis. After review of the information provided regarding a client’s account(s), the appointed sub‐advisor
may accept or reject its appointment by PCIA to provide investment advisory (sub‐advisory) services to
the client. Upon acceptance of its appointment by PCIA, the sub‐advisor will agree to manage the client’s
account(s) with discretion and to invest all securities and cash that a client may deposit into his or her
account(s) without prior consultation with PCIA, subject only to the investment objectives and restrictions
imposed by written notice to sub‐advisor by PCIA. A client’s PCIA rep‐advisor will assist the client with
identifying his or her risk tolerance and investment objectives. PCIA’s and its rep‐advisor(s)’
recommendation to have a sub‐advisor manage a client’s account is based on the client’s financial
situation, level of financial sophistication, investment experience, and financial goals, and PCIA’s and its
rep‐advisor(s)’ reasonable due diligence of such items and of the sub‐advisor. A PCIA rep‐advisor is also
responsible for reviewing a client’s applicable account activity, and for reviewing the client’s account(s)
with the client, at least annually, to identify any changes in the client’s information, financial situation,
investment objectives or restrictions placed on the account, and for communicating such changes to the
sub‐advisor. PCIA may exercise its fiduciary duties as required or requested by a client regarding
participation in the accounts managed by a sub‐advisor and the strategy chosen by the client. PCIA also
retains the right to terminate the aforementioned sub‐advisory relationship at its sole discretion, as PCIA
deems prudent. PCIA and a client’s PCIA rep‐advisor are also responsible for tracking and managing a
client’s cash held in his or her account(s), including deposits, contributions, withdrawals, and
distributions, and for communicating such requests to the sub‐advisor.
Other Services
Limited Advisory Services (also called Limited Scope Advisory Services)
The PCIA Limited Advisory Services or Limited Scope Advisory Services Program is a wrap fee program.
Neither PCIA nor any person associated with PCIA shall provide continuous ongoing supervision and
management for your account. PCIA will not monitor specific securities or general portfolios within your
account. You have the exclusive responsibility for the making investment decisions and monitoring of all
securities that are held in or purchased or sold for your account. Participants in this wrap fee program
will receive a separate Wrap Fee Brochure for Limited Advisory Services. PCIA will not make any
investment recommendations for your account except PCIA may provide investment recommendation for
your account in response to a specific request made by you. You understand that it will be incumbent
upon you to make such request, and PCIA may decline, at its discretion, to provide any recommendation
for your account. The Account receiving Limited Advisory Services is expressly excluded from receiving
other advisory services of PCIA, unless otherwise agreed to in writing by you and PCIA. Further
description of the above program is provided in the Firm’s Wrap Fee Brochure for Limited Advisory
Services.
Momentum
PCIA, doing business as, Qualified Plan Advisors (“QPA”), together with Empower Retirement, offers
Momentum, a service program designed for small to mid‐sized retirement plans. QPA and Empower
Retirement are not affiliated. QPA does not custody plan assets and is not a recordkeeper or third‐party
administrator. As an ERISA 3(38) Investment Manager, QPA’s services provided in connection with
Momentum include Investment Selection, Plan Design, and Fund Monitoring and Oversight. QPA also
provides Employee Education. Please see Item 4 Qualified Retirement Plan Sponsor and Trustee Services
and Item 5 Qualified Retirement Plan Investment Advisory, Plan Sponsor and/or Trustee Services Fees for
more information about QPA’s retirement plan services.
Prime Clarity and tenclient
PCIA offers Prime Clarity and tenclient. Both are enhanced service programs provided by a team of rep‐
advisors at no additional cost to applicable high net‐worth individuals and companies who qualify for
more intensive and specialized services.
Managed Account Services (for legacy Advisory clients)
Special notice regarding former advisory clients of Longer Investments, Inc.
PCIA acquired the assets of Longer Investments, Inc. (“LII”), a federally registered adviser. Former
advisory clients of LII who become clients of PCIA (i.e., legacy Advisory clients) may have advisory
accounts that continue to be subject to prior contract terms, custodial arrangements, and fee structures
in order to facilitate continuity in both service and investment management. Such terms, arrangements,
and fee structures are not otherwise available to other clients of PCIA. These accounts will continue to
utilize “transaction‐based pricing” and will not participate in the Firm’s aforementioned Wrap Fee
Programs. Instead, PCIA offers investment planning and discretionary asset management (“Managed
Account Services”) to such clients. PCIA recognizes that each client has unique investment objectives, tax
considerations, income and liquidity needs, and investment preferences. With that in mind, PCIA
manages the investment process with each client by jointly developing or utilizing a tailored investment
plan or IPS that addresses those issues. The portfolios for the client are individually invested and
administered according to the client's specific plan. Clients may impose restrictions on investing in certain
securities or types of securities. Such Managed Account Services are offered through platforms made
available by Schwab and Northern Trust Corporation.
Special notice regarding former advisory clients of Sphere, LLC.
PCIA recently acquired the assets of Sphere, LLC. (“Sphere”), a state registered adviser. Former advisory
clients of Sphere who become clients of PCIA (i.e., legacy Advisory clients) may have advisory accounts
that continue to be subject to prior contract terms, custodial arrangements, and fee structures in order to
facilitate continuity in both service and investment management. Such terms, arrangements, and fee
structures are not otherwise available to other clients of PCIA. These accounts will continue to utilize
“transaction‐based pricing” and will not participate in the Firm’s aforementioned Wrap Fee Programs.
Instead, PCIA offers investment planning and discretionary asset management (“Managed Account
Services”) to such clients. PCIA recognizes that each client has unique investment objectives, tax
considerations, income and liquidity needs, and investment preferences. With that in mind, PCIA
manages the investment process with each client by jointly developing or utilizing a tailored investment
plan or IPS that addresses those issues. The portfolios for the client are individually invested and
administered according to the client's specific plan. Clients may impose restrictions on investing in certain
securities or types of securities. Such Managed Account Services are offered through platforms made
available by Schwab and TD Ameritrade.
Advisory Services for Non‐Discretionary Assets
The scope of such services is limited to making investment recommendations with respect to the assets,
providing regular and periodic (no less than annual) supervision of the assets, implementing trades at the
client’s direction, and to otherwise perform as described in PCIA’s disclosure documents and in the
client’s specific agreement with PCIA.
Limits Its Advice to Certain Types of Investments
PCIA may provide investment advice on the following types of investments:
Certificates of deposit
Closed‐end fund shares
Collective Investment Trusts (“CIT”s)
Corporate debt securities (other than commercial paper)
Direct Participation Programs (“DPP”s)
Exchange‐listed securities
Exchange‐traded fund shares or units (“ETF”s)
Exchange‐traded notes (“ETN”s)
Foreign issues
Interests in Partnerships
Interval fund shares
Master Limited Partnerships (“MLP”s)
Municipal securities
Mutual fund shares (including money market mutual funds)
Open‐end fund shares
Options contracts on securities
Private Offerings or Placements
Real Estate Investment Trusts (“REIT”s)
Securities traded over‐the‐counter
Separate account shares
Stable value products (including guaranteed income funds)
Structured products (including structured notes)
Unit Investment Trusts (“UIT”s)
United States government securities
Variable annuities
Variable life insurance
Although we generally provide advice only on the products previously listed, we reserve the right to offer
advice on any investment product that may be suitable for each client’s specific circumstances, needs,
goals and objectives.
Advisory Services Tailored to Individual Needs of Clients
PCIA’s advisory services are always provided based on your individual needs. This means, for example, that when
we provide asset management services, you are given the ability to impose restrictions on the accounts we
manage for you, including specific investment selections and sectors. We work with you on a one‐on‐one basis
through interviews and questionnaires to determine your investment objectives and suitability information. We
will not enter into an investment adviser relationship with a prospective client whose investment objectives may
be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to
impose unduly restrictive investment guidelines. For plan participants whose accounts are serviced under the
Managed Account Allocation Program, the accounts are managed according to the selected strategy (Conservative
Income, Income, Conservative Growth, Growth, and Aggressive/Aggressive Growth), or the strategy assigned by
the goals‐based managed account methodology, and the restrictions PCIA can reasonably accommodate are more
limited. For Qualified Retirement Plan Sponsor and Trustee Services, Financial Planning Services, Business Planning
Services, and Consulting Services, the services are generally delivered upon client engagement for such services.
For these services, issues may be prioritized and addressed all at one time, for example, with delivery of a financial
plan, or alternatively, the services can be delivered over a specified duration of time, for example, if periodic
monitoring is included in the services provided to a qualified retirement plan. For advisory service programs that
are not of a limited duration, clients will have a scheduled conference with their investment adviser representative
at least annually to review any changes to the client’s goals and objectives and for clients in the Asset
Management Services Program, the Investment Policy Statement.