This Disclosure document is being offered to you by CarsonAllaria Wealth Management,
LTD. (“CarsonAllaria” or “Firm”) about the investment advisory services we provide. It
discloses information about our services and the way those services are made available to
you, the client.
We are an investment management firm located in Glen Carbon, IL. Our Firm became a
registered investment adviser in August 2011. Joseph M. Allaria and Mark V. Allaria are the
owners of the Firm.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide guidance that helps clients to achieve their stated financial goals. We will offer an
initial complimentary meeting upon our discretion; however, investment advisory services
are initiated only after you and CarsonAllaria execute an Investment Management
Agreement.
Investment Management Services
We manage advisory accounts on a discretionary basis. Once we have determined a profile
and investment plan with a client, we will execute the day-to-day transactions without
seeking prior client consent. Account supervision is guided by the written profile and
investment plan of the client. We may accept accounts with certain restrictions if
circumstances warrant. We primarily allocate client assets among various equities,
Exchanged Traded Funds (“ETFs”), mutual funds, cash and debt securities in accordance
with their stated investment objectives. All of which are considered asset allocation
categories for the client’s investment strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Based on client needs,
we develop a client’s personal profile and investment plan. We then create and manage
the client’s investments based on that policy and plan. It is the client’s obligation to notify
us immediately if circumstances have changed with respect to their goals.
Once we have determined the appropriate strategy for you or your business and executed
the strategy, we will provide ongoing investment review and management services. This
approach requires us to periodically review your portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios based on the
combination of our market views and your objectives, using our investment process. We
tailor our advisory services to meet the needs of our clients and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. You will have
the ability to leave standing instructions with us to refrain from investing in particular
industries.
Where appropriate, we provide advice about concentrated stock positions held in client
portfolios. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Financial Planning
We provide financial planning services to clients. These services are provided based on the
individual needs of the client and commence after meeting with and collecting information
from the client via a wealth planning questionnaire. The menu of possible services may
include some or all of the following areas as appropriate and agreed to between the client
and Adviser. The client will not receive all of these services unless requested and
appropriate based on the client’s circumstances. It is important to note that we do not
practice law or provide accounting services.
▪ Investment planning – Review of current investments and how those investments
align with the client’s goals, objectives and risk tolerance.
▪ Retirement planning – Review retirement goals, current assets, sources of income,
current savings, etc. and provide detailed cash flow projections based upon several
variables including tax rates, anticipated rates of return, etc.
▪ Tax planning – Consideration of a client’s overall tax situation and tax implications
of various investment strategies, verification of tax cost basis for each security,
management of capital gains and losses for tax efficiency, develop a working
relationship with your accountant if requested to assist in potential tax saving
opportunities.
▪ Estate planning – Determine if estate planning documents have been executed,
make sure trusts are funded, review account registrations, and work closely with
your attorney to coordinate to any changes needed.
▪ Business planning – Assist small to medium size businesses in their implementation
of a retirement plan including custodian selection, selection of a plan design and
coordinating administrative functions with a third-party administrator.
▪ Education planning – A detailed cost projection for education expenses,
determination of the appropriate funding amount, and types of accounts
appropriate for the goal.
▪ Risk Management planning – A detailed analysis of risk management needs,
including all types of insurance coverage.
Results of the analysis or review may be provided verbally, in a written financial plan or
analysis, or delivered via online access to a financial planning or analysis tool. We may make
general recommendations as to the types of investments that may be appropriate for
clients to consider and may also provide specific investment recommendations. Financial
planning services offered by our Firm conclude upon delivery of the analysis or review. The
services do not include implementation of any investment recommendations.
Employee Retirement Income Security Act Retirement Plan Advisory Services
Our firm offers (1) Discretionary Investment Management Services, (2) Non-Discretionary
Investment Advisory Services and/or (3) Retirement Plan Consulting Services to employer-
sponsored retirement plans and their participants. Depending on the type of the Plan and
the specific arrangement with the Sponsor, we may provide one or more of these services.
Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2A
along with a copy of our Privacy Policy and the Investment Fiduciary & Retirement Plan
Consulting Agreement ("Agreement") that contains the information required under Sec.
408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as applicable.
The Agreement authorizes our Investment Adviser Representatives ("IARs") to deliver one
or more of the following services:
Discretionary Investment Management Services
These services are designed to allow the Plan fiduciary to delegate responsibility for
managing, acquiring and disposing of Plan assets that meet the requirements of the
Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these
investment management services through our IARs and charge fees as described in this
Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these services
as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to
the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may determine that
we perform the following services:
Selection, Monitoring & Replacement of Designated Investment Alternatives (“DIA”)
Advisor will review with Sponsor the investment objectives, risk tolerance and goals
of the Plan and provide to Sponsor an IPS that contains criteria from which Advisor
will select, monitor and replace the Plan's DIAs. Once approved by Sponsor, Advisor
will review the investment options available to the Plan and will select the Plan's
DIAs in accordance with the criteria set forth in the IPS. On a periodic basis, Advisor
will monitor and evaluate the DIAs and replace any DIA(s) that no longer meet the
IPS criteria.
Selection, Monitoring & Replacement of Qualified Default Investment Alternatives
(“QDIA(s)”)
Based upon the options available to the Plan, Advisor will select, monitor and
replace the Plan's QDIA(s) in accordance with the IPS.
Management Of Trust Fund
Advisor will review with Sponsor the investment objectives, risk tolerance and goals
of the Plan and provide to Sponsor an IPS that contains criteria from which Advisor
will select, monitor and replace the Plan's investments. Once approved by Sponsor,
Advisor will review the investment options available to the Plan and will select the
Plan's investments in accordance with the criteria set forth in the IPS. On a periodic
basis, Advisor will monitor and evaluate the investments and replace any
investment(s) that no longer meet the IPS criteria.
Non-Discretionary Fiduciary Services
These services are designed to allow the Sponsor to retain full discretionary authority or
control over assets of the Plan. We will solely be making recommendations to the Sponsor.
We will perform these Non-Discretionary investment advisory services through our IARs
and charge fees as described in this Form ADV and the Agreement. If the Plan is covered
by ERISA, we will perform these investment advisory services to the Plan as a "fiduciary"
defined under ERISA Section 3(21). The Sponsor may engage us to perform one or more of
the following Non-Discretionary investment advisory services:
Investment Policy Statement (“IPS”)
Advisor will review with Sponsor the investment objectives, risk tolerance and goals
of the Plan. If the Plan does not have an IPS, Advisor will provide recommendations
to Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, Advisor
will review it for consistency with the Plan's objectives. If the IPS does not represent
the objectives of the Plan, Advisor will recommend to Sponsor revisions to align the
IPS with the Plan's objectives.
Advice regarding designated investment alternatives (“DIAs”)
Based on the Plan's IPS or other guidelines established by the Plan, Advisor will
review the investment options available to the Plan and will make
recommendations to assist Sponsor with selecting DIAs to be offered to Plan
participants. Once Sponsor selects the DIAs, Advisor will, on a periodic basis and/or
upon reasonable request, provide reports and information to assist Sponsor with
monitoring the DIAs. If a DIA is required to be removed, Advisor will provide
recommendations to assist Sponsor with replacing the DIA.
Advice Regarding Qualified Default Investment Alternatives (“QDIA”)
Based on the Plan's IPS or other guidelines established by the Plan, Advisor will
review the investment options available to the Plan and will make
recommendations to assist Sponsor with selecting or replacing
the Plan's QDIA(s).
Participant Investment Advice
Advisor will meet with Plan participants, upon reasonable request, to collect
information necessary to identify the Plan participant's investment objectives, risk
tolerance, time horizon, etc. Advisor will provide written recommendations to assist
the Plan participant with creating a portfolio using the Plan's DIAs or Models, if
available. The Plan participant retains sole discretion over the investment of his/her
account.
Advice Regarding Investment of Trust Fund
Based on the Plan's IPS, Advisor will review the investment options available to the
Plan and will make recommendations to assist Sponsor with selecting investments
that meet the IPS criteria. Once Sponsor selects the investment(s), Advisor will, on
a periodic basis and/or upon reasonable request, provide reports and information
to assist Sponsor with monitoring the investment(s). If the IPS criteria require any
investment(s) to be replaced, Advisor will provide recommendations to assist
Sponsor with replacing the investment(s).
Retirement Plan Consulting Services
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in
meeting his/her fiduciary duties to administer the Plan in the best interests of Plan
participants and their beneficiaries. Retirement Plan Consulting Services are performed so
that they would not be considered “investment advice” under ERISA. The Sponsor may
elect for our IARs to assist with any of the following services:
Administrative Support
• Assist Sponsor in reviewing objectives and options available through the Plan
• Review Plan committee structure and administrative policies/procedures
• Recommend Plan participant education and communication policies under ERISA
404(c)
• Assist with development/maintenance of fiduciary audit file and document
retention policies
• Deliver fiduciary training and/or education periodically or upon reasonable request
• Recommend procedures for responding to Plan participant requests
Service Provider Support
• Assist fiduciaries with a process to select, monitor and replace service providers
• Assist fiduciaries with review of Covered Service Providers ("CSP") and fee
benchmarking
• Provide reports and/or information designed to assist fiduciaries with monitoring
CSPs
• Assist with use of ERISA Spending Accounts or Plan Expense Recapture Accounts to
pay CSPs
• Assist with preparation and review of Requests for Proposals and/or Information
• Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
• Periodic review of investment policy in the context of Plan objectives
• Assist the Plan committee with monitoring investment performance
• Assist with monitoring Designated Investment Managers and/or third-party advice
providers
• Educate Plan committee members, as needed, regarding replacement of DIA(s)
and/or QDIA(s)
Participant Services
• Facilitate group enrollment meetings and coordinate investment education
• Assist Plan participants with financial wellness education, retirement planning
and/or gap analysis
Potential Additional Retirement Services Provided Outside of the Agreement
In providing Retirement Plan Services, we and our IARs may establish a client relationship
with one or more Plan participants or beneficiaries. Such client relationships develop in
various ways, including, without limitation:
• as a result of a decision by the Plan participant or beneficiary to purchase
services from us not involving the use of Plan assets;
• as part of an individual or family financial plan for which any specific
recommendations concerning the allocation of assets or investment
recommendations relating to assets held outside of the Plan; or
• through a rollover of an Individual Retirement Account ("IRA Rollover").
If we are providing Retirement Plan Services to a plan, IARs may, when requested by a Plan
participant or beneficiary, arrange to provide services to that participant or beneficiary
through a separate agreement. If a Plan participant or beneficiary desires to affect an IRA
Rollover from the Plan to an account advised or managed by us, IAR will have a conflict of
interest if his/her fees are reasonably expected to be higher than those we would otherwise
receive in connection with the Retirement Plan Services. IAR will disclose relevant
information about the applicable fees charged by us prior to opening an IRA account. Any
decision to affect the rollover or about what to do with the rollover assets remain that of
the Plan participant or beneficiary alone.
In providing these optional services, we may offer employers and employees information
on other financial and retirement products or services offered by us and our IARs.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services. As
a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA,
(iii) the services and responsiveness of the plan’s investment professionals versus those of
our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer
and remains available to address any questions that a client or prospective client has
regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
Individually Tailored Services
When providing investment fiduciary services, we will tailor our advice or (if applicable)
discretion to meet the investment policies or other written guidelines adopted by the
Sponsor. When providing Participant Investment Advice, such advice will be based upon
the investment objectives, risk tolerance and investment time horizon of each individual
Plan participant.
Consulting Services
We provide consulting services based on the information provided by Client regarding
Client’s individual financial objectives, needs and circumstances. The specific services to be
provided are disclosed in the agreement. Our recommendations are based on the
information you provide us; therefore, the completeness and accuracy of the information
provided to us is essential. You agree to discuss with us your current financial resources
and projected needs, and to provide copies of any financial documents that we may
reasonably request as necessary to evaluate your financial circumstances and provide
consulting services. As an additional service, you may choose to have us review and update
the consulting recommendations annually or more frequently to adjust for changes in your
financial situation or investment objectives. The recommendations should be reviewed and
updated as necessary, but in any event at least annually.
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as small business consulting, real estate, pension plan consulting, or
any other specific topic. Additionally, we provide advice on non-securities matters about
the rendering of estate planning, insurance, real estate, and/or annuity advice.
In these cases, you will be required to select your own investment managers, custodian
and/or insurance companies for the implementation of consulting recommendations. If
your needs include brokerage and/or other financial services, we will recommend the use
of one of several investment managers, brokers, banks, custodians, insurance companies
or other financial professionals. You must independently evaluate these firms before
opening an account or transacting business, and you have the right to effect business
through any firm you choose.
Sub-advisory Services
Betterment for Advisors is a digital wealth management platform generally serving
independent investment advisory firms. Betterment LLC (“Betterment”), a registered
investment advisor, serves as sub-advisor to you, the Client (“Clients”). MTG LLC, dba
Betterment Securities (“Betterment Securities”), a registered broker-dealer and member
of FINRA and the SIPC, serves as broker-dealer and custodian. Betterment will manage
your portfolio on a discretionary basis. You will separately enter an agreement with
Betterment granting them discretionary authorization to buy and sell, when to buy and sell,
and in what amounts, in accordance with your investment parameters without obtaining
your prior consent or approval for each transaction. We will be available to answer any
ongoing questions regarding the program or the portfolio. Since you enter into a
discretionary arrangement with our firm, we can update your portfolio on behalf of your
account without your prior approval.
Wrap Fee Program
CarsonAllaria does not sponsor a Wrap Fee Program.
Assets
As of December 31, 2022, CarsonAllaria manages a total of $345,329,918. Total assets
under discretionary management are $345,329,918 and $0 are under non-discretionary
management. Additionally, CarsonAllaria has been engaged to serve as a 3(21) Fiduciary
on ERISA Plans totaling $44,784,518.