This Disclosure document is being offered to you by Correct Capital Wealth Management, LLC (“Correct
Capital” 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 Clayton, Missouri. We specialize in investment advisory
services for individuals, high net worth individuals, corporations and other businesses, pension and profit-
sharing plans, trusts, estates and charitable organizations. Our Firm was founded in 2018 as a registered
investment adviser and is majority owned by Brian I. Pultman.
We are committed to helping clients build, manage, and preserve their wealth, and provide clarity and
direction to help clients 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 Correct Capital
execute a signed Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts,
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 such as preferred stocks, commons stocks,
Exchanged Traded Funds (“ETFs”), CDs, no-load or load-waived mutual funds, cash and fixed income
positions in accordance with their stated investment objectives. All of which are considered asset allocation
categories for the client’s investment strategy.
During 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 or changes in their personal financial condition.
Once we have determined the types of investments to be included in your portfolio and allocated them, we
will provide ongoing investment review and management services. This approach requires us to review
your portfolio periodically.
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 or invest in limited amounts of
securities.
In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in
a pool of securities. We do have limited authority to direct the custodian to deduct our investment advisory
fees from your accounts, but only with the appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
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such as variable life insurance, annuity contracts, 529 Plans and assets held in employer-sponsored
retirement plans. In these situations, Correct Capital directs or recommends the allocation of client assets
among the various investment options available with the product. These assets are generally maintained at
the underwriting insurance company or the custodian designated by the product’s provider.
You are advised and are expected to understand that our past performance is not a guarantee of future
results. Certain capital market and economic risks exist that adversely affect an account’s performance. This
could result in capital losses in your account.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the
family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated
effort of all parties toward the client’s stated goals. Such services include various reports on specific goals
and objectives or general investment and/or planning recommendations, guidance to outside assets, and
periodic updates.
Our specific services in preparing your plan may include:
● Review and clarification of your financial goals.
● Assessment of your overall financial position including cash flow, balance sheet, investment strat-
egy, risk management, and estate planning.
● Creation of a unique plan for each goal you have, including personal and business real estate, ed-
ucation, retirement or financial independence, charitable giving, estate planning, business succes-
sion, and other personal goals.
● Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention.
● Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
including liquidity as well as various insurance and possible company benefits; and
● Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax
advisor, an estate plan to provide for you and/or your heirs in the event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the client. For younger
generational clients or clients in accumulation mode, on-going quarterly financial planning/coaching
services are offered. A quarterly review and summary of Financial Planning and coaching is delivered to
those who opt for this quarterly service. Services are agreed to between the Client and Correct Capital using
a separate Financial Planning Agreement.
Clients should be aware a conflict exists between the interests of the investment adviser and the interests
of the client. The client is under no obligation to act upon the investment adviser's recommendation, and
if the client elects to act on any of the recommendations, the client is under no obligation to affect the
transaction through the investment adviser.
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RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services includes providing participant enrollment meetings and assisting with
participant education. While the primary clients for these services will be pension, profit sharing and 401(k)
plans, we offer these services, where appropriate, to individuals and trusts and organizations.
When serving as an ERISA 3(21) investment advisor, the Plan Sponsor, and our Firm share fiduciary
responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may
accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor
Investment Management Agreement between our Firm and the Plan Sponsor. Under the 3(21) agreement,
Our Firm provides the following services to the Plan Sponsor:
▪ Screen investments and make recommendations.
▪ Monitor the investments and suggests replacement investments when appropriate.
▪ Provide a quarterly monitoring report.
▪ Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
▪ Recommend QDIA alternatives.
▪ Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial
education to Plan participants, participant seminars, benchmarking the Plan services, education to fiduciary
committee members, and monitoring the service provider. The scope of education provided to participants
will not constitute “investment advice” within the meaning of ERISA, and participant education will relate
to general principles for investing and information about the investment options currently in the Plan. We
may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for
new participants.
THIRD PARTY MONEY MANAGERS
Our Firm may determine that engaging the expertise of an independent third-party money manager
(“TPMM’) is best suited for the client’s account. If deemed appropriate for the client, our Firm will
recommend utilizing an independent TPMM to aid in the implementation of investment strategies for the
client’s portfolio. In certain circumstances, we may allocate a portion of a portfolio to the TPMM for
separate account management based upon the client’s individual circumstances and objectives, including,
but not limited to, your account size and tax circumstances. Upon the recognition of such situations, in
coordination with the client, the client will engage directly with the TPMM for the management of those
assets. These TPMMs shall assist our Firm in managing the day‐to‐day investment operations
of the
various allocations, shall determine the composition of the investments comprising the allocation, shall
determine what securities and other assets of the allocation will be acquired, held, disposed of or loaned
in conformity with the written investment objectives, policies, and restrictions and other statements of
each client comprising the allocation, or as instructed by our Firm.
TPMMs selected for your investments need to meet several quantitative and qualitative criteria established
by us. Among the criteria that may be considered are the TPMM’s experience, assets under management,
performance record, client retention, the level of client services provided, investment style, buy and sell
disciplines, capitalization level, and the general investment process.
The client is advised and should understand that:
▪ A TPMM’s past performance is no guarantee of future results;
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▪ There is a certain market and/or interest rate risk which may adversely affect any TPMM’s
objectives and strategies, and could cause a loss in a client's account(s); and
▪ Client risk parameters or comparative index selections provided to our Firm are guidelines only,
and there is no guarantee that they will be met or not be exceeded.
TPMMs take discretionary authority to determine the securities to be purchased and sold for the client. Our
Firm will work with the TPMM to communicate any trading restrictions or standing instructions to refrain
from a particular industry requested by the client. In all cases, trading restrictions will depend on the TPMM
and their ability to accommodate such restrictions.
We review the performance of our TPMMs on a periodic basis. More frequent reviews may be triggered by
changes in the TPMM’s management, performance or geopolitical and macroeconomic specific events.
Our Firm only enters into only a select number of relationships with TPMMs.
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 also reviewed by our Firm’s Chief Compliance Officer in a best effort to
determine that the recommendation to a client was reasonable or that the client has determined to make
the rollover after being provided ample information about their options. No client is under any obligation
to roll over plan assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the
account while maintained with the client's employer. Our Firm’s Chief Compliance Officer remains available
to address any questions that a client or prospective client has regarding this disclosure.
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.
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PARTICIPANT ACCOUNT MANAGEMENT (DISCRETIONARY)
We use a third-party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows us 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. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A
link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Adviser will review the current account allocations. When deemed
necessary, Adviser 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. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as
deemed necessary.
ENVESTNET PRIVATE WEALTH MANAGEMENT
We offer separately managed account services through Envestnet’s Private Wealth Management program.
For all Programs, we will compile pertinent financial and demographic information to develop an
investment program that will meet your goals and objectives. Utilizing the Envestnet platform tools, your
assets will be allocated among the different options in the Program and determine the suitability of the
asset allocation and investment options, based on your needs and objectives, investment time horizon, risk
tolerance and any other pertinent factors.
Envestnet provide an extensive range of investment advisory services through their platform. We will
primarily be utilizing the Unified Management Account (“UMA”) program. For those clients selecting the
UMA program, you are offered access to an actively managed investment portfolio chosen from a roster of
independent asset managers from a variety of disciplines. Unlike a mutual fund, where the funds are
commingled, a separately managed account is a portfolio of individually owned securities that can be
tailored to fit your investing preferences.
Envestnet will assist Correct Capital in identifying individual asset managers and investment vehicles that
correspond to the proposed asset classes and styles Envestnet may independently identify asset managers
Envestnet retain the independent asset managers for portfolio management services in connection with
the UMA program through separate agreements entered into between Envestnet and these independent
managers on terms and conditions that Envestnet deems appropriate. Envestnet will additionally provide
account billing and reporting for all CCWM clients.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern.
Additionally, we provide advice on non-securities matters about the rendering of estate planning, insurance,
real estate, and/or advice. In these consultation engagements, 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.
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WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions,
we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
ASSETS
As of December 31, 2023, we have $806,536,678in regulatory assets under management. We manage
$424,828,626 under discretionary management and $381,708,052 under non-discretionary management.