General Information
Disciplina Capital Management LLC, which also does business under the name Disciplina Group, LLC,
(“DCM” or “we”) was formed in 2013 and provides advisory services to small and mid-sized
institutions. We also provide personalized wealth management services to high-net worth investors.
Disciplina Group, LLC is the sole principal owner of DCM. Matthew W. Wright is the principal owner
of Disciplina Group, LLC; Brant Smith, Alena Thangaraj and Brian Arsenault are also owners. Please
see Brochure Supplements, Exhibit A, for more information on Mr. Wright and other individuals
who formulate investment advice and have direct contact with you or have discretionary authority
over your account(s).
As of December 31, 2023, we managed $1,926,808,941 of client assets on a discretionary basis and
$353,152,372 on a non-discretionary basis.
INSTITUTIONAL ADVISORY SERVICES
DCM helps resource-constrained institutional investors, including university endowments and
charitable foundations, achieve their missions through an expansive global investment network and
tailored solutions developed from our cohesive investment team’s extensive firsthand experience at
multi-billion-dollar institutions. We work closely with small and mid-sized institutions — such as
university endowments and charitable foundations — with the goal of maximizing performance of
their investment policies and portfolios. We provide customized investment solutions including
Outsourced Chief Investment Officer (OCIO) services, with investment capabilities and scale
comparable to multi-billion-dollar organizations through access to a global network of investment
managers, asset classes and opportunities. And we take a proactive, ongoing approach to sourcing and
monitoring.
Outsourced Chief Investment Officer (“OCIO”) Solution
Our asset and manager allocation experience span three decades and multiple market cycles across
developed, emerging and frontier markets. Our professional management team has existing networks
and infrastructure that provides singular oversight, utilizing best practices with dual management of
return and risk. Our robust analytical and risk management capabilities provide daily insight into your
portfolio.
Our bundled investment advisory solutions include:
• Asset allocation review ensuring consistency with institution’s goals
• Continual monitoring of investment guidelines and process
• Manager selection, implementation, monitoring, and comparative analysis
• Operational due diligence
• Daily portfolio risk monitoring and management
• Performance measurement and analysis
Our OCIO services also include discretionary management of your investment portfolio. As a
discretionary investment adviser, we will have the authority to supervise and direct the portfolio
without prior consultation with you. Notwithstanding the foregoing, you may impose certain written
restrictions on us in the management of your investment portfolio, such as prohibiting the inclusion
of certain types of investments in an investment portfolio or prohibiting the sale of certain
investments held in the account at the commencement of the relationship.
We may also agree to non-discretionary arrangements in limited circumstances. Under a non-
discretionary arrangement, clients must be contacted prior to the execution of any trade in the
account(s) under management. This may result in a delay in executing recommended trades, which
could adversely affect the performance of the portfolio. This delay also normally means the affected
account(s) will not be able to participate in block trades, a practice designed to enhance the execution
quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement,
the client retains the responsibility for the final decision on all actions taken with respect to the
portfolio.
Separate Account Managers
When appropriate, we may select one or more Separate Account Managers, each a “Manager,” to
manage a portion of your assets. Having access to various Managers offers a wide variety of manager
styles and offers you the opportunity to utilize more than one Manager, if necessary, to meet your
needs and investment objectives. We will select the Manager(s) that we deem most appropriate for
the client. Factors that we consider in selecting Managers generally includes your stated investment
objective(s), management style, performance, risk level, reputation, financial strength, reporting,
pricing, and research.
Manager(s) will generally be granted discretionary trading authority to provide investment
supervisory services for the portfolio. Under certain circumstances, we retain the authority to
terminate the Manager’s relationship or to add new Managers without your specific consent. In other
cases, you will ultimately select one or more Managers
recommended by us.
In any case, with respect to assets managed by a Manager, our role will be to monitor your overall
financial situation, to monitor the investment approach and performance of the Manager(s), and to
assist you in understanding the investments of the portfolio. Fees paid to such Manager(s) are
separate from and in addition to our fee.
Private Funds
We may from time to time, based on your risk tolerance, sophistication and financial qualifications,
invest a portion of your assets in certain private investments. These may include private equity, private
debt and real estate funds, hedge funds, and other types of private investment vehicles (collectively
“Private Funds”). We will continue to render advisory services to you, relative to the ongoing monitoring
and review of asset performance and due diligence of the Private Fund.
WEALTH MANAGEMENT SERVICES
Wealth Management
As a professional asset manager, we design and manage customized investment portfolios tailored to
the unique risk characteristics and investment objectives of each client. Based on your personal
circumstances, we create an investment portfolio structured to build wealth and maintain your
acceptable risk level.
To implement the portfolio, we will manage your investments on a discretionary basis. As a
discretionary investment adviser, we will have the authority to supervise and direct the portfolio
without prior consultation with you.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the management
of your investment portfolio, such as prohibiting the inclusion of certain types of investments in your
investment portfolio or prohibiting the sale of certain investments held in the account at the
commencement of our relationship. You should note, however, that if you impose restrictions it may
adversely affect the composition and performance of your investment portfolio. You should also note
that your investment portfolio is treated individually by considering each purchase or sale for your
account. For these and other reasons, performance of client investment portfolios within the same
investment objectives, goals and/or risk tolerance may differ, and you should not expect that the
composition or performance of your investment portfolio would necessarily be consistent with similar
clients of ours.
Separate Account Managers
We can manage your entire portfolio directly, or we can select from among a variety of third-party
account managers, sub-advisers or model providers (collectively, the “Managers”) to manage certain
of your assets. We perform due diligence on such Managers prior to selecting them to (i) manage
portions of your portfolio on a discretionary basis; or (ii) provide one or model portfolios which are
employed by us to manage your account at our discretion. We will select the Manager(s) that we
deem most appropriate for you based on, among other things, your stated investment objective(s)
and the Manager’s management style, performance, risk level, reputation, financial strength,
reporting, pricing, and research.
In any case, with respect to assets managed by a Manager, our role will be to monitor your overall
financial situation, to monitor the investment approach and performance of the Manager(s), and to
assist you in understanding the investments of the portfolio. Fees paid to such Manager(s) are
separate from and in addition to our fee.
Private Funds
We may from time to time, based on your risk tolerance, sophistication and financial qualifications,
invest a portion of your assets in certain private investments. These may include private equity, private
debt and real estate funds, hedge funds, and other types of private investment vehicles. We will continue
to render advisory services to you, relative to the ongoing monitoring and review of asset performance
and due diligence of the Private Fund.
Retirement Plan Rollovers
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. If we recommend that you transfer your IRA account
or roll over your retirement plan assets into an account to be managed by us, such a recommendation
creates a conflict of interest if we will earn a new (or increase our current) advisory fee because of the
rollover. Investing in an IRA with us will typically be more expensive than an employer-sponsored
retirement plan. You are under no obligation to roll over plan assets to an IRA managed by us or to
engage us to monitor and/or manage the account while maintained at your employer.