A. Description of the Advisory Firm
Connecticut Capital Management Group, LLC (hereinafter “CCMGL”) is a Limited
Liability Company organized in the State of Connecticut. The firm was formed in
May 1998, and the principal owner and Chief Compliance Officer is Brian Parke.
B. Types of Advisory Services
Portfolio Management Services (Direct)
CCMGL offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. CCMGL creates an
Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan to
aid in the selection of a portfolio that matches each client's specific situation. Portfolio
management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
CCMGL evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the
Investment Policy Statement, which is given to each client.
CCMGL seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of CCMGL’s
economic, investment or other financial interests. To meet its fiduciary obligations,
CCMGL attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly,
CCMGL’s policy is to seek fair and equitable allocation of investment
opportunities/transactions among its clients to avoid favoring one client over another
over time. It is CCMGL’s policy to allocate investment opportunities and transactions
it identifies as being appropriate and prudent, including initial public offerings
("IPOs") and other investment opportunities that might have a limited supply, among
its clients on a fair and equitable basis over time.
Portfolio Management Services (via Selection of Other Advisers)
CCMGL may offer investment advisory services through use of third-party money
managers (“Outside Managers” and “Sub-Advisers”) for portfolio management
services. In doing so, CCMGL assists clients in selecting an appropriate allocation
model, completing the investor profile questionnaire, interacting with the Outside
Manager and reviewing the Outside Manager. CCMGL will meet with the client on a
periodic basis to discuss changes in their personal or financial situation, suitability, and
any new or revised restrictions to be applied to the account.
Before selecting other advisers for clients, CCMGL will always ensure those other
advisers are properly licensed or registered as an investment adviser. CCMGL conducts
due diligence on any third-party investment adviser, which may involve one or more
of the following: phone calls, meetings and review of the third-party adviser's
performance and investment strategy. CCMGL then makes investments with a third-
party investment adviser by referring the client to the third-party adviser. CCMGL will
review the ongoing performance of the third-party adviser as a portion of the client's
portfolio.
Specifically, CCMGL will direct clients to a third party and its affiliates (collectively,
“Independent Manager”), which include Independent Manager’s affiliated investment
advisory firm (the “Independent Manager Affiliate”) and broker-dealer. Independent
Manager has developed a standard managed account solutions (“MAS”), which
program includes Independent Manager ’s distribution focused strategies, an integrated
managed account solutions providing a tax overlay service (“Tax Management”) and a
Goals Based Investing managed account solutions, consisting of MAS and Tax
Management portfolios invested in accordance with Independent Manager ’s goals-
based investment solutions and, may, in the future, develop additional managed
account solutions (collectively, the “Managed Account Solutions”).
Under this program, Independent Manager Affiliate acts a co-investment advisor to the
client, along with the CCMGL, pursuant to a tri-party investment management
agreement executed among Independent Manager Affiliate, CCMGL and each client
investing assets into the Managed Account Solutions (the “Tri-party Agreement”).
For each Managed Account Solutions, Independent Manager Affiliate is responsible for
developing managed account portfolios designed to be invested in accordance with a
stated investment objective (the “Managed Account Portfolios”). For each Managed
Account Portfolio, other than the Managed Account Portfolios implementing
distribution- focused strategies (the “DFS Portfolios”), Independent Manager Affiliate
is solely responsible for screening, reviewing and selecting the various money managers
and/or individual mutual funds and other assets available for selection by CCMGL
and their clients designed to meet the specific Managed Account Portfolio’s stated
investment objective or goal.
For each DFS Portfolio, Independent Manager Affiliate is responsible for selecting
the Independent Manager’s funds and/or other assets underlying each DFS Portfolio
and actively managing each client’s account invested in a DFS Portfolio in accordance
with the portfolio’s investment objectives.
Pursuant to the Managed Account Solutions, Independent Manager Affiliate will
provide to CCMGL, and its investment
adviser representatives of CCMGL the
following services:
• Make available to CCMGL and its investment adviser representatives of
CCMGL Managed Account Portfolios developed solely by Independent Manager
Affiliate and designed to achieve specific investment objectives or goals, and,
pursuant to which the clients, with recommendations from investment adviser
representatives of CCMGL, will select from a list of available money managers
(which may include Independent Manager Affiliate), Independent Manager
mutual funds, and/or other assets and, in the case of DFS Managed Account
Portfolios, investment strategies managed solely by Independent Manager
Affiliate, and which Independent Manager Affiliate has determined: (i) as to
available money managers, will invest in accordance with the Managed Account
Portfolio’s stated investment objective or goal; and (ii) as to available individual
mutual funds and other assets, are intended to help achieve the specific Managed
Account Portfolio’s stated investment objectives or goals.
• In its sole discretion, rebalance the model asset allocation mix of the Managed
Account Portfolios (including adding, removing or otherwise changing money
managers available to manage assets within a portfolio, or the mutual funds or
other assets available), as necessary to remain consistent with the model Managed
Account Portfolio’s investment objectives and otherwise be fully responsible for
determining that the Managed Account Portfolios remain invested consistent with
their stated investment objective or goal and will notify CCMGL of any money
manager change.
• Through a proprietary web-based portfolio modeling system, recommend to
CCMGL one or more Managed Account Portfolios that may meet a client’s
investment objective(s), based solely on that client’s financial and other information
provided to Independent Manager by CCMGL.
• In its role as co-advisor to clients in the Managed Account Solutions, manage
each Managed Account Portfolio, including, without limitation, (i) monitoring the
performance of each selected money manager, in accordance with the portfolio’s
stated investment objective or goal and in accordance with the terms of the Tri-
party Agreement and (ii) for client accounts invested in DFS Portfolios, be solely
responsible for selecting, managing and rebalancing the Independent Manager
funds or other assets included in the client accounts necessary for such accounts to
be and remain invested in accordance with the applicable DFS Portfolio’s
investment objective, as selected by clients with the assistance of investment
adviser representatives of CCMGL.
Pension Consulting Services
CCMGL offers consulting services to pension or other employee benefit plans
(including but not limited to 401(k) plans). Pension consulting may include, but is not
limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways
designed to achieve objectives
• monitoring performance of money managers and investment options and
making recommendations for changes
• recommending other service providers, such as custodians, administrators
and broker-dealers
• creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or
risk tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
CCMGL generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), insurance products including annuities, equities,
hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal
sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S.
securities, venture capital funds and private placements. CCMGL may use other
securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
CCMGL will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by CCMGL on behalf of the client. CCMGL may use model allocations
together with a specific set of recommendations for each client based on their personal
restrictions, needs, and targets. Clients may impose restrictions in investing in certain
securities or types of securities in accordance with their values or beliefs. However, if the
restrictions prevent CCMGL from properly servicing the client account, or if the
restrictions would require CCMGL to deviate from its standard suite of services, CCMGL
reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees.
CCMGL does not participate in wrap fee programs.
E. Assets Under Management
CCMGL has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 194,140,297 $ 9,578,063 December 2023