Introduction
Level Four Capital Management, (referred to as “LFCM”, the “Firm”, “us” and “we” in this Disclosure Brochure), is an
investment adviser registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability
Company formed under the laws of the State of Texas.
The Firm was formed in June 2019 primarily provides asset management services. The Firm will be managing assets
previously managed by Level Four Asset Management (“LFAM”), a division of Level Four Advisory Services, LLC (“LFAS”), an
affiliate company sharing common ownership with LFCM as detailed below.
The Firm is owned and controlled by Level Four Group. Level Four Group is a holding company and the 100% owner of
LFCM. Level Four Group is owned and operated by Carr, Riggs & Ingram Capital, LLC, a Delaware limited liability
company. Carr, Riggs & Ingram Capital, LLC is 100% owned by Carr, Riggs & Ingram, L.L.C., an Alabama limited liability
company. No individuals own more than 25% of Carr, Riggs & Ingram, LLC. Level Four Advisory Services, LLC is an affiliate
company and SEC registered investment adviser also owned and controlled by Level Four Group.
Client Assets Managed by LFCM
The amount of client assets managed by LFCM totaled approximately $1,011,305,374 as of December 31,2023.
$1,011,305,374 is managed on a discretionary basis and $0 is managed on a non-discretionary basis.
General Description Advisory Services
LFCM primarily provides advisory services in the form of asset management services directly or through either a Third-
Party arrangement or a Sub-Advisory arrangement with either affiliated or unaffiliated SEC and state-registered
investment advisory firms to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations and other business entities.
More specifically, LFCM has developed separately managed accounts and various asset allocation models intended to
achieve a particular investment goal or to meet particular risk and return characteristics. These models are not tailored to
accommodate the needs or objectives of a specific individual, but rather are designed to enable an advisor to match its
clients to an investment solution that is overall consistent with that client’s investment goals and objectives.
LFCM provides portfolio management for managed asset programs that are offered on a wrap fee or non-wrap fee basis
through a managed account program using accounts established with Raymond James and Associates (“Raymond
James”), Fidelity Institutional Wealth Services (“Fidelity”), Charles Schwab & Co., Inc. (“Schwab”) and other qualified
custodians as approved by LFCM. The accounts established through these custodians are held in separate account(s) in
the name of the end client. The applicable custodian maintains physical custody of all funds and securities in that account,
with the end client retaining all rights of ownership, including without limitation, the right to withdraw securities funds and
the right to exercise or delegate proxy voting.
Sub-Advisory relationship. In connection with such services, LFCM does not have a direct investment advisory
relationship with either the advisor or the advisor’s end clients, nor does LFCM conduct an independent investigation of
the advisor’s end client or the client’s financial condition. Instead, the ‘referring advisor” who may either be a registered
advisory representative with Level Four Advisory Services, LLC, (“LFAS”) or another referring advisor serves as the advisor
to its client and is responsible for analyzing the client’s current financial situation, risk tolerance, time horizon, and asset
class preference. LFCM serves as a sub-advisor according to the terms of a written Sub-Adviser Agreement. The referring
adviser is responsible for the recommendation and selection of LFCM on behalf of the client.
These asset management services are provided on a discretionary basis and LFCM accordingly makes all decisions to buy,
sell or hold securities, cash or other investments in the managed account without consulting you as the end client and you
must provide written authorization for this exercise of discretionary authority at the time your account is established. This
discretionary authority is limited to trading authorization only and LFCM will not have access to your funds and/or
securities with the exception of having advisory fees debited directly from your account and paid to LFCM by the account
custodian.
When client accounts are managed using models, investment selections are based on the underlying model and the firm
does not typically develop customized (or individualized) portfolio holdings for each client. However, the firm may on an
exception basis, develop portfolio holdings on an individualized basis based upon client-imposed social restrictions or as
otherwise agreed to on a case-by-case basis. The determination to use a particular model or models is always based on
each client’s individual investment goals, objectives and mandates and is assessed in consultation with the referring
adviser.
Once the advisor allocates one or more investment styles or models to a client’s account, assets allocated to the strategy
or model by the advisor will be invested by LFCM in accordance with the applicable investment style or model, as updated
by LFCM’s investment committee from time to time.
Client assets that are allocated to an investment style or model are subject to the risk that performance may deviate from
the performance of a style or model.
LFCM also provides services as a sub-adviser to a large cap growth exchange-traded fund (“ETF” or “Fund”) registered
under the Investment Company Act of 1940 and distributed by ALPS Distributors, LLC (“ALPS”). LFCM does not tailor its
advisory services to the individual needs of the investors in the Fund. Rather, as sub-adviser to the Fund, LFCM
coordinates the investment and reinvestment of the assets of the Fund and determines the composition of the assets of
such Fund, in accordance with the terms of it sub-advisory agreement with the advisor of the Fund, as well as the Fund’s
Prospectus and Statement of Material Information, which set forth the Fund’s investment strategy, guidelines and
restrictions. Prospective investors in the Fund should review these documents carefully before making any investment in
the Fund.
Types of Investments
In addition to its role as sub-adviser to the Fund as described herein, LFCM offers actively managed portfolios consisting
of equities, fixed income (including without limitation government securities, investment grade and high yield corporate
bonds, floating rate senior loans, emerging market debt, mortgage -backed securities, and ultra-short duration securities),
alternatives (including private equity and private credit), mutual funds and exchange traded funds (“ETF’s).