A. Kingsbury Capital Investment Advisors
Kingsbury Capital Investment Advisors, LLC ("KCIA,” and/or the “firm"), is an Illinois limited
liability company and is registered with the SEC as an investment adviser. The firm is principally
owned by William Vellon and Asher Wolmark and has been providing investment advisory and
asset management services since 2008.
B. Advisory Services Offered
KCIA is an independent investment advisory and asset management firm offering a variety of
financial services to individuals and high-net-worth individuals, trusts, retirement plans, pension
and profit sharing plans, corporations, partnerships, and other legal entities. Advisory services
may include investment strategy and portfolio management.
KCIA receives a limited power of attorney to effect securities transactions on behalf of its clients
that include securities and strategies itemized in Item 8 of this Brochure. In addition KCIA,
pursuant to the terms of its investment advisory agreement with clients, has discretionary
authority to determine which securities are to be bought and sold, the price of such securities,
the executing broker and the commission rates to be paid to effect such transactions, as more
fully described in Item 16 of this Brochure. We may also retain third-party money managers to
manage a portion of the client's investment portfolio.
Clients will be asked to complete a questionnaire establishing their financial situation, goals,
needs, and tolerance for risk, and to factor in any additional personal or financial circumstances
that they mandate. KCIA will then review the responses to the questionnaire and obtain any
additional information, if necessary, and recommend a suitable portfolio of investments. Should
the client agree, KCIA will implement the recommended portfolio.
In lieu of the unique nature of trusts, corporate or institutional plans, funds or otherwise for
which KCIA provides services, the client and firm will establish goals under the direction of one
or more trustees or the authorized executive of the plan or trust, which will be part of the
Investment Policy Statement. Such information will include goals, needs, and tolerance for risk,
and to factor in any additional restriction, requirement of the trust(s) and beneficiaries as they
respect to the plan, trust or fund, or financial circumstances that they mandate.
Clients have the right to provide the firm with any reasonable investment restrictions that should
be imposed on the management of their portfolio (to be noted on the client agreement), and
should promptly notify the firm in writing of any changes in such restrictions or in the client's
personal financial circumstances, investment objectives, goals and tolerance for risk. KCIA will
remind clients of their obligation to inform the firm of any such changes or any restrictions that
should be imposed on the management of the client’s account. KCIA will also contact clients at
least annually to determine whether there have been any changes in a client's personal financial
circumstances, investment objectives and tolerance for risk.
Institutional Retirement Investment Advisory Services
Employees in qualified retirement plans are protected by the Employee Retirement Income
Security Act of 1974 (ERISA), which requires employers, investment advisors, and plan
administrators to put employees’ interests first when managing retirement savings plans. Public
retirement systems are governed by similar state laws and often incorporate the protections of
ERISA.
In order to demonstrate that a plan fiduciary has operated in a prudent manner, there are
certain steps that the fiduciary must take. KCIA is committed to helping fiduciaries understand
their roles and to assist them in implementing a process that allows them to fulfill their duties
and responsibilities.
KCIA offers government retirement systems, sponsors of employee benefit plans (defined
contribution and defined benefit) qualified under the Internal Revenue Code (“IRC”), and other
retirement plans not qualified under the IRC (including Taft-Hartley organizations and “church”
plans) a range of discretionary and non-discretionary services, including the selection of
registered investment companies or other pooled investment funds to be offered under the
plan.
KCIA will assist plan fiduciaries in the following areas:
▪ Investment Selection and Monitoring
• Creating an investment policy statement
• Modeling asset allocations
• Selecting investment managers
• Monitoring the investment options against well-defined risk and return criteria
• Monitoring costs, fees and other criteria that relate to Plan Sponsor oversight
responsibilities
▪ Plan Evaluation/Benchmarking
KCIA also “benchmarks” retirement plans against those of organizations in the same
industry and against national normative data. Factors that KCIA evaluates include the
following:
• Participation, deferral percentage, and asset allocation
• Investment performance
• Plan design
• Total plan costs
• Compliance
• Participant education and communication
• Recordkeeping and administration
• Technology
• Service provider capabilities and profiles
KCIA investment professionals work in partnership with clients to create sound solutions
to investment challenges, including:
• Maximizing long-term return while not assuming unnecessary risk
• Creating an optimal portfolio that includes a diverse array of investment options
that span the risk/return spectrum
• Keeping plan sponsors current on manager performance and the events that may
affect performance
▪ Vendor Search and Selection and Plan Implementation
KCIA also assists its retirement plan clients in selecting trustees, custodians, accountants,
actuaries, and other service providers. This process involves:
• Generating criteria to identify appropriate service provides
• Developing requests for proposals
• Objectively rating service providers
• Evaluating highly rated service provider candidates
Once a service provider is selected, KCIA will assist a client in implementing the client’s
retirement plan program. In implementing the program, KCIA will, among other things,
review the plan design, develop performance standards, and review the service
provider’s contract.
▪ Ongoing Plan Operations Support
KCIA also provides assistance with strategic employee education and communications in
connection with client retirement plan programs, as well as ongoing plan sponsor
administrative support with respect to the Plan. We will assist in designing appropriate
participant education strategies, provide on-site education and enrollment meetings,
and provide supporting education and counseling specific to participant benefits under
the plan. As retirement program administration is central to the successful operation of
the plan, we will provide support to Plan Fiduciaries in fulfilling their obligations through
guidance with respect to compliance with rules and regulations as they apply to each
specific situation.
KCIA will not provide legal advice as we are not licensed attorneys; however, we can
provide guidance based on our expertise as well as client resources specific to benefit
plan operations and general employee benefit issues.
KCIA, in conjunction with Service Provider recommendations, will provide ongoing
management and support of vendor transitions, such as a change in recordkeeper,
investment managers, or other providers.
Limitations with Regard to KCIA Services and Plan Establishment, Termination or Other
Employer Needs
In no event will the services of KCIA specific to a Plan for which we receive payment out of plan
assets be related solely to the Plan Sponsor. Our obligation as fiduciaries prohibits receiving any
compensation from plan assets unless solely related to plan operations as defined under ERISA.
In some cases clients may enter separate agreements with other professionals (who may also be
KCIA Investment Advisor Representatives) with specific expertise in benefit plan management.
Limitations with Regard to Participant Education and Investment Advice
KCIA does not provide individual advice to plan participants as part of the services to the Plan.
Individual participants
may or may not engage KCIA for personalized financial advice for their
personal investment needs. KCIA and/or plan vendors may make available individual, personal
investment advice services, including automated advice modules, asset allocation services or
other means to deliver individual advice through other parties, and fees to the participant or the
plan may apply. In no event will Kingsbury have any relationship or arrangement which results in
KCIA having an economic interest or benefit from such arrangements. KCIA will provide ongoing
support in the evaluation of the individual advice vendor, as appropriate.
Limitation of Services with Respect to Participant Directed Employer Plans, Annuities, or Other
Arrangements
In some cases KCIA will act as an advisor to a Plan, Trust or Employer with respect to
investments held on behalf of participants of a plan established by the Employer. KCIA in its role
may or may not make available other services that provide advice to participants, unless
directed by the Plan that is deemed “investment advice” under ERISA. KCIA, in its unique role
with respect to plan assets, or assets held in a trust, annuity or other arrangement, may be in
position to advise or make recommendations of a personal nature. KCIA will take into account
the specific information unique to the participant in executing its obligations as required by the
terms of agreement, or as requested by a participant if applicable. Participants, in their sole
discretion, may enter into separate agreements for other services with our firm with respect to
other personal assets. Any advice provided to a natural person who is a beneficiary of the plan
or trust that is incidental to the providing of services to the plan or trust will be based on the
objectives, restrictions or otherwise established with the client on behalf of participants or
beneficiaries as necessary, and take into account personal information provided by the
participant.
Any arrangement to provide “advice” as defined under ERISA on behalf of plan participants that
is established by the employer or plan sponsor is intended to meet applicable regulations. KCIA
and Client agree to modify such arrangement, and make available information with regard to
administration, certification or any required changes, restrictions, or circumstances effecting
such arrangement as needed. Such advice, if provided to participants, will be at the discretion of
the participant, and will be limited to the specific information disclosed by the participant and
any information provided in the context of participation in a plan or status as an employee or
independent contractor of an employer. In many cases, such systems, tools, programs that are
used to provide these services will be under a separate arrangement with one or more service
providers to a plan or trust.
KCIA and Client may also enter into agreements limited nature with respect to Participant
Advice, or other services of a personal nature specific to a beneficiary of a plan or trust. Such
agreements may be provided through or on behalf of a plan, a plan service provider, trust
company, bank or insurance company qualified to perform services required by the Client, or
any combination of the above.
KCIA services are limited in nature with respect to Employer Plans, in that KCIA, as investment
advisor, does not act as, or substitute for, the Plan Sponsor, with respect to other service
providers to the Plan or Trust. KCIA may make recommendations that include other services in
addition to investments or investment related services on behalf of plans. Client agrees to notify
KCIA of any change to, or restrictions of, its objectives and obligations under the Plan as
needed. KCIA, in its role, may also provide advice and guidance with regard to such services.
KCIA, in its role, does not have any interest in such service providers, and does not benefit from
any recommendation unless specifically authorized by a plan.
Financial Planning Services
Clients will receive a written or oral report (depending on the client’s preference) providing a
basic financial plan designed to help achieve their stated financial goals and objectives. Based
on the client’s needs, financial planning services may include (but are not limited to) the
following:
▪ Preparation of a recommended asset allocation that serves to diversify the client's
portfolio among different categories of investments, such as domestic and international
small, medium, and large capitalization securities; corporate and government fixed
income (short-, intermediate-, and long-term maturities); emerging market securities (i.e.,
foreign issuers); real estate investment trusts; and such other alternative asset categories
that are suitable in light of the client's investment goals, objectives, and risk tolerance.
▪ Preparation of an investment policy statement setting forth the client’s investment plan,
with specific direction in terms of diversification requirements, tax issues, estate planning
issues, risk tolerance, retirement, and other identified objectives of the client, including a
targeted rate-of-return objective.
▪ Preparation of a retirement plan that serves to identify whether the client is saving
enough and investing in a way that meets retirement objectives in light of the client's
financial circumstances and risk tolerance.
▪ Preparation of cash flow projections to ensure that the client can meet daily living
expenses and obligations.
▪ Insurance planning to meet the needs of the client, taking into account family, business,
and other financial objectives of the client.
▪ General family office and business consulting:
• Retirement objectives
• Philanthropy
• Estate planning
• Wealth transition
• Business succession and related issues
• Recommendation of third-party managers for use by the client
KCIA gathers required information through in-depth personal interviews and questionnaires.
Information gathered includes a client's current financial status, investment objectives, future
goals, and attitudes toward risk. Related documents supplied by the client are carefully
reviewed, and a report is prepared covering one or more of the above-mentioned topics as
directed by the client.
Account Aggregation Services
KCIA, subject to client authorization, provides account aggregation services to its clients. KCIA
through a third-party service provider will provide a secure website that aggregates various
investment accounts from various financial institutions so clients can view their investment
holdings in one place. Certain financial institutions may not support this service. If any of your
accounts are not able to link with our service, KCIA will submit a request to have them added,
but cannot guarantee that all links will be successful.
Account Aggregation Services for Trusts, Retirement Plans, Insurance through Outside Firms
KCIA, subject to client authorization, may utilize, provide or have access to outside account
aggregation services on behalf of clients. KCIA through a third-party service provider will
provide a secure website that aggregates various investment accounts from various financial
institutions so clients, which may include corporate retirement plans, trusts, or other funds, can
manage their obligations under any such plan, trust or fund. For plans, such services may include
participant access and related services. Certain financial institutions may not support this
service, and the Client is required to provide sufficient information, restrictions, or directives to
KCIA, so that the firm may recommend a suitable portfolio of investments.
C. Client-Tailored Services and Client-Imposed Restrictions
Clients’ accounts will be managed on the basis of their financial situation and investment
objectives and in accordance with any reasonable restrictions imposed by the client on the
management of the account—for example, restricting the type or amount of security to be
purchased in the portfolio.
D. Wrap Fee Programs
KCIA does not participate in wrap fee programs. (Wrap fee programs offer services for one all-
inclusive fee.)
E. Client Assets Under Management
As of December 31, 2023, KCIA had $121,252,310 in discretionary and $14,893,556 in non-
discretionary client assets under supervision.