A. Firm Information
Capstone Triton Financial Group LLC (formerly known as Capstone Financial Group, Inc.) (“CTFG” or the
“Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
Advisor is organized as a limited liability company under the laws of the State of Oklahoma. CTFG was founded
in February 2020. CTFG is owned wholly owned by the Andrew Oster Revocable Trust, LLC, Andrew E. Oster
owns the Andrew Oster Revocable Trust and serves as the President and Chief Compliance Officer (CCO) of
CTFG. This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by CTFG.
B. Advisory Services Offered
CTFG offers investment advisory services to individuals, high net worth individuals, corporations, pensions and
profit-sharing plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. CTFG’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Wealth Management Services
CTFG may provide Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary management of
investment portfolios. These services may also be offered on a stand-alone basis and are described below.
Investment Management Services – CTFG provides customized investment advisory solutions for its Clients. This
is achieved through continuous personal Client contact and interaction while providing discretionary investment
management and related advisory services. CTFG works closely with each Client to identify their investment goals
and objectives, risk tolerance and financial situation in order to create a portfolio strategy. CTFG will then construct
an investment portfolio, primarily consisting of individual stocks, bonds, mutual funds, and exchange-trade funds
(“ETFs”) to achieve the Client’s investment goals. The Advisor may retain certain
types of investments based on a Client’s legacy portfolio construction.
CTFG will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial and/or
mutual fund company constraints, material tax consideration, and/or systematic investment plans, CTFG will
select, recommend and/or retain a mutual fund share class that does not have trading costs, but do have higher
internal expense ratios than institutional share classes. CTFG will seek to select the lowest cost share class
available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial
objectives and stated investment guidelines.
CTFG’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held less than one year to meet the objectives of the Client or due to market conditions. CTFG will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the
types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
CTFG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. CTFG may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. CTFG may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. CTFG may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
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in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of
the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will CTFG accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outline in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning and Consulting Services – CTFG will typically provide a variety of financial planning and
consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several
areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. Financial consulting may involve
preparing a consulting report, but such a report is not required. This planning or consulting may encompass one
or more areas of need, including but not limited to, investment planning, retirement planning, personal savings,
education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
CTFG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
CTFG provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs
of the Plan and Plan Sponsor. Services generally include:
● Vendor Analysis
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● Plan Participant Enrollment and Education Tracking
● Investment Policy Statement (“IPS”) Design and Monitoring
● Investment Management Services (ERISA 3(38))
● Performance Reporting
● Ongoing Investment Recommendation and Assistance
● ERISA 404(c) Assistance
These services are provided by CTFG serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of CTFG’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging CTFG to provide investment advisory services, each Client is required to enter into a written
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
● Establishing an Investment Strategy – CTFG, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
● Asset Allocation – CTFG will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – CTFG will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
● Investment Management and Supervision – CTFG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CTFG does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by CTFG.
E. Assets Under Management
As of December 31, 2023 CTFG manages $ 282,644,038 in Client assets, $ 282,575,924 of which are managed
on a discretionary basis and $ 68,114 on a non-discretionary basis. Clients may request more current information
at any time by contacting the Advisor.