Kavar Capital Partners Group, LLC is a SEC-registered investment adviser with its principal place of
business located in Leawood, Kansas. Kavar Capital Partners Group, LLC ("KCP" or "Adviser" or “the
firm”) acquired the investment advisory business of Kavar Capital Partners, LLC which began
conducting business in January 2011.
KCP is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, KCP is a
wholly-owned indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole
managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the
board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly
and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”).
Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of
Focus LLC. Because KCP is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone
Point investment vehicles are indirect owners of KCP.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance
firms, business managers and other firms (the “Focus Partners”), most of which provide wealth
management, benefit consulting and investment consulting services to individuals, families, employers,
and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or
investment companies as disclosed on their respective Form ADVs.
KCP is managed by Douglas Ciocca, Thomas Boling, Stefanie Callahan and John Nagle (“KCP
Principals”), pursuant to a management agreement between DTS Partners, LLC and KCP. The KCP
Principals serve as officers and leaders of KCP and are responsible for the management, supervision
and oversight of KCP.
KCP offers the following advisory services to clients:
WEALTH MANAGEMENT AND INVESTMENT SERVICES
We offer Wealth Management Services that include comprehensive financial planning and investment
management services. For clients who request our financial planning services, we typically begin the
financial planning process by offering to provide a comprehensive evaluation of a client's current
financial state and potential financial future by analyzing their cash flows, asset values and withdrawal
plans. When conducting an assessment, we consider a wide range of relevant information such as the
client’s tax returns, investment holdings, insurance policies, estate documents and other relevant
information. Clients will complete a questionnaire regarding current financial status, tax status, future
goals, return objectives and attitudes towards risk. KCP will then design a financial plan designed to
help clients meet their goals and objectives. We will periodically review and work with clients to refine
the plan as circumstances dictate. However, it remains the client's responsibility to promptly notify KCP
if there are ever any changes in the client's financial situation or objectives.
When providing financial planning services, we are not serving as attorneys, accountants or insurance
agents. We recommend that clients seek legal, accounting and insurance advice from appropriately
qualified professional services firms. In the event that we refer a client to any such professionals,
clients will decide whether to engage the professionals and retain all decision-making authority
concerning the implementation of their advice. Financial planning is a service included with KCP’s
Wealth Management Services program and is not offered as a stand-alone service.
Our financial planning services are part of a wealth management program where we implement the
plan by providing investment management services. KCP manages advisory accounts on both a
discretionary and a non-discretionary basis as determined by the client. Account supervision is guided
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by the client's stated risk tolerance (for example: Aggressive Growth, Capital Preservation, Growth &
Income, Growth, or Income) as well as any income needs and tax considerations, as noted by the
client in the questionnaire, a risk profile on the Investment Management Agreement and/or information
obtained during the financial planning stage of the engagement.
Clients who engage us to manage their accounts on a discretionary basis must give us discretionary
authority to manage their account(s). Discretionary authorization will allow KCP to determine the
specific securities and the amount of securities to be purchased or sold for the client’s account without
approval prior to each transaction. Discretionary authority is typically granted on the Investment
Management Agreement the client signs with KCP and the appropriate trading authorization forms
with the custodian.
Clients may impose reasonable written restrictions on investing in certain securities, types of
securities, or industry sectors.
KCP may also offer non-discretionary portfolio management services. If a client enters into a non-
discretionary arrangement with KCP, KCP must obtain the clients approval prior to executing any
transactions. The client has an unrestricted right to decline any advice provided by KCP on a non-
discretionary basis.
KCP’s investment recommendations are not limited to any specific product or service offered by a
broker- dealer or insurance company and will generally include advice regarding equity securities
(including options), fixed income securities, mutual funds, government securities, money-market (or
cash) instruments and alternative assets in the form of liquid alternatives or structured products.
We implement investment advice on behalf of certain clients in held-away accounts that are
maintained at independent third-party custodians. These held-away accounts are often 401(k)
accounts, 529 plans and other assets that are not held at our primary custodian(s).
We offer investment advisory services on the allocation of subaccounts for variable annuities. The
investment services we can provide are limited to allowable products and can be billed
separately. The client on these accounts will provide our firm with trading authorization; and, on a
discretionary basis we will reallocate the subaccounts within the client’s plan or annuity pursuant
to investment objectives chosen by the client.
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial
institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates,
“UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important
information
RETIREMENT PLAN ADVISORY SERVICES
KCP offers Retirement Plan Advisory Services to employee benefit plans and their fiduciaries based
upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In
general, these services may include an existing plan review and analysis, plan-level advice regarding
fund selection and investment options, education services to plan participants, investment
performance monitoring, and/or ongoing consultation. The Retirement Plan Advisory Services will
generally be non- discretionary and advisory in nature. The ultimate decision to act on behalf of the
plan shall remain with the plan sponsor or other named fiduciary.
KCP may also assist with participant enrollment meetings and provide investment-related
educational seminars to plan participants on such topics as:
• Diversification
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• Asset allocation
• Risk tolerance
• Time horizon
Educational seminars may include other investment-related topics specific to the particular
plan. The scope of education provided to participants is agreed upon but will not constitute "investment
advice" within the meaning of ERISA. Participant education will relate to general principles for investing
and information about the investment options currently in the plan.
KCP may also provide additional types of retirement plan advisory services to plans on an individually
negotiated basis.
Either party to the retirement consulting agreement may terminate the agreement upon oral or written
notice to the other party in accordance with the terms of the agreement for services. The retirement
plan advisory fees will be prorated for the quarter in which the termination notice is given and any
unearned fees will be refunded to the client.
KCP also offers ERISA 3(21) Retirement Plan Consulting. With such services, KCP shall not have any
discretion, trading or otherwise, with respect to any decisions made by or on behalf of the
client as the
client will retain absolute discretion over all investment and implementation decisions. KCP will not
have custody, take physical possession or control of the assets/funds of the Plan. Services provided
will be on a client-by-client basis and outlined in the Investment Management Agreement.
KCP receives no payment for recommending other money managers or sub-advisers. From time to
time, KCP may be asked by the plan administrators to meet with plan participants and provide general
investment education, which may include basic information regarding plan approved products and
mutual funds. KCP never takes custody of plan participant's assets nor executes transactions for plan
participant's accounts.
In any case for the above services (other than for educational seminars for plan participants),
recommendations are based on the individual needs of the client. Through discussions with the
client, whereby goals and objectives are established based on the client's circumstances, KCP will
develop a tailored investment strategy. The investment strategy is mutually agreed upon with the
client prior to entering into a service agreement.
KCP is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”)
with respect to investment management services and investment advice provided to ERISA plan clients,
including plan participants. KCP is also a fiduciary under section 4975 of the Internal Revenue Code (the
“IRC”) with respect to investment management services and investment advice provided to individual
retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, KCP is subject to
specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things,
prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest.
When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or
eliminate the conflict or rely upon a prohibited transaction exemption (a “PTE”).
As a fiduciary, we have duties of care and of loyalty to clients and are subject to obligations imposed on
us by the federal and state securities laws. As a result, clients have certain rights that you cannot waive
or limit by contract. Nothing in our agreement with clients should be interpreted as a limitation of our
obligations under the federal and state securities laws or as a waiver of any non-waivable rights you
possess.
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IRA Rollover Considerations
As part of KCP’s investment advisory services, the firm may recommend that clients withdraw their
assets from an employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that KCP will manage on behalf of the client. If the client elects to roll the assets to an IRA that
is subject to KCP’s management, the firm will charge the client an asset-based fee as set forth in the
agreement executed with the firm. This practice presents a conflict of interest because persons
providing investment advice on KCP’s behalf have an incentive to recommend a rollover to clients for
the purpose of generating fee-based compensation rather than solely based on client needs. Clients
are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if a client does
complete a rollover, they are under no obligation to have the assets in an IRA managed by KCP.
Many employers permit former employees to keep their retirement assets in the company plan. Also,
current employees can sometimes move assets out of the company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, clients should consider the costs and benefits of:
1. Leaving the funds in the employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change, KCP
encourages clients to speak with a CPA and/or tax professional.
If a client is considering rolling over retirement funds to an IRA for KCP to manage, below are a
few points to consider before doing so:
1. Investment options: Employer retirement plans may have unique investment options not available
to the public such as employer securities, or previously closed funds. Employer retirement plans
generally have a more limited investment menu than IRAs. An IRA may be able to offer more
diversified products than a current sponsored plan.
2. Fees and expenses: Plans and IRAs usually generate investment-related expenses and plan or
account fees. Plan fees include administrative fees, which may be paid by the employer. IRA
account fees may include management fees and fees charged by the custodian.
3. Services: KCP will consider what services are offered under the plan, such as investment
advice. KCP will compare the services that may not be offered, such as asset allocation and
planning.
4. Withdrawals: IRA assets can be accessed at any time; however; distributions are subject to
ordinary income tax and may also be subject to a 10% early distribution penalty unless the
account holder qualifies for an exception such as a disability, higher education expenses or the
purchase of a home. In many employer retirement plans, separation from service after age 55
is an exemption from the 10% early distribution penalty (for distributions taken prior to age 59
½) that is available for qualified plan distributions but not IRA distributions.
5. Penalty-free withdrawal: KCP will evaluate withdrawal-related differences between IRAs and
401(k)s. For example, a 401(k) may offer a plan loan, a feature not offered by IRAs.
6. Protection from creditors and legal judgments: Generally, plan assets are fully protected
under federal law. IRAs are usually protected in a bankruptcy filing. State laws vary as to
whether IRAs are protected against lawsuits. There can be some exceptions to the general
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rules so clients should consult with an attorney if protecting retirement plan assets is a
concern.
7. Required minimum distributions (RMD): A plan may permit the participant to take RMDs later if
the individual is still working.
8. Employer stock: KCP should analyze whether there will be negative tax implications from rolling
stock over to an IRA, if applicable. Generally, stock appreciation when withdrawn from an IRA is
taxable as ordinary income. Certain kinds of employer stock plans let investors liquidate shares
and profits are taxed at the lower capital gains rates. KCP, however, must analyze whether the
tax benefits are outweighed by the risk that arises when a client is overly concentrated in the
employer’s stock.
It is important that each client understands the differences between these types of accounts and to
decide whether a rollover is the best option. Prior to proceeding, if a client should have any
questions, contact KCP at the main number listed on the cover page of this brochure.
Types of Investments
KCP offers advice on equity securities, corporate debt securities (other than commercial paper),
commercial paper, certificates of deposit, municipal securities, mutual funds, United States
government securities, options contracts on securities, money market funds, structured notes and
exchange-traded funds ("ETFs").
KCP recommends certain private investment funds to certain financially qualified clients. The
private funds are suitable only for sophisticated investors who do not require immediate liquidity
for their investments, for whom an investment in a private fund does not constitute a complete
investment program, and who fully understand and are willing to assume the risks involved in the
private fund’s investment program. Even where the investments of a private fund are successful,
some do not produce a realized return for a period of years. The private funds’ offering documents
contain additional information that must be reviewed by any potential investor.
Additionally, KCP may advise clients on various types of investments based on the stated goals and
objectives. KCP may also provide advice on any type of investment held in the client’s portfolio at the
inception of the advisory relationship.
AMOUNT OF MANAGED ASSETS
As of 12/31/2023, KCP was actively managing $1,140,820,829 of clients' assets on a discretionary
basis plus $1,115,863 of clients' assets on a non-discretionary basis.