CCWM is an SEC registered investment adviser with its principal place of business located in New
York, NY, USA. The Firm was originally founded in 1997 as YMSR Advisors, Inc. On May 1, 2008
YMSR Advisors, Inc. merged into Citrin Cooperman Wealth Management, LP. In October 2021,
Citrin Cooperman Wealth Management, LP redomesticated from Pennsylvania to Delaware and
converted its form of entity from a limited partnership to a limited liability company.
Principal Owners
CCWM is 100% owned by Citrin Cooperman Advisors, LLC. That entity is principally owned
indirectly by New Mountain Capital, LLC.
Regulatory Assets Under Management
As of December 31, 2023, CCWM managed $1,449,845,404 in assets on a non-discretionary basis.
Types of Services
CCWM offers investment advisory services on a discretionary and/or non-discretionary basis to each
of its clients, including both individuals and institutions (details on the types of clients CCWM serves
are in Item 7-Types of Clients). CCWM will assist a client in determining the client’s investment needs
and objectives, as well as risk tolerance, through the use of an asset optimization model for asset
allocation and research on investment managers and investments. After the client’s asset classes have
been determined, the team recommends strategies, managers and/or products that have been
evaluated and approved by CCWM’s Investment Committee (as defined below).
The recommended strategies are based upon a client’s goals, investment objectives, risk tolerance, and
cash flow needs, which are documented in an Investment Policy Statement and reviewed periodically.
CCWM will then implement the allocation into appropriate mutual funds, ETFs, separately managed
accounts, private investment funds (including, but not limited to hedge funds, private equity funds,
venture capital funds), and/or investment managers within each asset class that meet the client’s
individual requirements. CCWM does not recommend individual company stocks and bonds.
In addition to its full consulting offering, CCWM also provides financial planning services, including
providing independent guidance during the planning of upcoming liquidity events. Financial planning
includes estate planning, tax planning, education funding planning, charitable gifting planning, etc.,
however, CCWM will provide advice as appropriate and may not provide advice on all of the
aforementioned types of financial planning.
The client is under no obligation to act upon any of the recommendations made by CCWM under a
financial planning or consulting engagement or to engage the services of any such recommended
professional, including CCWM itself. The client retains absolute discretion over all such
implementation decisions in such instance and is free to accept or reject any of CCWM’s
recommendations.
Tailored Relationships
CCWM tailors its advisory services to the individual needs of clients. Customarily, the Firm will
arrange for an initial meeting, which may be by telephone or webcast to determine the extent to which
financial planning and investment management may be beneficial to the client. CCWM consults with
clients on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact
the clients’ investment needs. CCWM helps clients find suitable investments for their goals, objectives,
and risk tolerance.
Prior to CCWM providing investment management services, the client will be required to enter into a
formal Investment Management Agreement (as defined below) with CCWM setting forth the terms
and conditions under which CCWM shall manage the client’s assets, as well as a separate
custodial/clearing agreement with the broker-dealers/custodians (See Item 12 – Brokerage Practices).
Clients may impose restrictions on investing in certain securities or types of securities in the
Investment Management Agreement.
Investment Management
CCWM provides continuous and regular account supervision. As part of our investment management
service, we generally create a portfolio, consisting of separately managed accounts comprising stocks
or bonds, exchange traded funds, mutual funds and other public and private securities or investments.
We may also provide broader financial planning/financial consulting to clients.
We offer at least one, but often more than one meeting (in person, if possible, otherwise via telephone
or webcast conference) with clients in order to understand their current financial situation, existing
resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment
approach to the client that will be suitable to the client’s circumstances. Each client’s individual
investment strategy is tailored to their specific needs and may include some or all of stocks or bonds,
exchange traded funds, options, mutual funds and other public and private securities or investments.
Upon the client’s agreement to the proposed investment plan, we work with the client to establish or
transfer investment accounts so that we can manage the client’s portfolio. We review the client’s
investment plan at least annually and, if necessary, rebalance the portfolio based upon the client’s
individual needs, stated goals and objectives.
CCWM generally recommends that clients allocate investment assets among certain third-party money
managers / investment programs (collectively, the “Independent Managers”) and private investment
funds. CCWM’s trading activities are therefore extremely limited. The vast majority of account
transactions are executed by Independent Managers and private investment fund managers that
maintain day-to- day discretionary authority for the management of the allocated assets. Based upon
these and other factors, there may be extended periods when CCWM determines that upon review,
trades within a client’s portfolio are not prudent. Clients nonetheless remain subject to the fees
described in Item 5 during periods of portfolio trading inactivity.
Clients are advised to promptly notify CCWM if there are changes in their financial situation or
investment objectives or if they wish to impose any reasonable restrictions upon CCWM’s
management services. Clients may impose reasonable restrictions or mandates on the management of
their account if, in CCWM’s sole discretion, the conditions will not materially impact the performance
of a portfolio strategy or prove overly burdensome to its management efforts.
If the client experiences any significant changes to his/her financial or personal circumstances, the
client must notify us so that we can consider such information in managing the client’s investments.
CCWM offers to manage clients’ investment portfolios on a discretionary or non-discretionary basis.
a. Discretionary. CCWM has the discretionary authority to manage client accounts by
determining the amount and type of investments to be bought and sold and managers to be hired and
terminated without receiving client confirmation for each transaction. In all cases, CCWM exercises
this discretion in a manner consistent with the stated investment objectives for the particular client
account. The Investment Committee (as defined below) determines the investment strategy and
manager selection options for CCWM. Depending on the CCWM Investment Committee (the
“Investment Committee”) recommendation, CCWM will adopt an implementation plan that considers
the goals of the Investment Committee decision, fairness to all clients, and practical issues (such as
short-term redemption fees and tax liabilities). The Investment Committee is responsible for
considering how and when to implement the investment strategy and manager selection options for
each client and considers these factors, among others, when making those decisions: investment
objective, policies, and strategy of the account; appropriateness of the investment to the account’s
time horizon and risk objectives; existing levels of ownership of the investment and other similar
investments; immediate availability of cash or buying power to fund the investment; and complexity
of client portfolio (including whether the portfolio holds private investment vehicles or more liquid
securities). As a result of customizing client portfolios based on the above considerations, the time
frame for implementing the investment strategy and/or manager selection may vary client by client
which may result in different clients receiving favorable or disadvantageous execution. CCWM will
monitor the implementation plan to ensure all investment decisions are implemented fairly and in
accordance with the goals and objectives of the Investment Committee.
CCWM may also allocate a clients’ investment management assets among Independent Managers (as
defined below), mutual funds, exchange-traded funds, bonds, master limited partnerships and
alternative investments in accordance with the investment objectives of the client.
b. Non-Discretionary. CCWM may not make investment decisions, including buying or
selling securities, for the client without prior consultation with, and the consent of, the client. Clients
understand that they may forego a particular transaction if CCWM cannot obtain that consent. In
addition, certain clients, such as institutional clients, may only make investment decisions with the
approval of oversight groups, such as Board of Directors, Board of Trustees, or investment
committees. As such, depending on when these oversight groups have scheduled meetings and
CCWM has access to such oversight boards, CCWM may not have an opportunity to make
recommendations within the timeframe of the implementation plan. CCWM will make investment
recommendations as soon as practicable, and may, if deemed necessary, request access to the oversight
committee in between scheduled meetings. If such access is not available, however, CCWM may not
be able to make recommendations and get consent in accordance with implementation plans available
to other clients. Non-discretionary investment management services can negatively impact client
accounts if CCWM is unable to contact clients during sudden negative market conditions.
With respect to its non-discretionary asset management services, CCWM generally maintains ongoing
responsibility to make recommendations, based upon the needs of the client, as to the specific
securities the account may purchase or sell. The final decision on investment selection rests with the
client in this arrangement and the client always maintains asset control. CCWM may place trades for
clients under a limited power of attorney, as may be provided by the client. Certain of the alternative
investments recommended by the Firm, which may include debt, equity and/or pooled investment
vehicles, exist in the form of private placement securities. As such, CCWM limits such
recommendations to those clients which are deemed to be “accredited investors”, or “institutional
investors” as defined under Rule 501 of the Securities Act of 1933.
Prior to engaging CCWM to provide investment management services, the client is required to enter
into a written investment management agreement with CCWM setting forth the terms and
conditions of the engagement (the “Investment Management Agreement”).
Independent Managers
CCWM may recommend that certain clients authorize the active discretionary management of a
portion of their assets among Independent Managers.
When selecting an Independent Manager for a client, CCWM considers the client’s stated investment
objectives as well as the Independent Manager’s reputation, performance, management style,
investment strategies, past performance, and disclosures and/or research materials. CCWM will
continue to provide ongoing monitoring and review of account performance and asset allocation as
compared to account and overall portfolio investment objectives. The investment management fee
charged by the Independent Manager is separate from, and in addition to, CCWM’s advisory fee.
In addition to CCWM’s written disclosure brochure, the client also receives the written disclosure
brochure of the designated Independent Managers. Certain Independent Managers may impose more
restrictive account requirements and varying billing practices than CCWM. In such instances, CCWM
may alter its corresponding account requirements and/or billing practices to accommodate those of
the Independent Managers.
A client may also choose to implement CCWM’s recommendations through CCWM. In the event the
client decides to implement investment recommendations through CCWM on a fee basis, CCWM
shall charge an annual investment management fee based upon a percentage of the market value of
the assets being managed by CCWM. The investment management fee charged shall vary (generally
between 0.25% and 1.00%) depending upon the market value of assets under management and the
specific type of discretionary or non- discretionary investment management services to be rendered.
The terms and conditions under which the client shall engage the Independent Managers shall be set
forth in separate written agreements between the client and CCWM and the client and the designated
Independent Managers. CCWM shall continue to render non-investment supervisory services to the
client relative to the ongoing monitoring and review of account performance, asset allocation and
client investment objectives, for which CCWM shall receive an annual advisory fee which is based
upon a percentage of the market value of the assets being managed by the designated Independent
Managers.
The investment management fees charged by the designated Independent Managers are exclusive of,
and in addition to, CCWM’s ongoing investment advisory fee.
Financial Planning and Consulting Services
CCWM may provide its clients with a broad range of comprehensive financial planning and consulting
services, addressing a multitude of investment and non-investment related matters which may include,
but is not limited to, the following:
• Asset protection strategies
• Charitable giving
• Philanthropic planning
• Education funding
• Insurance coverage
• Risk management
• Retirement planning
• Tax strategies
• Estate planning
• Succession planning
Prior to engaging CCWM to provide financial planning and/or consulting services, the client will be
required to enter into a financial planning agreement with CCWM setting forth the terms and
conditions of the engagement, describing the scope of the services to be provided (the “Financial
Planning Agreement”).
In the event the client terminates CCWM’s investment management, financial planning, and/or
consulting services, the balance of CCWM’s fee, if any, shall be refunded to the client.
Neither CCWM nor the client may assign a Financial Planning Agreement or Investment Management
Agreement without the prior consent of the other party. Transactions that do not result in a change
of actual control or management of CCWM shall not be considered an assignment.
A client may terminate any of the aforementioned agreements at any time by notifying CCWM in
writing and paying the rate for the time spent on the investment advisory engagement prior to
notification of termination. If the client made an advance payment, CCWM’s fee shall be prorated
through the date of termination. CCWM may terminate any of the aforementioned agreements at any
time by notifying the client in writing. If the client made an advance payment, CCWM’s fee shall be
prorated through the date of termination.
A copy of the written disclosure statement for CCWM, as set forth on Part 2A and 2B of Form ADV,
shall be provided to each client prior to, or contemporaneously with, the execution of the Financial
Planning Agreement or Investment Management Agreement.
Consolidated Reporting
CCWM also provides consolidated investment reporting services, which amalgamates client accounts
from various custodians, including alternatives to show overall performance allocation and other
pertinent metrics.
Miscellaneous
ERISA / IRC Fiduciary Acknowledgment. When CCWM provides investment advice to a client about
the client’s retirement plan account or individual retirement account, it does so as 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. Because
the way CCWM makes money creates some conflicts with client interests, CCWM operates under a
special rule that requires it to act in the client’s best interest and not put its interests ahead of the
client’s. Under this special rule’s provisions, CCWM must: meet a professional standard of care when
making investment recommendations (give prudent advice); never put its financial interests ahead of
the client’s when making recommendations (give loyal advice); avoid misleading statements about
conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that
CCWM gives advice that is in the client’s best interest; charge no more than is reasonable for CCWM’s
services; and give the client basic information about conflicts of interest.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client leaving
an employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over
to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). If CCWM recommends that a
client roll over their retirement plan assets into an account to be managed by CCWM, such a
recommendation presents a conflict of interest if CCWM will earn a new (or increase its current)
advisory fee as a result of the rollover. Clients are not obligated to roll over retirement plan assets to
an account managed by CCWM.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. Except
for stand-alone financial planning engagements, CCWM will provide general financial planning and
related consulting services under its advisory fee set forth at Item 5 below. CCWM strongly
recommends that clients address financial planning and related issues with CCWM on an ongoing
basis, especially because CCWM’s fee will remain as set forth in Item 5 below regardless of whether
the client engages CCWM in that capacity. Unless specifically agreed in writing, neither CCWM nor
its representatives are responsible to implement any financial plans or financial planning advice,
provide ongoing financial planning services, or provide ongoing monitoring of financial plans or
financial planning advice. Clients are solely responsible to revisit the financial plan or financial
planning advice with CCWM, if desired. CCWM’s financial planning and consulting services are
completed upon communicating its recommendations to the client, upon delivery of the written
financial plan, or upon termination of the applicable agreement. CCWM does not serve as an attorney,
accountant, or insurance agent, and no portion of our services should be construed as same.
Accordingly, CCWM does not prepare legal documents, prepare tax returns, or sell insurance
products. To the extent requested by a client, CCWM may recommend the services of other
professionals for non-investment implementation purpose (i.e., attorneys, accountants, insurance,
etc.), including CCWM’s affiliated CPA firm, which presents a conflict of interest. Clients are not
obligated to engage the services of any recommended professionals, who are responsible for the
quality and competency of the services they provide.
Client Obligations. When performing its services, CCWM is not required to verify any information
received from the client or from the client’s designated professionals and is expressly authorized to
rely on that information. Clients are responsible to promptly notify CCWM if there is ever any change
in their financial situation or investment objectives for the purpose of reviewing or amending CCWM’s
services or previous recommendations.