Firm Description
Capital Asset Management, LLC (“CAM”) was founded in January of 2003 and registered as an
investment advisor in July of 2016. Prior to registration as an investment advisor, CAM was used
as a dba for Mr. Matthew Hickey’s advisory and securities business with various firms. Matthew
Hickey is 100% owner.
ASSET MANAGEMENT
CAM offers discretionary direct asset management services to advisory Clients. CAM will offer
Clients ongoing portfolio management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection,
asset allocation, portfolio monitoring and the overall investment management process will be
based on the above factors. The Client will authorize CAM discretionary authority to execute
selected investment program transactions as stated within the Investment Advisory
Agreement.
Clients maintain the right to place certain restrictions on our discretionary authority such as
prohibiting the securities of a certain issuer or a certain type. Such restrictions could include
only allowing purchases of socially conscious investments. These restrictions must be provided
to CAM in writing.
Envestnet
CAM offers discretionary direct asset management services to advisory Clients utilizing
Envestnet’s wrap program described in detail in their appendix. The wrap program provides
access to the portfolios on the Envestnet platform. CAM will offer Clients ongoing portfolio
management services through determining individual investment goals, time horizons,
objectives, and risk tolerance. Investment strategies, investment selection, assets allocation,
portfolio monitoring and the overall investment program will be based on the above factors.
The Client will authorize CAM discretionary authority to execute selected investment
program transactions as stated within the Investment Advisory Agreement.
SEI Managed Accounts Solutions
CAM offers discretionary management services through a program sponsored by SEI
Management Corp (SIMC). SIMC has developed a standard managed account solutions (“MAS”),
which program includes SEI’s distribution focused strategies, an integrated managed account
solutions providing a tax overlay service (“Tax Management”) and a Goals Based Investing
managed account solutions, consisting of MAS and Tax Management portfolios invested in
accordance with SEI’s goals-based investment solutions and, may, in the future, develop
additional managed account solutions (collectively, the “Managed Account Solutions”). Under
this program, SIMC acts as a co-investment advisor to the Investor, along with CAM, pursuant
to a tri-party investment management agreement executed among SIMC, CAM and each
Investor investing assets into the Managed Account Solutions (the “Tri-party Agreement”). For
each Managed Account Solutions, SIMC is responsible for developing managed account
portfolios designed to be invested in accordance with a stated investment objective (the
“Managed Account Portfolios”). For each Managed Account Portfolio, other than the Managed
Account Portfolios implementing distribution-focused strategies (the “DFS Portfolios”), SIMC is
solely responsible for screening, reviewing and selecting the various money managers and/or
individual mutual funds and Other Assets available for selection by Advisors and their Investors
designed to meet the specific Managed Account Portfolio’s stated investment objective or goal.
For each DFS Portfolio, SIMC is responsible for selecting the SEI Funds and/or Other Assets
underlying each DFS Portfolio and actively managing each Investor Account invested in a DFS
Portfolio in accordance with the portfolio’s investment objectives.
SEI Mutual Fund Models Program and SEI Funds
CAM offers discretionary management services through a program sponsored by SEI
Management Corp (SIMC). SIMC has developed various model mutual fund asset allocation
portfolios (the "Mutual Fund Models") designed to be invested in accordance with a stated
investment objective or goal (the "Mutual Fund Models Program"). SIMC currently develops its
Mutual Fund Models through two underlying programs, described in various SEI literature as
either SEl's Institutional Mutual Fund models or SEl's Goals Based Investing models and, may
in the future, develop additional mutual fund model programs. Each Mutual Fund Model's
underlying portfolio
allocation is generally comprised exclusively of mutual funds in the SEI
family of funds ("SEI Funds"), which are each advised by SIMC. Pursuant to the Mutual Fund
Models Program, SEI will make available its various Mutual Fund Models to CAM who, in turn,
may assist Investors in determining into which Mutual Fund Models to invest their assets.
ERISA PLAN SERVICES
CAM provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit sharing plans, cash balance plans, and deferred compensation plans. CAM
acts as a 3(21) advisor:
Limited Scope ERISA 3(21) Fiduciary. CAM may serve as a limited scope ERISA 3(21) fiduciary
that can advise, help and assist plan sponsors with their investment decisions on a non-
discretionary basis. As an investment advisor CAM has a fiduciary duty to act in the best interest
of the Client. The plan sponsor is still ultimately responsible for the decisions made in their plan,
though using CAM can help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s investment
policies and objectives. Client will make the final decision regarding the initial selection,
retention, removal and addition of investment options. CAM acknowledges that it is a
fiduciary as defined in ERISA section 3 (21) (A) (ii).
Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the ultimate
responsibility and authority to establish such policies and objectives and to adopt and
amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The Client
retains the sole responsibility to provide all notices to the Plan participants required under
ERISA Section 404(c) (5) and 404(a)-5.
Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance to
the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information and the
investment alternatives available to them under the Plan. Client understands CAM’s
assistance in education of the Plan participants shall be consistent with and within the scope
of the Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, CAM is not providing fiduciary advice as defined by
ERISA 3(21)(A)(ii) to the Plan participants. Advisor will not provide investment advice
concerning the prudence of any investment option or combination of investment options for
a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan participation
among the employees and investment and financial understanding by the employees.
CAM may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Advisor and Client.
3. CAM has no responsibility to provide services related to the following types of assets (“Excluded
Assets”):
Employer securities;
Real estate (except for real estate funds or publicly traded REITs);
Stock brokerage accounts or mutual fund windows;
Participant loans;
Non-publicly traded partnership interests;
Other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or
Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to CAM on the ERISA Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
As of March 2024, CAM had $150,168,176 in discretionary assets under management and
$33,901,858 in non-discretionary assets under management.