A. Description of the Advisory Firm
Centerpoint Advisory Group, LLC (hereinafter “CAG”) is a Limited Liability Company
organized in the State of Kansas. The firm was formed in November 2022, and the
principal owners are Alan M Rickert, William Padek, and Parker Madl.
B. Types of Advisory Services
Portfolio Management Services
CAG offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. CAG creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
CAG evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. CAG will require discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
CAG seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of CAG’s economic,
investment or other financial interests. To meet its fiduciary obligations, CAG attempts to
avoid, among other things, investment or trading practices that systematically advantage
or disadvantage certain client portfolios, and accordingly, CAG’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is CAG’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Strategic Wealth Management Platform (SWM) & Strategic Wealth Management
Platform II (SWM II)
SWM and SWM II offer clients an asset management account that allows the IAR to direct
and manage specified client assets. The difference between SWM and SWM II is the type
of fee charged. On the SWM platform clients pay an asset based management fee and
separate transaction costs. On the SWM II platform, clients pay a single wrap fee for
advisory services and execution of transactions. The IARs can choose to use these models
within the SWM and SWM II platform; however, they still have the flexibility to deviate
from the model to suit the individual client’s needs.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; education planning; and
debt/credit planning.
As part of its financial planning services, CAG will offer estate planning services to clients
to assist with general information as it applies to review of existing plans, gathering
information needed to provide outside firms in the creation of documents, and updating
existing plans for client. To facilitate these services, CAG will generally recommend Estate
Guru Planning Software. Clients are not required to utilize a third-party service that we
may recommend, and they may receive similar services from other professionals at a
similar or lower cost. Fees associated with the service will be in addition to the fees that
clients may already pay and are disclosed within the agreement that clients sign upon
engaging in this service. CAG is not a licensed attorney and will be giving no legal advice,
creating no legal documents, and is not acting in the capacity of an attorney as part of
these engagements.
Pension Consulting Services
CAG offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
o identifying investment objectives and restrictions
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan assets in ways designed to
achieve objectives
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Selection of Other Advisers
CAG may direct clients to third-party investment advisers. Before selecting other advisers
for clients, CAG will verify that all recommended advisers are properly licensed, notice
filed, or exempt in the states where CAG is recommending the adviser to clients.
Services Limited to Specific Types of Investments
CAG generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), equities, ETFs (including ETFs
in the gold and precious
metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities.
CAG may use other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
CAG will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by CAG on behalf of the client. CAG may use model allocations together
with a specific set of recommendations for each client based on their personal restrictions,
needs, and targets. Clients may not impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
CAG acts as portfolio manager in a wrap fee program, which is an investment program
where the client pays one stated fee that includes management fees, transaction costs, and
certain other administrative fees. The wrap fee program is sponsored by CAG and clients
utilizing the wrap fee program should also review the sponsor’s separate Wrap Fee
Program Brochure. CAG manages the investments in the wrap fee program, but does not
manage those wrap fee accounts any differently than it would manage non-wrap fee
accounts. CAG receives the advisory fee set forth in the wrap fee brochure as a
management fee under the wrap fee program.
Although clients do not pay a transaction charge for transactions in a SWM II account,
clients should be aware that CAG pays LPL Financial transaction charges for those
transactions. The transaction charges paid by CAG vary based on the type of transaction
(e.g., mutual fund, equity or ETF) and for mutual funds based on whether or not the
mutual fund pays 12b-1 fees and/or recordkeeping fees to LPL Financial. Transaction
charges paid by the CAG for equities and ETFs are $9. For mutual funds, the transaction
charges range from $0 to $26.50. Because CAG pays the transaction charges in SWM II
accounts, there is a conflict of interest in cases where the mutual fund is offered at both $0
and $26.50. Clients should understand that the cost to CAG of transaction charges may be
a factor that CAG considers when deciding which securities to select and how frequently
to place transactions in a SWM II account.
In many instances, LPL Financial makes available mutual funds in a SWM II account that
offer various classes of shares, including shares designated as Class A Shares and shares
designed for advisory programs, which can be titled, for example, as “Class I,”
“institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share
classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund
in SWM II in many cases will not be the least expensive share class that the mutual fund
makes available and was selected by LPL Financial in certain cases because the share class
pays LPL Financial compensation for the administrative and recordkeeping services LPL
Financial provides to the mutual fund. Clients should understand that another financial
services firm may offer the same mutual fund at a lower overall cost to the investor than
is available through SWM II. In other instances, a mutual fund may offer only Class A
Shares, but another similar mutual fund may be available that offers Platform Shares.
Class A Shares typically pay LPL Financial a 12b-1 fee for providing shareholder services,
distribution, and marketing expenses (“brokerage-related services”) to the mutual funds.
Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses
of the mutual fund share classes, it is generally more expensive for a client to own Class
A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over
time and keep more of his or her investment returns than an investor who holds Class A
Shares of the same fund.
E. Assets Under Management
CAG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$175,000,000 $11,400,000 December 2023