A. Description of the Advisory Firm
Cobblestone Asset Management LLC (hereinafter “Cobblestone Asset Management”) is a
Limited Liability Company organized in the State of Virginia. The firm was formed in
March 2019, and the principal owner is Cobblestone Asset Management.
B. Types of Advisory Services
Portfolio Management Services
Cobblestone Asset Management offers ongoing portfolio management services based on
the individual goals, objectives, time horizon, and risk tolerance of each client.
Cobblestone Asset Management creates an Investment Policy Statement for each client,
which outlines the client’s current situation (income, tax levels, and risk tolerance levels).
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
Cobblestone Asset Management evaluates the current investments of each client with
respect to their risk tolerance levels and time horizon. Risk tolerance levels are
documented in the Investment Policy Statement, which is given to each client.
Cobblestone Asset Management seeks to provide that investment decisions are made in
accordance with the fiduciary duties owed to its accounts and without consideration of
Cobblestone Asset Management’s economic, investment or other financial interests. To
meet its fiduciary obligations, Cobblestone Asset Management attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, Cobblestone Asset Management’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 Cobblestone
Asset Management’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.
Platform Services
Cobblestone Asset Management may provide their platform to advisors unaffiliated with
Cobblestone Asset Management. These third-party advisors would utilize Cobblestone
Asset Management's platform to provide portfolio management services to their
clients. This relationship will be memorialized in each contract between Cobblestone
Asset Management and the third-party advisor. Cobblestone Asset Management will
have no contact with the third-party advisors' clients. The third-party advisor will be
responsible for client due diligence, suitability, and providing Cobblestone Asset
Management with discretionary authority, if applicable.
Selection of Other Advisors
Cobblestone Asset Management may direct clients to third-party investment advisors.
Before selecting other advisors for clients, Cobblestone Asset Management will verify that
all recommended advisors are properly licensed, notice filed, or exempt in the states
where Cobblestone Asset Management is recommending the advisor to clients.
Services Limited to Specific Types of Investments
Cobblestone Asset Management generally limits its investment advice to equities, fixed
income securities, real estate funds (including REITs), ETFs (including ETFs in the gold
and precious metal sectors), mutual funds treasury inflation protected/inflation linked
bonds, commodities, non-U.S. securities, venture capital funds and private placements,
and insurance products including annuities although Cobblestone Asset Management
primarily recommends ETFs. Cobblestone Asset Management 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
Cobblestone Asset Management 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 Cobblestone Asset Management on behalf of the
client. Cobblestone Asset Management may use model allocations together with a specific
set of recommendations for each client based on their personal restrictions, needs, and
targets. Clients may impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs. However, if the restrictions prevent
Cobblestone Asset Management from properly servicing the client account, or if the
restrictions would require Cobblestone Asset Management to deviate from its standard
suite of services, Cobblestone Asset Management reserves the right to end the
relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. Cobblestone Asset Management acts as
portfolio manager for and sponsor of 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. However, this brochure describes
Cobblestone Asset Management’s non-wrap fee advisory services; clients utilizing
Cobblestone Asset Management’s wrap fee portfolio management should see
Cobblestone Asset Management’s separate Wrap Fee Program Brochure. Cobblestone
Asset Management 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.
The benefits under a wrap fee program depend, in part, upon the size of the account, the
costs associated with managing the account, and the frequency or type of securities
transactions executed in the account. For example, a wrap fee program may not be suitable
for all accounts, including but not limited to accountings holding primarily, and for any
substantial period of time, cash or cash equivalents investments, fixed income securities
or no-transaction-fee mutual funds, or any other type of security that can be traded
without commissions or other transaction fees. In order to evaluate whether a wrap fee
arrangement is appropriate for you, you should compare the agreed-upon Wrap Fee
Program with the amounts that would be charged by other advisers, broker-dealers, and
custodians, for advisory fees, brokerage and execution costs, and custodial services
comparable to those provided under the Wrap Fee Program.
E. Assets Under Management
Cobblestone Asset Management has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$134,064,081 $0 September 2023