Cookson Peirce & Co., Inc. (“CooksonPeirce Wealth Management” or “CooksonPeirce”) is a fee-
only money management firm founded in June 1984. CooksonPeirce is privately held by three
principal owners, Bruce Miller, Daniel Henderson and Cory Krebs. We provide wealth
management and financial planning services to individuals, high-net worth individuals, trusts,
endowments, pensions and foundations. We refer to these clients as “private clients”. As a private
client you will have a direct relationship with CooksonPeirce. We also provide asset management
services to professional advisors at non-affiliated financial institutions. We refer to this group of
clients as “institutional clients”.
Private Clients: As a private client you will sign an investment advisory agreement directly with
CooksonPeirce. Our investment management services for private clients include conducting an
initial review of your financial situation, including your specific goals, investment objectives and
risk tolerance. Portfolios will be constructed using stocks, exchange-traded funds (ETFs), and
bonds invested in one of our model investment strategies as described in Item 8. Clients may
impose restrictions in certain securities or groups of securities. Please note, based on the increased
risk and volatility, private client assets invested in the Short-Term Aggressive strategy, will be
limited to no more than fifty percent of the clients’ assets.
As part of this process, CooksonPeirce offers financial planning services, including tax and
retirement planning. We gather information through interviews and questionnaires to understand
your financial situation and determine your financial goals. Information gathered includes income,
retirement plans, assets, taxes, investments, insurance policies, trusts, wills, future goals and
related documents. Based on the information and documents reviewed, we assist you in designing
a plan to help pursue your stated financial goals and objectives. CooksonPeirce receives no
additional compensation for financial plans.
CooksonPeirce may also provide estate planning for some clients by providing an estate tax
analysis. We will review current documents and may recommend basic estate tax saving strategies
and demonstrate hypothetical results. If updates or new documents are recommended,
CooksonPeirce may recommend the services of other professionals. The client is free to accept or
reject any recommendation. CooksonPeirce and its representatives do not serve as attorneys and
the services should not be construed as legal advice. CooksonPeirce receives no additional
compensation for estate planning advice or consulting services.
InvestStronger: CooksonPeirce offers discretionary management to private clients who are below
our account minimum through an automated investment advisory solution, known as Invest
Stronger. The minimum account size for this service is $5,000. Clients complete a brief online
questionnaire to assess their risk tolerance and investment needs. The Invest Stronger portfolios
consist of three diversified portfolios composed of exchange traded funds and a cash allocation.
Based on your personal risk tolerance, you will choose from one of the three investment portfolio
options. These portfolios are developed and overseen by the CooksonPeirce’s portfolio
management team. The portfolios and underlying investments are regularly monitored and
rebalanced monthly. Once enrolled you can update your investment profile and monitor your
accounts through a customized dashboard.
Institutional Clients: Our services for professional advisors are restricted to the management of
stock and ETF portfolios. This is generally done as a sub-advisor to an open-end mutual fund or
as a portfolio manager within a wrap fee program.
CooksonPeirce serves as a portfolio manager in a number of wrap fee programs. The sponsors of
programs include, but is not limited to: (i) Raymond James’ Consulting Services Program; (ii)
UBS Financials’ Managed Accounts Consulting Program; (iii) RBC’s MAP Program; (iv) LPL’s
Manager Select/Manager Access Select Program; (v) Wells Fargo’s Private Advisor Network; and
(vi) Smithfield Trust. These wrap fee programs are arrangements
in which investment advisory
service, brokerage execution services and custody are provided by a sponsor for a single
predetermined “wrap” fee (regardless of the number of trades completed by a client). Generally,
clients participating in a wrap fee program (“Wrap Program Clients”) pay this single, all-inclusive
fee quarterly in advance to the program sponsor, based on the net assets under management.
CooksonPeirce receives from the program sponsor a portion of the wrap fee for the portfolio
management services it provides. Each program sponsor has prepared a brochure which contains
detailed information about its wrap fee program, including the wrap fee charged. Copies of each
brochure are available from the program sponsor upon request. Each wrap program sponsor has
retained CooksonPeirce through a separate investment advisory contract. In some instances, you
may sign an agreement directly with CooksonPeirce.
Wrap Program Clients should note that CooksonPeirce will execute transactions for their accounts
through the Wrap Sponsor. Transactions executed through a Wrap Sponsor may be less favorable
in some respects than CooksonPeirce’s clients whose trades are not executed through the Wrap
Sponsor. This is because CooksonPeirce may have no ability to negotiate price or take advantage
of combined orders or volume discounts. CooksonPeirce may be constrained in obtaining best
execution for Wrap Program Clients by sending trades to the Wrap Sponsor.
CooksonPeirce serves as sub-advisor to an open-end mutual fund, the Catalyst Dynamic Alpha
Fund “Fund”. This Fund is managed pursuant to the investment strategy and restrictions as
described in the prospectus. For the investment management of the Fund, CooksonPeirce receives
an investment management fee and administrative fees from the Fund and/or reimbursement of
operating expenses by the Fund. CooksonPeirce does not provide tailored investment advisory
services to the individual investors in the Fund. However, it is possible that some of
CooksonPeirce’s private client assets may be invested in the Fund if, in the determination of the
portfolio manager, such an investment is suitable for the client. In these cases, as explained below
under Fees and Compensation, the management fee from individual clients invested in the Fund is
waived.
For all clients we utilize a quantitative selection methodology in constructing our portfolios to
eliminate subjective and emotional decision making. The security selection methodology is highly
replicable and produces clear buy, hold and sell recommendations for every security monitored in
our database. These rankings are utilized to create unconstrained investment portfolios which aim
to tactically allocate towards those areas of the market ranked to outperform.
IRA Rollover Recommendations: For purposes of complying with the DOL’s Prohibited
Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the
following acknowledgment to you. 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.
As of December 31, 2023, the Adviser managed $1,924,727,747 of regulatory assets under
management on behalf of Clients, all on a discretionary basis.