Firm Description
NBT Capital Management, Inc., hereinafter referred to as NBTCM or the Firm, is a
Registered Investment Advisory firm, registered with the Securities and Exchange
Commission. NBTCM is a privately held corporation and a wholly owned subsidiary
of NBT Bancorp, which is headquartered in Norwich, New York.
Effective April 1, 2020, EPIC Advisors, Inc., a wholly owned subsidiary of NBT
Bancorp, acquired substantially all of the assets of ABG Retirement Plan Investment
Services, a subsidiary of Alliance Benefit Group of Illinois, Inc. (ABGIL), an SEC
registered advisor that conducted business under the ABG Retirement Plan Investment
Services name, providing investment advisory services to plan sponsors and trustees of
qualified and non-qualified retirement plans. The acquisition included the assignment of
client agreements from ABGIL to EPIC. As part of this transaction, the assets and clients
of ABGIL were then immediately transferred to NBTCM. In addition, NBTCM acquired
the DBA name of ABG Retirement Plan Investment Services. Effective 1/29/24 ABG
Retirement Plan Investment Services has rebranded to Navigate Retirement Solutions
On April 1, 2022, NBT Bank’s subsidiary, EPIC Retirement Plan Services, completed the
acquisition of Cleveland Hauswirth Investment Management (“CH”).CH is a Registered
Investment Advisor located in Milwaukee, WI with $150 million in assets under
management that provides investment advice and fiduciary services to over 70 individual
and corporate retirement plan clients. All assets of CH were transferred to NBTCM
Moving forward, NBTCM will provide different services under the NBTCM name,
Navigate Retirement Solutions, and Cleveland Hauswirth Investment Management
names.
Navigate Retirement Solutions
NBTCM will provide services to plan trustees and plan investment committees under the
Navigate Retirement Solutions name (hereinafter referred to as NRS). These services
will include both fiduciary and non-fiduciary services. NRS’s fiduciary services will
focus primarily on providing investment advice to plan trustees and plan investment
committees with respect to the selection and monitoring of funds that are offered by a
plan to its participants. Where appropriate and so elected by the client, these services
may also include Investment Manager functions under ERISA Section 3(38). Non-
fiduciary services may include the development of written Investment Policy Statements,
establishing procedures for a plan’s Investment Committee, plan participant education
functions, and/or assistance with specific vendor selections.
Cleveland Hauswirth Investment Management
NBTCM will provide services to retirement plans and individuals under the Cleveland
Hauswirth Investment Management name (hereinafter referred to as CH or Cleveland
Hauswirth).Cleveland Hauswirth was founded in 1995 under the original name of Maier
Hauswirth Investment Advisors, LLC. CH specializes in providing personalized,
investment advisory services to retirement plans including 401(k) plans, profit sharing
plans and defined benefit plans. CH also provides advisory services to individuals with
portfolios of mutual funds, stocks and bonds. An asset-based fee is charged for services.
CH does not sell investment products for commission.
NBTCM Services
NBTCM has historically provided and will continue to provide traditional investment
advisory services inclusive of personalized confidential financial planning, asset
management and related consulting services to individuals, high net worth individuals,
pension and profit-sharing plans, trusts, charitable organizations and small businesses.
Recommendations to clients are made based on consultation with the client and analysis
of each client’s specific financial needs and may include the following focused services:
Determination of financial objectives Identification of financial problems
Cash flow management Tax planning
Insurance review Investment management
Education funding Retirement planning
Estate planning
Within the context of providing these services, clients may place restrictions on the types of
securities to be held within their portfolios but may cede general investment discretion authority
to their advisor. NBTCM, at this time, does not offer its clients wrap fee programs. Wrap
programs charge a single consolidated advisory fee for an investment program that bundles
together a suite of services, such as brokerage, advisory, research and management. Investment
advisory services may be provided to clients on either a discretionary or non-discretionary basis.
In all services provided, NBTCM does not act as a custodian of client assets, opting
instead to utilize the services of the following outside custodial firms at this time:
• Charles Schwab & Co., previously referred to herein as Schwab, an independent
and unaffiliated SEC-registered broker/dealer and a member of
FINRA/SIPC/NFA;
• TD Ameritrade Institutional, hereinafter referred to as TD Ameritrade, an
independent and unaffiliated SEC-registered broker/dealer and a member of
FINRA/SIPC;
• TIAA-CREF Individual & Institutional Services LLC, an independent,
unaffiliated SEC-registered broker/dealer and a member of FINRA/SIPC.
• Fidelity Investments Inc, hereinafter referred to as Fidelity, an independent and
unaffiliated SEC-registered broker/dealer and a member of FINRA/SIPC
• LPL Financial Holdings, Inc, hereinafter referred to as LPL Financial, an
independent and unaffiliated SEC- registered broker/dealer and a member of
FINRA/SIPC
NBTCM may, to better serve specific client needs, elect to use the services of other custodians as
well, at its discretion. The clients always maintain control of their assets but may authorize
NBTCM to transact trades on their behalf, without prior consultation, by the discretion
authorization contained in a discretionary advisory agreement executed with the Firm.
A written evaluation of each client's initial situation is prepared prior to the
commencement of services. Periodic account review summaries may also be provided to clients
as reminders of the specific courses of action that need to be taken. More frequent reviews may
occur but are not necessarily communicated to clients unless immediate changes are to be
recommended.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be engaged
directly by either the client or NBTCM, on an as-needed basis. Potential conflicts of
interest resulting from such outside referrals and/or engagements will be immediately
disclosed to the client in the unlikely event they should or potentially could occur.
The initial discovery meeting with new clients, which may be either in-person or by
telephone, is free of charge and is considered an exploratory interview to determine the
extent to which financial planning and/or investment management services offered by
NBTCM may be beneficial to the client.
As of December 31, 2023, NBTCM had approximately $1,324,321,206 in assets under
management for 624 advisory clients with approximately $936,880,010 managed on a
discretionary basis and approximately $ 387,441,196 managed on a non-discretionary basis
Principal Owners
As previously stated, NBTCM is wholly owned by NBT Bank, N.A. of Norwich, New
York. NBT Bank, N.A. currently holds 100% ownership of NBTCM stock.
Types of Advisory Services
NBTCM provides traditional investment advisory services, also known as asset
management services, as well as financial planning and consultative services to its
clients. NBTCM also offers a digital investment advisory service.
• Asset management services may entail the active or passive management of
investment accounts, furnishing of investment advice through consultations
with clients, issuing periodic newsletters or special reports to its clients about
securities and market conditions or trends and evaluating securities held by
clients to foster an understanding of their assets relative to their stated goals and
objectives.
• Financial planning services are provided to clients to assist them in pursuing
both short- and long-range financial goals. This is accomplished through a
process of collecting client information about the client’s current financial
condition, clarification of their goals, identification of their past efforts and
current abilities in pursuit of their goals and ongoing progress reviews relative
to any actions taken.
• On more than an occasional basis, NBTCM may furnish consulting services to
clients on matters not involving securities, such as taxation, trust management
and estate planning. However, the Firm does not act in the capacity as a tax or
legal advisor to its clients.
• As noted above, NBTCM offers a digital advisory service platform. Clients
utilizing this option are allowed a high degree of self-direction in the structuring
of their investment portfolio through the selection of established models while
retaining the assistance of a professional investment advisor who will provide
the following advisory services:
(i) An evaluation of the client’s investment objectives and risk
tolerance level.
(ii) Implementation of an investment program using Exchange-Traded
Funds (ETF’s); and
(iii) An adviser will be available to meet with the client upon request to
discuss client’s account and other financial matters, which may affect
the managing of the client’s account.
The Firm is compensated for its advisory services to clients through asset management
fees, fixed fees or hourly fees as determined by the types of services elected by the
clients.
NBTCM under the NRS name offers non-fiduciary and fiduciary services to both
qualified and non-qualified retirement plans. Non-fiduciary services include
development of a written Investment Policy Statement, assistance in establishing
procedures for the Plan's Investment Committee, education of Plan Participants and
assistance with other vendor services. Fiduciary services include advice regarding
investment alternatives, analysis, and fund monitoring services NRS will provide
discretionary investment management services as described under ERISA Section
3(38) to clients who elect this service as set forth in the Agreement.
Tailored Relationships
The goals and objectives for each client are documented at the onset of services.
Investment strategies are then created that reflect the stated goals and objectives of
each client. Clients may impose restrictions on investing in certain securities or types
of securities, with the understanding that such restrictions may impair the Firm’s pursuit
of a client’s management objectives.
Types of Agreements
Prior to engaging NBTCM’s services, clients are required to sign an agreement which
defines the services that will be provided by the Firm. The following agreements
define the typical client relationships between NBTCM and its clients. Agreements
may not be assigned or transferred to parties other than the original clients entering
into the agreements. Since NBTCM does not maintain custody of client assets,
however, separate agreements may also need to be executed between custodial firms
and the client, in addition to the agreements of the Firm described below. Since
neither NBTCM nor its advisors act as attorneys, their recommendations should not be
interpreted as legal advice.
Financial Planning and Consulting Service Agreement
Planning or consulting service clients are required to sign a Financial Planning and
Consulting Service Agreement with the Firm. This agreement outlines the nature and
level of advisory services to be provided, without requiring the direct management of
the client’s assets.
For financial planning clients, information regarding a client’s personal and financial
situation and objectives is collected by the advisor through a confidential interview
process. This data is analyzed and a written financial plan, with specific
recommendations,
is presented to clients if and when appropriate to do so.
The financial plan may include, but is not limited to a net worth statement, a cash
flow statement, a review of investment accounts including reviewing past asset
allocations, providing asset repositioning recommendations, strategic tax planning,
education planning with funding recommendations, a review of retirement accounts
and plans including recommendations and one or more retirement scenarios, a review
of insurance policies and recommendations for changes, if necessary and an estate
planning review and recommendations.
As previously stated, the Firm does not provide legal or accounting advice relative to
its financial plans. It will, however, act as a facilitator in these areas between clients and their
legal and/or tax advisors relative to the recommendations made in a financial plan.
Detailed investment advice and specific recommendations are provided as part of a
financial plan. Implementation of the recommendations is at the discretion of the
client and may be implemented with either NBTCM or with a financial advisor of
the client’s choosing.
Consulting services may be provided to clients regarding other financial-related
concerns in situations where detailed or comprehensive financial planning is either not necessary
or not desired. Common areas of concern addressed by these services include:
Education planning Simple investment planning
Death, disability and retirement planning Tax planning
Net worth, cash flow and financial position Risk management (insurance)
Other investment or non-investment issues Estate planning
Investment Management Agreement
Most clients choose to have NBTCM manage their assets in order to obtain ongoing
in-depth advice and life planning. These clients are required to sign an Investment
Management Agreement which defines the manner in which their assets will be
managed and the fees assessed by the Firm. The scope of work and fee for an
Investment Management Service Agreement is provided to the client in writing prior
to the start of the relationship. This Agreement includes the following services:
• An evaluation of the client’s present portfolio and a determination of the client’s
investment objectives and risk tolerance level;
• Selection of the components of an investment portfolio based on the client’s
individual facts and circumstances;
• Implementation, monitoring and rebalancing of the portfolio through the purchase
and sale of securities such as no-load mutual funds, exchange-traded funds,
individual equities and other securities that we deem appropriate for the situation;
• Quarterly performance reports;
• A periodic review of the client’s portfolio allocation; and
• An update of the client’s personal financial information, goals and objectives to
determine if any changes in the portfolio design are warranted.
Based on each client’s objectives and suitability factors identified in their suitability
documents, the advisor will develop a plan with each client that focuses on capital
preservation, income generation, growth of principal, speculation or a combination of
two or more objectives. All aspects of the client’s financial affairs are reviewed,
including those of their dependents, if any. Realistic and measurable goals are set and
objectives to reach those goals are defined. As goals and objectives change over time,
suggestions are made and implemented on an ongoing basis.
Asset management services may be provided on either a discretionary or
non-discretionary basis. Under the terms of our discretionary agreement, clients
authorize the advisor to buy, sell, invest, reinvest, exchange and/or trade securities in
their accounts at his/her sole discretion and without consulting with the client in
advance. Non-discretionary accounts require the advisor to consult with the client to
gain consent and approval prior to engaging in any of these trading activities on the
client’s behalf.
NBTCM’s standard investment management fee for non-NRS clients is based on a
percentage of the client’s investable assets under management by the Firm according to
the following schedule:
1.00% on the first $1,000,000
¾ of 1% on everything over 1,000,000
NBTCM will assess these clients a minimum annual fee of $500 when applicable.
Fees are billed quarterly in arrears and deducted directly from clients’ advisory
accounts by the account custodian, unless otherwise agreed to (i.e. direct invoicing to
the client by NBTCM).
These fee structures may be negotiable, at the discretion of the advisor, based on potential
deviations from our standard Investment Management Agreement services. Current client
relationships may exist where the fees are higher or lower than the fee schedules above
due to desired deviations in the standard service structure or because a prior fee schedule
has been “grandfathered” due to our long-term relationship with the client.
On the LPL platform, clients pay LPL and its IAR’s an annual account fee for advisory
services. The account fee is negotiable between the client and the IAR and is set out in
the Account Application. The account fee is typically a straight percentage based on the
value of all assets in the account, including cash holdings. Upon request, the account fee
may be structured on a tiered basis and/ or grouped basis, with a reduced percentage rate
based on reaching certain thresholds in the account or in a group of eligible advisory
accounts. The account fee is paid to LPL and is shared between LPL and the IAR. The
account fee is paid to LPL, and LPL retains up to .20% of the account fee, which is not
shared with the IAR, for its administrative services. LPL shares up to 100% (typically
between 90% and 100%) of the remaining portion of the account fee with the IAR based
on the agreement between LPL and the IAR.
Cleveland Hauswirth Investment Management Agreement
CH advisory services are delivered from the Registered Investment Advisor platform.
CH performs many tasks on a discretionary basis and as a fiduciary, acting in the best
interest of our clients. Individual clients enter into a discretionary relationship where
CH takes full responsibility to execute a pre-determined client objective. The
Investment Management Agreement describes CH services, investment restrictions if
any, the fee to be charged and method of fee payment chosen. A retirement plan
Investment Management Agreement acknowledges CH as a Fiduciary of the plan under
Sections 3(21) and 3(38) of the Employee Retirement Income Security Act (ERISA).
This means we take on the role and duties of a plan’s Investment Fiduciary. It also
outlines services and responsibilities to the plan sponsor and the plan, describes the fee
to be charged and the method of fee payment chosen. Agreements may not be assigned
to another entity without your consent
Assets are invested primarily in no-load mutual funds. Multiple mutual fund strategies
are combined in a portfolio to follow an individual client’s investment objective.
Retirement plans use multiple mutual fund strategies, stable value funds and money
market funds. Other investment tools we may use or offer advice on include: exchange
traded funds, equity securities (stocks), corporate debt securities (bonds), certificates of
deposit, municipal securities, U.S. government securities
Cleveland Hauswirth bases its fees on a percentage of assets under management. CH
uses no-load mutual funds and other securities we can buy that do not have commission
payments attached. CH may from time to time provide consulting services to clients and
charge $200 to $250 per hour, with clerical support billed at $50 per hour. Services may
also be provided on a negotiated, fixed fee basis. Fees are negotiable. Annual Fee
Schedule – Individual Clients $0 to $1,000,000 1.00% $1,000,001 to $2,500,000 0.80%
$2,500,001 and over 0.60% Annual Fee Schedule – 401(k) or Other Qualified Plan
Assets Fee as a Percentage of Assets $0 to $1,000,000 0.75% $1,000,001 to $2,500,000
0.65% $2,500,001 to $5,000,000 0.55% $5,000,001 and over 0.45% or negotiated rate
Minimum Annual Fee - $2,500. Management fee will be calculated using one rate that
represents the value of total relationship assets (as opposed to a tiered method).
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Retirement Planning Consulting Agreement
NRS provides investment management services as a 3(38) investment manager under an
Investment Management & Retirement Plan Consulting
Agreement and fiduciary services as a 3(21) fiduciary under an Investment Fiduciary
& Retirement Plan Consulting Agreement (collectively “Retirement Plan Consulting
Agreements”). The scope of work and fee for a Retirement Plan Consulting
Agreement is provided to the client in writing prior to the start of the relationship.
This Agreement includes the following services:
• Investment (typically mutual fund or collective investment fund) research geared
towards advising a plan trustee or the plan’s investment committee on the
selection of an appropriate investment menu;
• Quarterly monitoring of a plan’s investment performance, expenses, management
tenure, style drift and other relevant mutual fund factors; and
• Periodic group and individual meetings with plan participants to provide
information on plan provisions, investment education and assistance with
enrolling in the plan.
__________________________________________________________________________
Non-Fiduciary Retirement Plan Consulting Agreement
NRS provides non-fiduciary services to its clients. Non-fiduciary services included
development of a written Investment Policy Statement, education of Plan Participants,
and ongoing assistance with other vendor services.
Our standard Investment Management & Retirement Plan Consulting fee and Non-
Fiduciary Retirement Plan Consulting fee may be based on a percentage of plan assets,
a flat fee or a combination of both. The fee structure for each client depends on the
services desired, complexity of the overall plan, demographics of the participant group,
geographic location(s) and other factors unique to the client and the services provided.
Fees may be paid by the plan sponsor (i.e. employer), the plan participants or a
combination of both according to ERISA rules and regulations. NRS clients are billed
quarterly, either in advance or in arrears, as agreed to in their Respective asset
management agreement. Fees generally range from 10 to 100 basis points and are
negotiated on an individual basis and can include a negotiated minimum annual fee.
Annual asset-based fees can at times exceed this range, such as if a client’s agreement
includes a minimum fee.
Fees may be negotiable at the discretion of NRS, based on client specific facts and
circumstances, and subject to CCO approval. Full disclosure is provided to plan
participants regarding fees assessed to them.
Termination of Agreements
NRS clients may terminate their existing service agreement by providing 30 days
advanced written notice to NRS. A client may terminate any other existing service
agreement at any time by notifying NBTCM, NRS or Cleveland Hauswirth in writing. For
Cleveland Hauswirth clients the termination will become effective 10 business days from
receipt for individual client and 30 days from a retirement plan client. A final fee may be
assessed based on the number of days that have elapsed during the current quarter for
investment management services or on the amount of time already spent on retirement
planning or Retirement Plan advisory services prior to NBTCM’s receipt of notification
of termination from the client. NBTCM may also terminate any existing service
agreement at any time by notifying the client in writing.
In addition, NBTCM reserves the right to terminate any advisory engagement where a
client has willfully concealed or has refused to provide pertinent information about
financial situations when necessary and appropriate, in NBTCM’s judgment, to providing
proper financial advice.