CFS Investment Advisory Services, LLC (“CFS” or the "Firm") is a limited liability company formed on
January 1, 1998, in the State of New Jersey. CFS is a successor in interest to an entity which became
registered as an investment adviser in December 1993. CFS is owned by Gregory M. Makowski and Harris
S. Nydick, the Firm's Managing Members.
As of December 31, 2023, CFS had $2,087,107,293in assets under management, $1,323,943,132 of which
was managed on a discretionary basis and $763,164,161of which was managed on a non-discretionary
basis.
CFS offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to CFS rendering any of the foregoing advisory services, clients are required
to enter into one or more written agreements with CFS setting forth the relevant terms and conditions of the
advisory relationship (the “Advisory Agreement”).
While this brochure generally describes the business of CFS, certain sections also discuss the activities of
its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a
similar status or performing similar functions), employees or other persons who provide investment advice
on CFS’s behalf and are subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
To the extent requested by a client, CFS may provide financial planning and/or consulting services (which
may include investment and non-investment related matters, including tax planning, estate planning,
insurance planning, etc.) on a stand-alone separate fee basis.
Prior to engaging CFS to provide planning or consulting services, clients are generally required to enter
into a Financial Planning and Consulting Agreement with CFS setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided, and the portion of
the fee that is due from the client prior to CFS commencing services. If requested by the client, CFS may
recommend the services of other professionals for implementation purposes, including CFS's
representatives in their individual capacities as licensed insurance brokers. The client is under no obligation
to engage the services of any such recommended professional. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any recommendation from CFS. If the client
engages any such recommended professional, and a dispute arises thereafter relative to such engagement,
the client agrees to seek recourse exclusively from and against the engaged professional. It remains the
client's responsibility to promptly notify CFS if there is ever any change in the client’s financial situation
or investment objectives for the purpose of reviewing/evaluating/revising CFS's previous recommendations
and/or services.
Investment Management Services
CFS manages client investment portfolios on a discretionary or non-discretionary basis. Clients that
determine to engage the Firm on a non-discretionary investment advisory basis must be willing to accept
that the Firm cannot effect any account transactions without obtaining prior verbal consent to any such
transaction(s) from the client.
Thus, in the event of a market correction during which the client is unavailable, the Firm will be unable to
effect any account transactions (as it would for its discretionary clients) without first obtaining the client's
verbal consent.
CFS primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and
individual debt and equity securities, and independent investment managers (“Independent Managers”) in
accordance with their stated investment objectives.
Where appropriate, the Firm also provides advice about any type of legacy position or other investment
held in client portfolios, however, clients should not assume that these assets are being continuously
monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage CFS to
manage and/or advise on certain investment products that are not maintained at their primary custodian,
such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In these situations, CFS directs or recommends the allocation
of client assets among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
CFS tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
CFS consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon,
liquidity constraints and other related factors relevant to the management of their portfolios. Clients are
advised to promptly notify CFS if there are changes in their financial situation or if they wish to place any
limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates
on the management of their accounts if CFS determines, in its sole discretion, the conditions would not
materially impact the performance of a management strategy or prove overly burdensome to the Firm’s
management efforts.
Use of Independent Managers
As mentioned above, CFS selects certain Independent Managers to actively manage a portion of its clients’
assets. The specific terms and conditions under which a client engages an Independent Manager are set
forth in a separate
written agreement with the designated Independent Manager. That agreement can be
between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent
Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically
also receive the written disclosure documents of the respective Independent Managers engaged to manage
their assets.
CFS evaluates a variety of information about Independent Managers, which includes the Independent
Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and
other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the
Independent Managers’ investment strategies, past performance and risk results in relation to its clients’
individual portfolio allocations and risk exposure. CFS also takes into consideration each Independent
Manager’s management style, returns, reputation, financial strength, reporting, pricing and research
capabilities, among other factors.
CFS continues to provide services relative to the discretionary or non-discretionary selection of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. CFS seeks to ensure the Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests.
Retirement Plan Consulting Services
CFS also provides non-discretionary pension consulting services, pursuant to which it assists sponsors of
self-directed retirement plans with the selection and/or monitoring of investment alternatives (generally
open-end mutual funds) from which plan participants shall choose in self-directing the investments for their
individual plan retirement accounts. In addition, to the extent requested by the plan sponsor, CFS shall also
provide participant education designed to assist participants in identifying the appropriate investment
strategy for their retirement plan accounts. The terms and conditions of the engagement shall generally be
set forth in the Advisory Agreement between CFS and the plan sponsor.
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by CFS as a
fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of
CFS’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Firm reasonably expects under the engagement.
CFS educates plan fiduciaries regarding their responsibilities in a position of trust. CFS provides general
fiduciary assistance including: a fiduciary assessment/self-audit of the Plan, providing formal training to
the Client and/or retirement plan committee, assistance in establishing a retirement plan committee,
assistance with development and maintenance of corporate and plan governance processes, and creation of
a fiduciary file.
As an ERISA 3(21) Investment Advisor, services are designed to allow the Sponsor to retain full
discretionary authority or control over assets of the Plan. We will solely be making recommendations to
the Sponsor. CFS will recommend investments to the plan sponsor, monitor the plan’s investments, suggest
replacements as appropriate, develop and monitor risk-based models comprised solely from the plan’s
investment menu, provide investment advice with respect to the selection of a Qualified Default Investment
Alternative (“QDIA”), and provide participant education. CFS will provide guidance to the plan sponsor in
meeting its fiduciary responsibilities, including development of an investment policy statement. The
Sponsor retains decision making authority and may accept or reject any recommendations.
As an ERISA 3(38) Investment Manager, services are designed to allow the plan fiduciary to delegate
responsibility for managing, acquiring and disposing of Plan assets that meet the requirements of the
Employee Retirement Income Security Act of 1974 (“ERISA”). If appointed as an ERISA 3(38) Investment
Manager, CFS would have full discretionary authority to select, monitor, and remove the investment options
offered in a qualified retirement plan.
In either case, whether we are engaged as a 3(21) Investment Advisor or 3(38) Investment Manager, we
will perform investment services through our investment advisor representatives (“IARs”), and will charge
a fee for services rendered, as described in this Form ADV and the Agreement.
Estate Planning
CFS also offers Estate Planning services to its clients that consists of education on estate planning topics
and the collection of general information necessary to complete a new estate plan or review a current estate
plan. CFS also assists the client in gathering the required information needed to provide outside estate
planning firms so that an estate plan can be created or updated.
Any and all fees paid by the client for outside referred services will be paid to those service providers
directly. While CFS utilizes the services of Trust & Will and EncorEstate Plans, third-party estate planning
services for clients who have the need for estate planning review, creation or updates, clients are not
required to utilize any third-party products, services, or referrals that we may recommend and can select
the service provider of their choice. CFS does not guarantee specific results from client’s use of Trust &
Will or EncorEstate Plans for Estate Planning services.