A. Corrado Advisors, LLC (“Corrado”) is a New York limited liability company formed on
September 30, 1997. Corrado became registered as an Investment Adviser firm on
November 15, 1999. Corrado is principally owned by Mark A. Corrado and Lisa Balsamo.
Mr. Corrado serves as Corrado’s Managing Member.
B. As discussed below, Corrado offers to its clients (individuals, business entities, trusts,
estates and charitable organizations, etc.) investment advisory services and, to the extent
specifically requested by a client, financial planning and related consulting services.
INVESTMENT ADVISORY SERVICES
The client can determine to engage Corrado to provide discretionary or non-discretionary
investment advisory services on a fee basis. To commence the investment advisory process,
an investment adviser representative will first ascertain each client’s investment objectives
and then allocate and/or recommend that the client allocate investment assets consistent
with the designated investment objectives. Once allocated, Corrado provides ongoing
monitoring and review of account performance and asset allocation as compared to client
investment objectives, and rebalances the account on a discretionary or non-discretionary
basis.
For individual retail (i.e., non-institutional) clients, Corrado’s annual investment advisory
fee shall generally (exceptions can occur-see below) include investment advisory services,
and, to the extent specifically requested by the client, financial planning and consulting
services. In the event that the client requires specialized planning and/or consultation
services (to be determined in the sole discretion of Corrado), Corrado may determine to
charge for such additional services, the dollar amount of which shall be set forth in a separate
written notice to the client.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
Corrado may be engaged to provide financial planning and/or consulting services
(including investment and non-investment related matters, including estate planning,
insurance planning, etc.) on a stand-alone separate fee basis. Corrado’s planning and
consulting fees are negotiable, but generally range from $100 to $400 on an hourly rate
basis, depending upon the level and scope of the service(s) required and the professional(s)
rendering the service(s). Prior to engaging Corrado to provide planning or consulting
services, clients are generally required to enter into a Financial Planning and Consulting
Agreement with Corrado 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 Corrado commencing services. If requested by
the client, Corrado may recommend the services of other professionals for investment or non-
investment implementation purposes, including certain of Corrado’s representatives in their
individual capacities as certified public accountants and/or licensed insurance agents,
and/or attorneys or through its affiliated entities as disclosed below at Item 10. (See
disclosure at Item 10.C). 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 Corrado.
MISCELLANEOUS
Investment Consulting. Corrado may, in its sole discretion, determine to provide non-
discretionary portfolio review consulting services on a stand-alone basis, including those
investment assets that are not part of the assets managed by Corrado (the “Excluded
Assets”). Should the client receive such services, the client acknowledges and understands
that with respect to the Excluded Assets, Corrado’s service is limited to periodic review of
information provided by the client and/or the account custodian, and does not include
investment advisory services described above. Accordingly, the client, and not Corrado,
shall be exclusively responsible for the investment performance of the Excluded Assets. In
the event the client desires that Corrado provide investment advisory services with respect
to the Excluded Assets, the client may engage Corrado to do so pursuant to the terms and
conditions of an Investment Advisory Agreement between Corrado and the client.
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, Corrado may provide
financial planning and related consulting services regarding non-investment related
matters, such as estate planning, tax planning, insurance, etc. Corrado does not serve as
an attorney, and no portion of its services should be construed as legal services.
Accordingly, Corrado does not prepare estate planning documents or tax returns. To the
extent requested by a client, Corrado may recommend the services of other professionals
for certain non-investment implementation purpose (i.e. attorneys, accountants, insurance
agents, etc.), including representatives of Corrado in their separate individual capacities as
certified public accountants and/or as licensed insurance agents and/or attorneys. 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 Corrado and/or its representatives. Please Note:
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s]
(i.e. attorney, accountant, insurance agent, etc.), and not Corrado, shall be responsible for
the quality and competency of the services provided. Please Also Note-Conflict of
Interest: The recommendation by a Corrado representative that a client purchase an
insurance commission product through a representative of Corrado, in their separate and
individual capacity as an insurance agent, presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend investment or insurance products
based on commissions to be received, rather than on a particular client’s need. The fees
charged and compensation derived from the sale of such insurance and/or securities products
is separate from, and in addition to, Corrado’s investment advisory fee. No client is under any
obligation to purchase any securities or insurance commission products through such a
representative. Clients are reminded that they may purchase insurance products
recommended by Corrado through other, non-affiliated broker-dealers and/or insurance
agents.
If a client determines to engage CFG CPA, LLP (“CFG CPA”), he/she does so per the
terms and conditions of a separate written agreement between CFG CPA and the client, to
which Corrado is not a party. There is no fee-sharing arrangement between CFG CPA and
Corrado. The recommendation by the Corrado that a client engage CFG CPA for tax
preparation and/or accounting-related services, presents a conflict of interest because
Corrado’s affiliate will derive additional compensation from such engagement. No client
or prospective client is obligated to engage CFG CPA. Clients are reminded that they can
engage other, non-affiliated, providers. Corrado will work with the tax professional of the
client’s choosing.
Retirement Plan Rollovers – No Obligation / Potential for Conflict of Interest.: A client
or prospective client leaving an employer has four options regarding an existing retirement
plan (and may engage in a combination of these options): (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age,
result in adverse tax consequences). If Corrado recommends that a client roll over their
retirement plan assets into an account to be managed by Corrado, such a recommendation
creates a conflict of interest if Corrado will earn a new (or increase its current) advisory fee
as a result of the rollover. If Corrado provides a recommendation as to whether a client
should engage in a rollover or not (whether it is from an employer’s plan or an existing
IRA), Corrado is acting as a fiduciary 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. No client is under any obligation to roll over
retirement plan assets to an account managed by Corrado. Corrado’s Chief
Compliance Officer, Bennett Weiner, remains available to address any questions that
a client or prospective client may have regarding any conflicts of interest presented
by such rollover recommendations.
Fee Differentials. As indicated in Item 5, Corrado charges an investment advisory fee that
is based upon a percentage of the market value of the assets placed under management
(negotiable up to a maximum of 1.5%). However, fees shall vary depending upon various
objective and subjective factors, including but not limited to: the representative assigned to
the account, the amount of assets to be invested, the complexity of the engagement, the
anticipated number of meetings and servicing needs, related accounts, future earning
capacity, anticipated future additional assets, and negotiations with the client. As a result,
similar clients could pay different fees, which will correspondingly impact a client’s net
account performance. Moreover, the services to be provided by Corrado to any particular
client could be available from other advisers at lower fees. All clients and prospective
clients should be guided accordingly.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, Corrado generally
recommends that Schwab serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab charge brokerage commissions,
transaction, and/or other type of fees for effecting certain types of securities transactions
(i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs
charged for fixed income transactions, etc.). The types of securities for which transaction
fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ
depending upon the broker-dealer/custodian. While certain custodians, including Schwab,
generally (with potential exceptions) do not currently charge fees on individual equity
transactions (including ETFs), others do. Please Note: there can be no assurance that
Schwab will not change its transaction fee pricing in the future. Please Also Note: Schwab
may also assess fees to clients who elect to receive trade confirmations and account
statements by regular mail rather than electronically. Tradeaways: When beneficial to the
client, individual fixed‐income and/or equity transactions may be effected through broker‐
dealers with whom Corrado and/or the client have entered into arrangements for prime
brokerage clearing services, including effecting certain client transactions through other
SEC registered and FINRA member broker‐dealers (in which event, the client generally
will incur both the transaction fee charged by the executing broker‐dealer and a “trade-
away” fee charged by Schwab). The above fees/charges are in addition to Corrado’s
investment advisory fee at Item 5 below. Corrado does not receive any portion of these
fees/charges.
Use of Mutual Funds and Exchange Traded Funds: While Corrado may recommend
allocating investment assets to mutual funds and Exchange Traded Funds that are not
available directly to the public, Corrado may also recommend that clients allocate
investment assets to publicly-available mutual funds and ETFs that the client could obtain
without engaging Corrado as an investment adviser.
However, if a client or prospective
client determines to allocate investment assets to publicly-available mutual funds and ETFs
without engaging Corrado as an investment adviser, the client or prospective client would
not receive the benefit of Corrado’s initial and ongoing investment advisory services with
respect to any assets placed in those funds. In addition to Corrado’s investment advisory
fee described below, and transaction and/or custodial fees discussed above, clients will also
incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at
the fund level (e.g. management fees and other fund expenses).
Cash Sweep Accounts Account custodians generally require that cash proceeds from
account transactions or cash deposits be swept into and/or initially maintained in the
custodian’s sweep account. The yield on the sweep account is generally lower than those
available in money market accounts. To help mitigate this issue, Corrado shall generally
purchase a higher yielding money market fund available on the custodian’s platform with
cash proceeds or deposits, unless Corrado reasonably anticipates that it will utilize the cash
proceeds during the subsequent 30-day period to purchase additional investments for the
client’s account. Exceptions and/or modifications can and will occur with respect to all or
a portion of the cash balances for various reasons, including, but not limited to, the amount
of dispersion between the sweep account and a money market fund, the size of the cash
balance, an indication from the client of an imminent need for such cash, or the client has
a demonstrated history of writing checks from the account.
Please Note: The above does not apply to the cash component maintained within Corrado’s
actively managed investment strategy (the cash balances for which shall generally remain
in the custodian designated cash sweep account), an indication from the client of a need for
access to such cash, assets allocated to an unaffiliated investment manager, and cash
balances maintained for fee billing purposes. Please Also Note: The client shall remain
exclusively responsible for yield dispersion/cash balance decisions and corresponding
transactions for cash balances maintained in any of Corrado’s unmanaged accounts. ANY
QUESTIONS: Corrado’s Chief Compliance Officer remains available to address any
questions that a client or prospective client may have regarding the above
Cybersecurity Risk. The information technology systems and networks that Corrado and
its third-party service providers use to provide services to Corrado’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional
or unintentional actions that could cause significant interruptions in Corrado’s operations
and result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information. Clients and Corrado are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Corrado has established its processes to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Corrado does not directly control the cybersecurity measures
and policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental
and other regulatory authorities, exchange and other financial market operators, or other
financial institutions.
Independent Managers. Corrado may allocate (and/or recommend that the client allocate)
a portion of a client’s investment assets among unaffiliated independent investment
managers (“Independent Manager(s)”) in accordance with the client’s designated
investment objective(s). In such situations, the Independent Manager(s) will have day-to-
day responsibility for the active discretionary management of the allocated assets. Corrado
will continue to render investment supervisory services to the client relative to the ongoing
monitoring and review of account performance, asset allocation and client investment
objectives. Corrado generally considers the following factors when recommending
Independent Manager(s): the client’s designated investment objective(s), management
style, performance, reputation, financial strength, reporting, pricing, and research. The
investment management fees charged by the designated Independent Manager(s) are
exclusive of, and in addition to, Corrado’s ongoing investment advisory fee, which will be
disclosed to the client before entering into the Independent Manager engagement and/or
subject to the terms and conditions of a separate agreement between the client and the
Independent Manager(s).Client Obligations. In performing its services, Corrado shall not
be required to verify any information received from the client or from the client’s other
professionals, and is expressly authorized to rely thereon. Moreover, each client is advised
that it remains their responsibility to promptly notify Corrado if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising Corrado’s previous recommendations and/or services.
Cash Positions. Corrado continues to treat cash as an asset class. As such, unless
determined to the contrary by Corrado, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Corrado’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated
market conditions/events will occur), Corrado may maintain cash positions for defensive
purposes. In addition, while assets are maintained in cash, such amounts could miss market
advances. Depending upon current yields, at any point in time, Corrado’s advisory fee
could exceed the interest paid by the client’s money market fund.
Portfolio Activity. Corrado has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Corrado will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including but not limited to investment performance, fund manager tenure,
style drift, account additions/withdrawals, the client’s financial circumstances, and changes
in the client’s investment objectives. Based upon these and other factors, there may be
extended periods of time when Corrado determines that changes to a client’s portfolio are
neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below
during periods of portfolio inactivity. There can be no assurance that investment decisions
made by Corrado will be profitable or equal any specific performance level(s).
Structured Notes. Corrado may purchase structured notes for client accounts. A structured
note is a financial instrument that combines two elements, a debt security and exposure to
an underlying asset or assets. It is essentially a note, carrying counter party risk of the
issuer. However, the return on the note is linked to the return of an underlying asset or
assets (such as the S&P 500 Index or commodities). It is this latter feature that makes
structured products unique, as the payout can be used to provide some degree of principal
protection, leveraged returns (but usually with some cap on the maximum return), and be
tailored to a specific market or economic view. Structured notes will generally be subject to
liquidity constraints, such that the sale thereof before maturity will be limited, and any sale
before the maturity date could result in a substantial loss. There can be no assurance that
the structured notes investment will be profitable, equal any historical performance
level(s), or prove successful. Please Note: If the issuer of the Structured Note defaults, the
entire value of the investment could be lost See additional disclosure at Item 8 below. In
the event that the client seeks to prohibit or limit the purchase of structured notes for
the client’s account, the client can do so, in writing, addressed to Corrado’s Chief
Compliance Officer.
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
Trustee Directed Plans. Corrado may be engaged to provide discretionary investment
advisory services to ERISA retirement plans, whereby Corrado shall manage Plan assets
consistent with the investment objective designated by the Plan trustees. In such
engagements, Corrado will serve as an investment fiduciary as that term is defined under
The Employee Retirement Income Security Act of 1974 (“ERISA”). Corrado will generally
provide services on an “assets under management” fee basis per the terms and conditions
of an Investment Advisory Agreement between the Plan and Corrado.
Participant Directed Retirement Plans. Corrado may also provide investment advisory
and consulting services to participant directed retirement plans per the terms and conditions
of a Retirement Plan Services Agreement between Corrado and the Plan. For such
engagements, Corrado shall assist the Plan sponsor with the selection of an investment
platform from which Plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by Corrado), and, to the
extent engaged to do so, may also provide corresponding education to assist the participants
with their decision making process.
Client Retirement Plan Assets. If requested to do so, Corrado shall provide investment
advisory services relative to 401(k) plan assets maintained by the client in conjunction with
the retirement plan established by the client’s employer. In such event, Corrado shall
allocate (or recommend that the client allocate) the retirement account assets among the
investment options available on the 401(k) platform. Corrado’s ability to provide such
services shall be limited to the allocation of the assets among the investment alternatives
available through the plan. Corrado will not receive any communications from the plan
sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Corrado
of any changes in investment alternatives, restrictions, etc. pertaining to the retirement
account. Unless expressly indicated by the Corrado to the contrary, in writing, the client’s
401(k) plan assets shall be included as assets under management for purposes of Corrado
calculating its advisory fee.
Disclosure Brochure. A copy of Corrado’s written Brochure as set forth on Part 2A of
Form ADV, along with its Form CRS (Relationship Summary) shall be provided to each
client prior to, or contemporaneously with, the execution of the applicable form of client
agreement.
Please Note: Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by Corrado) will be profitable or equal any specific performance level(s).
C. Corrado shall provide investment advisory services specific to the needs of each client.
Prior to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, Corrado shall allocate and/or
recommend that the client allocate investment assets consistent with the designated
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on Corrado’s services.
D. Corrado does not participate in a wrap fee program.
E. As of December 31, 2023, Corrado had $ 184,262,486 in assets under management on a
discretionary basis and $12,657,532 in assets under management on a non-discretionary
basis.