Absolute Capital Management (“Absolute Capital” or “Firm”) was founded in 2002 and is primarily
owned by Brenden Gebben. As of March 31, 2024, Absolute Capital had a total of $351,474,969 of
assets under management which include discretionary assets of $345,573,580 and non-discretionary
assets of $5,901,389. As a registered investment advisor subject to Section 206 of the Advisers Act,
Absolute Capital acts as a fiduciary related to the conduct of its investment management and advisory
services. As such Absolute Capital has an obligation to act in the best interest of its clients guided by the
core fiduciary duties of loyalty and care.
Absolute Capital provides investment management and account supervisory services primarily to
individual investors on a fee-only basis. Absolute Capital also serves as adviser to the Absolute Capital
Asset Allocator Fund, Absolute Capital Defender Fund and The Teberg Fund (collectively referred to as
the “Fund(s)”). The Funds are diversified series of Northern Lights Fund Trust III, a Delaware statutory
trust organized on December 5, 2011 (the "Trust"). The Trust is registered as an open-end management
investment company. The Teberg Fund utilizes a single manager (subadviser) to achieve the investment
objectives.
Absolute Capital offers various model portfolios (the “Programs”) that allocate and reposition your
account assets over time based on specific allocation strategies and defensive strategies. The Programs
offer a range of investment profiles to suit your investment objectives which include aggressive growth,
growth, core, conservative and income as well as faith-based portfolios as described below. Within each
Program, depending upon the program and custodian chosen, client assets are invested in open-end
mutual funds, exchange traded funds (“ETFs”), bonds, equities, ETNs or other securities or sub-account
investment options available through an individual variable annuity provider. Not all Programs are
available at all custodians. Additionally, Absolute Capital sponsors wrap fee programs which are
described in Appendix 1 of this Brochure (the “Wrap Fee Brochure”).
As an individual client, in most cases you will be introduced to our services through your financial
representative who will work with you to provide continuous investment advice and to determine which
of our Programs are most appropriate given your financial situation, investment objectives, risk
tolerance and the investment alternatives available to you through a custodial relationship. This data
gathering process is completed by you and your financial representative and should be used to make the
decision whether to invest assets in any Absolute Capital Program. You can also contact Absolute
Capital. When and if your relationship with a particular financial representative ceases to exist, either a
new financial representative is assigned to your account or Absolute Capital assumes oversight
responsibility for your account, including for the services described above. In this case, you will be
periodically contacted by Absolute Capital regarding the status of your account. This assignment does
not result in a reduction or change to the advisory fees charged on your account(s).
Clients that are introduced to Absolute Capital by Cambridge Investment Research Advisors, Inc work
with Absolute Capital through their risk tolerance questionnaire to identify suitable Programs based on
your investment objectives and risk tolerance as reflected in the client questionnaire that is within the
Absolute Capital investment management agreement. Clients should contact Absolute Capital directly
should your financial situation change or if you have any questions.
Once you make your Program selection, you will enter into an Investment Management Agreement
(“Agreement”) with Absolute Capital. This Agreement will tell us which Program(s) you are selecting
and authorize us with discretionary authority to allocate your account into the investment options
available at your custodian that are consistent with the Program(s) you have selected and to continue to
make reallocations according to the Program strategy over time. You have the authority to impose
reasonable restrictions on Absolute Capital’s management of your accounts. The custodian holding your
assets will determine your authority to arrange to hold non-managed securities in your account.
Our investment management services begin on the date that your account is accepted and allocated into
the money management Program(s) (Acceptance Date”). There are circumstances where your
Agreement will be pending for a period of time due to account restrictions, anticipation of an upcoming
strategy change or other operational issues. Absolute Capital is not responsible for performance in your
account prior to the Acceptance Date. You will receive a letter from us that indicates the date on which
our investment management services have started. This letter is your notice that such services have
begun. Until you receive this notice, you should not assume investment management services have
begun. You or your financial representative can contact us at any time to inquire about the status of your
account.
Periodically, Absolute Capital will accept a letter of instruction from a client requesting all or some of
their assets be invested in specific securities in lieu of those assets being invested in a Program. Upon
acceptance of such instruction, the client will be required to submit another letter of instruction to
reinvest those assets into one of our Programs. Additionally, these assets can incur the same investment
management fee as the assets invested in a Program as outlined in Item 5 – Fees and Compensation.
Model Provider Services
In addition, Absolute Capital has entered into separate agreements with unaffiliated broker-dealers,
registered investment advisers and/or investment advisers
(the “Platform Sponsors”) enabling them to
offer some of our Programs to their clients (“Platform Clients”) via their product platforms. Absolute
Capital may enter into additional separate agreements with Platform Sponsors at their discretion.
Pursuant to the terms of our agreements with the Platform Sponsors, Absolute Capital reviews the
Programs and performs transactions and/or re-allocations of Platform Client assets within the Programs.
No personalized investment advice is provided by Absolute Capital to the Platform Sponsors or any
Platform Client participating in the Programs. If a Platform Client chooses to invest in one of our
Programs through the Platform, Absolute Capital will receive a fee directly from the Platform Sponsors.
The terms of any such fee arrangement are governed by the contract between the Platform Sponsor and
Absolute Capital and differ from the fee schedules shown in Section 5 of this document.
Co-Adviser
Absolute Capital provides services as a co-advisor with an unaffiliated third-party investment adviser in
which clients enter into a Co-Adviser agreement with the unaffiliated third-party co-advisor. Your
Financial Professional will assist you in selecting a suitable asset allocation strategy that will be used by
Absolute Capital to properly allocate your assets in the respective strategy. Your Financial Professional
will provide education concerning the asset allocation strategy selected. Financial Professionals are
available to answer questions you may have regarding your account and act as your relationship
manager between you and the third-party adviser. Your Financial Professional should periodically
communicate with you to review changes in your investment objectives and risk tolerance, and current
asset allocations within each portfolio. Clients are provided the opportunity to place reasonable
restrictions on their account. You may also contact Absolute Capital to review your investment
objectives, risk tolerance and your account.
Retirement Plan/Plan Participant Services
Absolute Capital currently exercises investment discretion when providing investment management
services to individual clients within their Individual Retirement Accounts such as an IRA or Roth IRA.
Absolute Capital also provides investment advice to clients in participant directed retirement plan
accounts and therefore is a “fiduciary” as defined under section 3(21)(A)(ii) of ERISA for these
accounts. Individual Retirement Accounts and participant directed accounts are referred to herein as
“Retirement Plan Assets” unless otherwise stated.
Absolute Capital invests clients’ Retirement Plan Assets in one or more Programs (described in Item 8
below) based on the recommendations of you or your financial representative and the instructions
received from you. Your financial representative provides recommendations to you regarding one or
more of the following matters: (i) the purchase, sale, exchange or holding of Program investments; (ii)
rollovers, distributions, or transfers; (iii) selection of Program(s) in which your Retirement Plan Assets
are invested; and (iv) the procurement of advisory services through third party investment advisers
including Absolute Capital.
A financial representative can recommend a client to engage Absolute Capital to manage all or a portion
of their participant directed retirement plan account through their employer’s retirement plan via a
custodial interface, custodial API or brokerage account option that provides Absolute Capital the ability
to allocate the client’s assets among the available core menu plan options and where available a self-
directed brokerage account option. Not all Plans enable this type of self-directed brokerage window or
custodial access feature and/or allow advisor access to a plan participants’ Retirement Plan Assets and
not all Program options are available at each custodian.
Finally, as noted above, your financial representative can recommend that you rollover your Retirement
Plan Assets into an IRA or Roth IRA account that is managed by Absolute Capital via one of its
Programs. You should review and consider the advantages and disadvantages of an IRA rollover
including fees and expenses, available investment options, management and/or advisory services to be
provided, availability of penalty-free withdrawals, protection from creditors and legal judgments,
required minimum distributions, and the ability to transact in employer stock. Absolute Capital
encourages you to discuss the available options and review the above-listed considerations with your
financial representative or with Absolute Capital.
By recommending that you rollover Retirement Plan Assets to an IRA, even if there are no costs
associated with the IRA rollover itself, Absolute Capital and the financial representative will be entitled
to earn an asset-based fee for the management of your IRA account. Therefore, your financial
representative has an incentive to encourage you to rollover Retirement Plan Assets into a managed IRA
account. Additional resources about IRA Rollovers are available to investors through FINRA’s web site
at
www.finra.org.
Absolute Capital Asset Allocator Fund and Absolute Capital Defender Fund
Absolute Capital has sponsored the creation of and serves as adviser to the Absolute Capital Asset
Allocator Fund and the Absolute Capital Defender Fund. Absolute Capital is responsible for selecting
each Fund’s investments according to that Fund’s investment objectives, policies and restrictions as
outlined in the Funds’ prospectus.
The Teberg Fund
Absolute Capital has delegated investment management of The Teberg Fund to a subadviser . Therefore,
the subadviser is responsible for selecting the Fund’s investments according to The Teberg Fund’s
investment objectives, policies and restrictions as outlined in its prospectus.