Cambridge Investment Research Advisors, Inc. (also referred to as “CIRA”, us, we, our and “Adviser” throughout this
Disclosure Brochure) is a corporation formed under the laws of the State of Iowa. CIRA is approved to conduct business in
all fifty states and has office locations in the majority of states. CIRA is majority owned and controlled by Cambridge
Investment Group, Inc., which in turn is majority owned by the Schwartz Family Trust.
Introduction
Individuals licensed or approved as Investment Advisor Representatives (referred to as “Financial Professionals” throughout
this document) with CIRA will provide its investment advisory services. These individuals are appropriately licensed when
required, qualified, and authorized to provide advisory services on behalf of CIRA. Some Financial Professionals are also
licensed as Registered Representatives of CIRA’s affiliated broker-dealer, Cambridge Investment Research, Inc. We will refer
to our affiliated broker-dealer as Cambridge throughout this Disclosure Brochure. Cambridge is a registered broker -dealer,
member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investors Protection Corporation
(“SIPC”).
CIRA has been registered as an Investment Adviser since February 2005. Prior to that date, Cambridge was dually registered
as a broker-dealer and Investment Adviser. At that time our advisory services were conducted under Cambridge in its
former capacity as an Investment Adviser. Cambridge was registered as an Investment Adviser from March 1996 through
March 2005. CIRA is a fiduciary for the purposes of the Investment Advisers Act of 1940.
Financial Professionals are not employees of CIRA or Cambridge. They are independent contractors of CIRA.
Financial Professionals are restricted to providing services and charging fees in accordance with the descriptions detailed in
this document. However, the exact services you will receive and the fees you will be charged are dependent upon your
Financial Professional. Fees can also vary depending on the geographic location of our clients and/or Financial
Professionals. Financial Professionals are instructed to consider the individual needs of each client when recommending an
advisory platform.
Financial Professionals and CIRA branch offices may use marketing names or other names that are held out to the public.
Such names are known as “doing business as” names. The purpose of using a name other than CIRA or Cambridge is for the
Financial Professional to create a brand that is specific to the Financial Professional and/or branch, but separate from CIRA
and Cambridge. While CIRA allows its Financial Professionals to use a name other than CIRA or Cambridge, the Financial
Professional must disclose on advertising and client correspondence that securities are offered through Cambridge and
advisory service are offered through CIRA.
General Description of Primary Advisory Services
The following are descriptions of the primary services that Financial Professionals are able to provide. A detailed description
of each service available through CIRA is provided in the corresponding sections of this brochure so that you can review the
services and description of fees in a side-by-side manner.
Financial Planning and Consulting
Our Financial Professionals may provide advisory services in the form of financial planning or consulting services. Financial
planning and/or consulting services do not involve the active management of client accounts. Financial planning can be
described as helping individuals determine and set their long-term financial goals through investments, tax planning, asset
allocation, risk management, retirement planning, and other areas. The role of a financial planner is to find ways to help the
client understand his/her overall financial situation and help the client set financial objectives.
Consulting services include consulting clients in the management of their money, investment options and asset reallocation.
Consulting services can be narrow in scope and not take into consideration all areas of a client’s financial situation.
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If you decide to sign up for financial planning or consulting services you will be required to execute the appropriate CIRA
agreement. Upon execution of the agreement, your Financial Professional will provide verbal or written recommendations,
depending on the investment advisory services selected and mutually agreed upon. Financial planning services will take into
consideration either individually or a combination of information such as your objectives, overall financial situation,
personal and financial goals, risk tolerance and objectives, risks that you are willing to undertake, investment knowledge,
net worth, income, age, projected retirement, unusual or material funding requirements, inheritance possibilities, pensions
social security, children/relative funding issues, estate issues, and living expenses expressed in today’s dollars requested for
retirement.
Based on the data and information compilation, financial planning recommendations are made based on your individual
needs. Topics included as part of financial planning services provided can include, but are not limited to, on e or more of the
following:
• Portfolio Review and Evaluation
• Retirement Account Analysis
• Cash Flow and Net Worth Analysis
• Risk Management Analysis
• Budgeting
• Planning for Family Member Special Needs
• Divorce Planning
• Developing a Comprehensive Documented Financial Plan
• Retirement Planning
• Education Funding Planning
• Review of Medical, Disability, and other insurance
• Estate Analysis and Planning
• Financial Planning and Education Seminars
Financial Professionals also provide financial planning services to business entities and groups requesting educational
services and financial planning seminars or individual consulting and planning services to be provided to employees or
members. If individual planning or consulting services will be provided, each participating employee or member will be
required to execute a separate agreement with CIRA depending on the services being provided.
Financial Professionals are allowed to provide financial planning seminars. Such services are provided on an impersonal
basis, which means topics covered are general in nature and do not purport to focus on the individual needs of the seminar
participants. Topics covered in a seminar can include the items listed above. Financial planning services do not include the
implementation of transactions on your behalf. To the extent you would like your Financial Professional to implement
transactions on your behalf, you will need to contract with your Financial Professional for one or more of the management
services described later in this section of the Disclosure Brochure or you can work with your Financial Professional in his/her
separate capacity as a Cambridge Registered Representative to establish a brokerage account and implement transactions
through a non-fee, commission-based brokerage account. If you choose to utilize any of these services a conflict of interest
will exist between those of CIRA, your Financial Professional and you. In addition to the fees charged for financial planning
services, your Financial Professional will earn commissions in his/her capacity as a Registered Representative or additional
advisory fees for managed accounts.
In addition to providing documented financial plans, Financial Professionals provide investment consulting services.
Consulting services are provided focusing on your specific areas of concern. These services can include retirement plan
consulting services provided to an individual client seeking advice on how their retirement plan investments should be
allocated.
Financial Professionals may also provide investment consulting services on accounts not managed or maintained by CIRA.
Only accounts for which a Financial Professional is not the Registered Representative of record or does not have trading
authorization on the account are eligible for this service. Such accounts include, but are not limited to, 401(k) accounts an d
pension plan accounts not held at CIRA or Cambridge. You will be responsible for all trade implementation under this
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service. Financial Professionals will not have access to your funds, securities, or account(s) and therefore will not have
authority to rebalance, reallocate or trade in the account(s).
If you decide to sign up for this service, your selected accounts will be reviewed based upon your specific needs and desires
for future financial goals and/or objectives. General or specific recommendations will be provided by your Financial
Professional. Fees can be paid in a variety of options determined between yourself and your Financial Professional. Please
see the Financial Planning and Consulting information within the Fees and Compensation section of this Disclosure
Brochure for additional fee information.
Financial Wellness
Firms can contract with a Financial Professional to provide financial wellness and services to its employees through
Financial Wellness Consulting. When working with the firm’s employees, Financial Professionals provide various services
such as assistance and education regarding budgeting and goal setting, financial wellness education presentations and
personal financial wellness assessments.
If you engage in Financial Wellness Services,
you will be required to execute the appropriate CIRA agreement. The exact
services provided are pre-determined by the employer and further documented and agreed to in the appropriate CIRA
agreement.
Upon execution of the agreement your Financial Professional will provide the services agreed upon in the agreement.
Employers contract a Financial Professional to provide individualized recommendations or non-individualized services to
employees. Services included in the individualized advice can include the following:
• Personal Financial Wellness Assessments
• Retirement Plan Participant Investment Advice
The non-individualized (education) services can include the following:
• Assistance and Education Regarding Budgeting, Goal Setting and Savings Tools.
• Financial Wellness Education Services
Investment Management Services
Financial Professionals can provide advisory services in the form of investment management services. Investment
management services involve providing clients with continuous and ongoing supervision over client account(s). This means
that Financial Professionals continuously monitor a client’s account(s) and make trades in the account(s) when necessary.
Investment management services are provided through one or more of the following platforms:
➢ Cambridge Managed Account Platform
➢ Flexible Managed Account Platform
➢ WealthPort Wrap Program
➢ CIRA Retirement Plan Strategies Management Platform
➢ Retirement Plan Advisory and Consulting Services
➢ Recommendation of Unaffiliated Third Party Investment Adviser
➢ Annuities
For all programs, account recommendations are ultimately determined based upon your risk tolerance, financial situation,
and stated investment objectives (i.e. preservation of capital, income, growth and income, growth and speculation, etc.). All
information gathered from you is confidential in accordance with Cambridge’s Privacy Policy located at
www.joincambridge.com. While CIRA does not set a specific timeframe for review, it does encourage Financial Professionals
to contact all of their clients at least annually, or at your (the client’s) request, to discuss your investment portfolio an d to
update your financial information should any changes have occurred. It is necessary for you to inform your Financial
Professional promptly with respect to any changes in your financial situation or investment goals and objectives. Failure to
notify CIRA of any such changes could result in investment recommendations not meeting your needs.
Your Financial Professional can provide investment advice to you regarding your retirement plan account or individual
retirement account (“IRA”). In doing so, your Financial Professional must act as a fiduciary within the meaning of Title I of
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the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. Fiduciary responsibility requires that Financial Professionals put your interests ahead of their own. In
acting in your best interest your Financial Professional will adhere to consumer protection standards that require that
compensation not be excessive based on the market value of the particular services, rights and benefits delivered to you.
Recommendations made by your Financial Professional regarding rollover options, from a retirement plan to another plan
or IRA, from an IRA to a plan, from an IRA to another IRA or from one account type to another (e.g., commission -based to
fee-based), will require your Financial Professional to document the reasons for the recommendation and specify why the
recommendation is in your best interest.
The way that your Financial Professional and Cambridge 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 thi s
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 services; and
• Give you basic information about conflicts of interest.
You should discuss with your Financial Professional the costs and benefits of each Investment management service and
then select the one that you believe best supports your investment goals and style and provides the most cost-effective
means of executing your investment strategy. More details regarding the brokerage options are available in the Brokerage
Practices section of this Disclosure Brochure.
➢ Cambridge Managed Account Platform
Financial Professionals provide investment management services defined as giving continuous investment advice to you
and making investments based on your individual needs through brokerage accounts established at Cambridge. Through
the Cambridge Managed Account Platform (“CMAP”) your Financial Professional will be responsible for determining
investment recommendations and implementing transactions. The Financial Professional shall manage your account(s) in
accordance with your individual needs, objectives and risk tolerance. These accounts are managed on either a discretionary
trading basis or non-discretionary trading basis as agreed to by you and your Financial Professional. In order to have trading
authorization on your account(s) your Financial Professional must be granted limited power of attorney over the account(s).
If you choose to establish an account with CIRA, your account(s) will be cleared and custodied at National Financial Services,
LLC (“NFS”) or Pershing, LLC (“Pershing”). The decision to use NFS or Pershing is made in conjunction with your Financial
Professional. More details regarding the brokerage options are available in the Brokerage Practices section of this
Disclosure Brochure. Generally, a Financial Professional will use one of the custodians and not the other. However,
depending on your needs, only one of the custodians could be a viable option. For example, one custodian can be
recommended when you need an individual 401(k) account because that custodian offers active management of 401(k)
accounts on a platform that is not currently available on the other custodian’s platform. Cambridge serves as the
introducing broker-dealer for all accounts through this investment management platform and clears securities transactions
on a fully disclosed basis through NFS and Pershing. Cambridge and CIRA have chosen to use NFS and Pershing as qualified
custodians based on past experiences, costs and other offerings or services that they provide to Cambridge. A conflict of
interest exists because other broker-dealers and custodians charge fees that could be more or less than using NFS or
Pershing through Cambridge and Cambridge receives compensation for the services it provides as an introducing broker
dealer. For more information regarding fees charged and compensation received, please refer to the Fees and
Compensation section of this Brochure.
Various investment strategies are provided through this service. However, a specific investment strategy is determined to
focus on your specific goals and objectives. Investment strategies and philosophies used vary based on the Financial
Professional providing advice.
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Models and strategies used by one Financial Professional are different than strategies used by other Financial Professionals.
Some Financial Professionals limit their advice to mutual funds while others will provide advice on a full range of securities
that include but are not limited to equities, mutual funds, options, fixed income and alternative investments. Some
Financial Professionals develop models or strategies that are generally applied across their clients while other Financial
Professionals will develop truly individualized portfolios for each client.
➢ Flexible Managed Account Platform
Financial Professionals provide investment management services defined as giving continuous investment advice to you
and making investments based on your individual needs through accounts established at an institutional RIA. Through the
Flexible Managed Account Platform (“FlexMAP”) your Financial Professional will be responsible for determining investment
recommendations and implementing transactions. The Financial Professional shall manage your account(s) in accordance
with your individual needs, objectives and risk tolerance. These accounts are managed on either a discretionary trading
basis or a non-discretionary trading basis as agreed to by you and your Financial Professional. In order to have trading
authorization on your account(s) your Financial Professional must be granted limited power of attorney over the account(s).
CIRA has a number of approved custodians. While there are others, the most commonly used are Schwab Advisor Services,
TD Ameritrade Institutional, Fidelity Brokerage Services LLC and Pershing Advisor Solutions. CIRA is independently owned
and operated and not affiliated with any of these companies. Generally, a Financial Professional will not use every platform
and in most cases will only recommend the use of one. More details regarding the brokerage options are available in the