CSPIA is an SEC registered investment adviser and a limited liability company formed under the laws of, and headquartered
in, the state of Virginia. Registration does not imply a certain level of skill or training. The Firm is a wholly owned subsidiary
of CSPF. As of December 31, 2023, CSPIA had $4,764,298,985 in assets under management on a discretionary basis and
$2,213,037,139in assets under management on a non-discretionary basis.
CSPIA provides individualized non-discretionary and discretionary advisory services to various categories of institutional
and individual clients who wish to participate in financial planning, separately managed accounts (“SMA”), mutual funds,
closed-end funds, exchange-traded funds, annuities, fixed income, structured notes, and equities; or who want to invest
in private equity funds or other alternative investment vehicles.
All services described in this brochure begin with a consultation between you and a CSPIA Investment Adviser
Representative (“Financial Advisor”, “Advisor” or “FA”) to review your investment objectives, financial situation, and risk
tolerance. Depending on the investment program, you are asked to complete a Client Profile to document the results of
this assessment. After review of your profile, working with the FA, you will determine which program is appropriate for
your needs.
Your FA will provide advisory services that may include allocation of assets among different classes, portfolio
diversification, managing portfolio risk, portfolio monitoring evaluation, investment policy statement development,
manager search and recommendation, financial planning, and other general economic and financial topics. Your FA will
construct a portfolio of securities based on your individual needs, risk tolerance and investment objectives. Account
supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, etc.), and all
managed accounts will be maintained with an independent qualified custodian. Certain investment programs, whether
offered directly through CSPIA or through a Third-Party Platform, offer investment products or utilize Sub-Managers
affiliated with CSPIA.
Services Offered
CSPIA offers various services to clients through its advisory programs based on individual client needs including financial
planning, and recommendations for separately managed accounts (“SMA”), mutual funds, closed-end funds, exchange-
traded funds, annuities, fixed income, structured notes, equities, private equity funds, and other alternative investment
vehicles.
Other Types of Advisory Services
Wrap Fee Programs
Cary Street Partners FA Directed Wrap Program (“FA Directed Program”)
CSPIA is the sponsor of the Cary Street Partners FA Directed Wrap Program which provides investment management
services on a discretionary basis to each client. Our wrap fee program allows you to pay a single fee that covers advisory
services, trade execution, custody, and other standard brokerage and investment services. Each FA develops well-
diversified portfolios designed to match the client’s financial goals, needs, risk tolerance and financial situation. Your FA
will recommend that you establish account(s) at Wells Fargo, Charles Schwab, Fidelity, or another qualified custodian
offering this type of wrap program pricing. Ultimately, though, it is your decision to custody assets with one of these or
another qualified custodian of your choosing. CSPIA is independently owned and operated and not affiliated with Wells
Fargo, Charles Schwab, Fidelity, or any other qualified custodian.
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For certain FA Directed wrap fee programs custodied at Wells Fargo, the provisions of our FA Directed program are based
on and related to certain wrap fee programs offered by Wells Fargo Advisors (“WFA”). CSPIA has an agreement with WFA,
pursuant to which WFA provides advisory and/or other services with respect to certain wrap fee programs (“WFA
Programs”) which are related to the Cary Street Partners FA Directed Program. Although WFA provides certain services
to our FA Directed Program wrap clients where Wells Fargo is custodian, WFA’s policy is to have CSPIA and their other
correspondent firms maintain the role of Sponsor. In addition to this Cary Street Partners Wrap Fee Brochure, please
review the appropriate WFA Disclosure Brochure (Form ADV Part 2A Firm Brochure and Wrap Fee Brochure) for a
complete description of the services, fee schedules and account minimums for these wrap fee programs. Clients will
receive those WFA wrap fee program brochures directly from Wells Fargo.
The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing
the account, and the frequency or type of securities transactions executed in the account.
• For example, a wrap fee program is not suitable for all accounts, including, but not limited to, accounts holding
primarily, and for any substantial period of time, cash or cash equivalent investments, fixed income securities or
no-transaction-fee mutual funds, or any other type of security that can be traded without commissions or other
transaction fees.
• In order to evaluate whether a wrap (or bundled) fee arrangement is appropriate for you, you should compare
the agreed-upon Wrap Program Fee and any other costs associated with participating in our Wrap Fee Program
with the amounts that would be charged by other advisers, broker-dealers, and custodians for advisory fees,
brokerage and execution costs, and custodial services comparable to those provided under the Wrap Fee Program.
Cary Street Partners Asset Management LLC (“CSPAM”) Wrap Programs
CSPIA offers clients discretionary management services through its affiliate CSPAM, a registered investment adviser.
CSPAM provides investment strategy services and is the Portfolio Manager of various wrap fee programs, each sponsored
by various unaffiliated, third-party registered investment advisers. Please review the CSPAM Firm Brochure (Form ADV
Part 2A Firm Brochure) for a complete description of its services, fee schedules and account minimums regarding its wrap
fee programs.
CSPAM manages specific investment strategies in wrap fee programs for both non-discretionary Model and discretionary
Wrap Account programs sponsored by unaffiliated financial institutions similar to its management of the same strategies
implemented in its CSP Global portfolios for example. In both the Wrap Account/Model programs however, CSPAM
personnel primarily support the financial institution sponsoring the wrap program (“Sponsor”) and not the actual
underlying client. There are fundamental differences between a Wrap Account and Model program. In a traditional Wrap
Account program, a client selects the Sponsor. The Sponsor will work with the client to select an approved discretionary
investment adviser, like CSPAM, for a particular investment strategy.
From time to time, the Sponsor will communicate any specific client needs/requests to CSPAM, and CSPAM will evaluate
for reasonableness within the strategy. CSPAM relies on the Sponsor to gather the necessary information and assess the
suitability of its investment style to the individual needs and financial situation of a Wrap Account client. For Wrap
Accounts, CSPAM exercises
investment discretion and delivers buy/sell instructions to the Sponsor’s platform. The
Sponsor is responsible for execution of each transaction in the client accounts.
Under the Model programs, depending on the model, the Sponsor or its designated representative, sometimes referred
to as an “overlay manager,” exercises investment discretion and executes each client’s portfolio transactions based on
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the Sponsor’s own investment judgment. CSPAM does not tailor the model portfolio to the individual needs of any
program client. CSPAM does not evaluate suitability for clients in a Model program.
In both types of wrap programs, the Sponsor provides a bundle of services for a single fee. Typically, this bundle of services
includes the review and monitoring of selected investment advisers approved in the program, performance evaluation of
the advisers, execution of the client’s portfolio transactions, custodial services for the client’s assets, and payment of
CSPAM’s advisory fee and other fees that may be charged in the Sponsor’s program.
Fees and Compensation
Wrap Fee Programs
In most cases, the wrap fee program fees are negotiable. However, certain WFA wrap fee programs have household
minimums that cannot be waived or negotiated. Please review the appropriate WFA Firm and Wrap Fee Disclosure
Brochures (Form ADV Part 2A) for a complete description of the services, fee schedules and account minimums for WFA’s
wrap fee programs and any related FA Directed programs.
CSPIA has the option of setting up your account as Transactional-Based Pricing or Asset-Based Pricing with certain
custodians.
• Transactional-Based Pricing-- CSPIA pays the transaction cost for each executed trade in such wrap fee accounts.
As a result, we have a financial incentive to limit orders for wrap fee accounts because trades increase our
transaction costs. Therefore, an incentive exists to trade less frequently in a wrap fee program with this pricing
structure. We may charge clients higher advisory fees based on their trading activity, but you should be aware
that we have an incentive to limit our trading in your account because we are charged for executed trades.
• Asset-Based Pricing-- CSPIA pays a single asset-based fee in lieu of transaction-based commissions. The fees we
pay are assessed on certain assets in your account, including stocks, bonds, and certain mutual funds. If there is
limited or no trading activity in your account, we will receive more compensation from your participation in our
wrap fee program with this pricing structure than if you purchased our advisory services and custodian services
separately.
A wrap fee is not based directly on the number of transactions in your account. Various factors influence the relative cost
of our wrap fee program to you, including the cost of our investment advice, custody and brokerage services if you
purchased them separately, the types of investments held in your account, and the frequency, type and size of trades in
your account. The wrap fee program could cost you more or less than purchasing our investment advice and
custody/brokerage services separately.
Our wrap fee covers our advisory services and the brokerage services provided by your qualified custodian including
custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive
to execute transactions for your account with your qualified custodian.
Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include the following: charges
imposed directly by a mutual fund, index fund, or exchange-traded fund which shall be disclosed in the fund’s prospectus
(i.e., fund management fees and other fund expenses); mark-ups and mark-downs; spreads paid to market makers; fees
(such as a commission or markup) for trades executed away from your qualified custodian at another broker-dealer; wire
transfer fees; and other fees and taxes on brokerage accounts and securities transactions.
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When managing a client's account on a wrap fee basis, we receive as compensation for our investment advisory services,
the balance of the total wrap (or program) fee you pay after custodial, trading and other management costs (including
execution and transaction fees) have been deducted. Accordingly, we have a conflict of interest because we have a
financial incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred in your
account(s) subject to a wrap fee.
Other Advisory Services Fees and Revenue Sharing
Our advisory services do not impose performance-based fees. Fees are based on the value of the assets in your account,
and CSPIA shall not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or
any portion of the funds of client (i.e., performance-based fee). CSPIA may assess fee minimums and certain flat or fixed
fee pricing arrangements which sometimes exceed 2% of the total assets under management and are higher than fees
charged by certain other advisers that provide the same or similar services.
Revenue Sharing within Cash Sweep Programs (the "Sweep Programs"): Uninvested cash balances in your account –
for which no interest is otherwise earned or paid –are automatically swept into interest-bearing deposit accounts
("Bank Deposit Sweep") or, if available, money market mutual funds ("Money Market Funds") or such other sweep
arrangements made available to you (collectively "Cash Sweep Vehicles"). Such balances remain in these sweep
programs until they are invested by you or otherwise needed to satisfy obligations arising in connection with your
account.
CSPIA and our affiliates, in some cases, receive fees and benefits for services provided in connection with the Sweep
Program, and we generally choose to make available the Cash Sweep Vehicles that are more profitable to us than other
Money Market Funds or Bank Deposit Sweep accounts. A portion of these fees are paid to your FA.
Lending Services – Interest Charges and Revenue Sharing
For Wells Fargo products, a portion of the interest charged on the outstanding balances of margin loans or securities-
backed lines of credit (“SBLOC”) will be paid to CSPIA, and solely with respect to an SBLOC, to your FA. An interest rate
may be individually negotiated, instead of being based on the Wells Fargo Clearing Services (“WFCS”) base rate.
Negotiated rates may have an expiration date, after which CSPIA/CSP may change your rate, without giving you any
prior notice of the change, based on factors determined by CSPIA/CSP, in our sole discretion, including, without
limitation, the account activity and our overall business relationship.
For Goldman Sachs products, CSPIA and your Advisor have an incentive to recommend borrowing money on a client
account, which represents a conflict of interest. A portion of the interest charged on the outstanding balance of your
loan will be paid to CSPIA and to your Advisor.
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