A. Description of the Advisory Firm
The Colony Group, LLC (“Colony”) is a limited liability company organized in Delaware. Colony is an investment
advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Colony is a successor to
The Colony Group, LLC, a limited liability company organized in Massachusetts (SEC # 801-27451) (“Old Colony”), and
The Colony Group of Naples, LLC, a limited liability company organized in Delaware (SEC # 801-67456) (“TCGN”).
Effective October 1, 2011, clients of Old Colony and TCGN assigned their advisory agreements to Colony. Old Colony
and TCGN had been providing investment advisory services since 1986 and 2007, respectively.
Colony merged with InterOcean Capital Group, LLC (SEC # 801-119431) (“IOC”) on May 1, 2024.
Colony merged with GW & Wade, LLC (SEC # 801-27292) (“GWW”) on March 1, 2024.
Colony merged with Cooper Lapman Financial, LLC (SEC # 801-79674) (“COLA”) on February 1, 2023.
Colony merged with Derby and Company Inc. (SEC # 8014-30056) (“Derby”) on December 31, 2021.
Colony merged with Capital Advisors, LLC (SEC # 801-108032) (“Capital Advisors”) on December 1, 2021.
Colony merged with Legacy Wealth Partners, Inc. (SEC # 801-108370) (“Legacy”) on September 1, 2021.
Colony merged with New Providence Asset Management L.P. (SEC # 801-65426) (“NPAM”) on August 1, 2021.
Colony merged with Harvest Capital Management Inc. (SEC # 801-50107) (“Harvest”) on October 1, 2019.
Colony merged with Steinberg Global Asset Management LTD (SEC # 801-41473) (“Steinberg”) on May 1, 2019.
Colony merged with Aurora Financial Advisors, LLC (SEC # 801-100394) (“AFA”) on February 1, 2019.
Colony merged with Blue Water Advisors, LLC (SEC # 801-80172) (“BWA”) on January 1, 2018.
Colony merged with Bridgewater Wealth & Fin. Mgmt., LLC (SEC # 801-71137) (“Bridgewater”) on January 1, 2018.
Colony merged with Jones Barclay Boston & Company (SEC # 801-46608) (“JBB”) on January 1, 2017.
Colony merged with CapGroup Advisors, LLC (SEC # 801-66418) (“CapGroup”) on March 1, 2015.
Colony merged with Prosper Advisors, LLC (SEC # 801-64486) (“Prosper”) on October 1, 2013.
Colony merged with Mintz Levin Financial Advisors, LLC (SEC # 801-55976) (“MLFA”) on July 1, 2012.
On November 1, 2021, Colony acquired Harrison McCarthy & Co. (“Harrison”), a tax services practice based
in Millburn, New Jersey. Tax services out of this office will complement Colony’s long-standing tax services to its
clients.
Focus Financial Partners
Colony is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Colony is a wholly-owned
indirect subsidiary of Focus LLC. Ferdinand FFP Acquisition, LLC is the sole managing member of Focus LLC. Ultimate
governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus
LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC
(“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC.
Because Colony is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are
indirect owners of Colony.
Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms,
business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit
consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners
also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective
Form ADVs.
Colony’s day-to-day operations are managed and overseen by its Executive Committee. The Executive Committee
provides operational oversight and execution. It also drives the overall design and implementation of Colony’s strategic
priorities.
As noted above, we are stating here, with clarity and in plain English, what it means to be a fiduciary to you.
As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by federal
and state securities laws. As a result, you have certain rights that cannot be waived or limited by contract. Nothing
in our agreement with you should be interpreted as a limitation of our obligations under federal and state securities
laws or as a waiver of any unwaivable rights you possess.
As noted above, as applicable, we amended the liability term of client advisory agreements with the following:
Adviser Liability
The federal and state securities laws impose liability under certain circumstances on investment advisers even when
acting in good faith, and nothing in this Agreement shall waive or limit any rights that you may have under those
laws. Except as otherwise provided by law, neither we nor any of our employees, affiliates, representatives or agents
shall be liable for: (a) any investment loss that you may suffer by reason of any investment decision made or not made
or any other action taken or omitted in good faith by us with that degree of care, skill, prudence, and diligence that a
person acting in a fiduciary capacity would use under the circumstances; (b) any loss arising from our adherence to
your written and/or oral instructions; (c) any act or failure to act by the Custodian, any broker-dealer to which we
direct transactions for the Account, or by any other non-party to this Agreement; and/or (d) any loss that you may
suffer by reason of any decision made or other action taken by any manager by which the Adviser delegates authority
in accordance with Section [X] hereof. The exculpation provisions set forth in this Section [X} shall survive any
termination of this Agreement.
B. Advisory and Other Services
Colony offers a suite of wealth advisory services to individuals, families, institutions, and businesses. These services
include investment management, financial counseling, and family office services. In addition, Colony provides
investment consulting services for certain clients on accounts and assets that Colony does not manage. Colony also
offers tax compliance, business management, dispute resolution, and financial management services. Colony also
offers sub-advisory and business services to other advisory firms. Colony also offers, through third parties, concierge
and cash management services. Colony acknowledges that it is held to a fiduciary standard of care in the delivery and
performance of its advisory and other services.
Investment Management Services
Colony calls its approach to investment management “enhanced open architecture.” In designing and implementing
customized strategies, Colony can manage, on a discretionary and/or nondiscretionary basis, or combination of both,
a broad range of investment strategies and vehicles.
• Equity (stock) and fixed income strategies
• Mutual fund and ETF strategies
• Private funds (LP structure funds)
• Alternative investments and strategies
• Third-party subadvisor/SAM (separate account manager) strategies
Colony provides investment advisory services to retirement plans under the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”), on either a discretionary or nondiscretionary basis, depending on the client.
Colony’s fiduciary services to ERISA Plans may include preparing an investment policy statement, screening and
selecting investment options for the plan, selecting a qualified default investment alternative, providing quarterly
investment reports, attending the investment committee meetings, and, if the services are discretionary, creating and
managing portfolios based on a range of varying target asset allocations. Colony’s non-fiduciary services to ERISA
Plans can include providing education regarding general investment principles and the investments options in the plan-
to-plan participants.
Colony is a fiduciary under ERISA with respect to investment management services and investment advice provided
to ERISA plans and ERISA plan participants. Colony is also a fiduciary under section 4975 of the Internal Revenue Code
of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to
individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Colony is subject to specific
duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction
rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the
fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a
“PTE”).
Colony serves as the investment manager of eight (8) private pooled investment vehicles (“Partnership(s)”).
Three of the Partnerships diversify their assets among a variety of asset classes. The diversified asset class funds are:
TCG Balanced Fund, L.P., a Delaware limited partnership established for tax exempt investors (“TCGBF”); TCG Onshore
Balanced Fund L.P., a Delaware limited partnership established for taxable investors (“TCGOBF”); and TCG Diversifying
Strategies Fund, L.P., a Delaware limited partnership (“TCGDSF”). One fund, International Opportunities Fund, L.P., a
Delaware limited partnership (“TCGIOF”), focuses on non-U.S. equities.
Two other Partnerships include: TCG Income Opportunity Partnership, L.P ( (“TCGIOP”); and the TCG Real Estate
Partners VII, LLC (“TCGREP”). TCGREP is closed to new investors but has a small amount of capital remaining to be
called from its limited partners. TCGIOP is composed of various classes, however, only TCGIOP Class A is currently
open for new investments. TCGIOP has made an investment that is managed by a family member of an advisory client.
This affiliation gives us an incentive to make or maintain the investment recommendation. We mitigate the conflict
by applying the same standards for making the investment as we do for all of our recommendations, and by disclosing
this conflict to you.
Two other Partnerships include TCG Private Equity 2022, L.P. (“TCGPE"), and TCG Private Credit 2024, L.P. (“TCGPC”)
Capital Integration Systems LLC (“CAIS”) sponsors both TCGPE and TCGPC and is the sole member of both TCG Private
Equity 2022 GP LLC and TCG Private Credit 2024 GP LLC (“CAIS GP”). CAIS GP serves as the general partner to both
TCGPE and TCGPC and has discretionary authority to manage their activities. Colony is responsible for the TCGPE’s
and TCGPC’s day-to-day portfolio management under the general supervision of CAIS GP.
Investment Consulting Services
Colony provides investment consulting services on a non-discretionary basis, which consist of reporting and review of
assets held outside of Colony’s management. Such services include the provision of consolidated reports and periodic
meetings with clients to discuss their financial objectives, asset allocation, portfolio performance, and liquidity needs,
among other things.
Financial Counseling Services
• Investment planning
• Retirement planning
• Tax planning
• Estate planning
• Cash flow planning
• Philanthropic planning
• Education planning
• Risk management
• Tax return preparation
Family Office Services
• Strategy: tax planning, wealth accumulation, estate and wealth transfer, lifestyle planning
• Investment: portfolio strategy, manager selection, aggregation & coordination
• Legacy: family education, business & financial advice, philanthropy, fiduciary services
• Governance: tax compliance, risk management, regulatory support, cash management & recordkeeping, bill
pay
Sub-Advisory and Related Services to other Advisory Firms
Colony may offer investment advisory services to other registered investment advisory firms and their clients. This
may include discretionary management and/or the provision of multiple asset class model portfolios that other advisors
may use in managing investment accounts for their clients. Colony provides sub-advisory services to advisors of ERISA
plans and acknowledges its fiduciary status under ERISA in such cases. Colony offers supplementary support services
to other advisors, including: administrative assistance as it relates to the advisor-custodian relationship; access to
portfolio accounting and reporting services; client questionnaires and investment policy statement templates; samples
of advisory agreement templates; assistance with accessing investment offerings generally available only to clients of
investment advisors; and collection and remittance of net fees to investment advisors.
Financial Solutions through UPTIQ Treasury & Credit Solutions, LLC, and Insurance solutions through Focus Risk Solutions,
LLC
We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions
through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see
Items 5 and 10 for a fuller discussion of these services and other important information.
Colony helps clients obtain certain insurance solutions from unaffiliated, third-party insurance brokers by introducing
clients to our affiliate, Focus Risk Solutions, LLC (“FRS”). Please see Items 5 and 10 for a fuller discussion of this service
and other important information.
Non-Advisory Services
Business Management
• Monthly updates & reporting
• QuickBooks set up
• Signatory authority set up
• Interested party set up
• Bill-pay and accounts receivable processing
• Budget and cash flow planning
• Tax compliance and planning
Dispute Resolution
• Accounting – preparation of balance sheets and income statements
• Forensic Accounting – analysis of financial activity reported by the parties
• Income and Asset Division – asset and income division scenarios
• Tax – assess taxation impacts associated with income and/or asset division
• Valuation – oversee the valuation of all assets
• Disposition or Reallocation of Assets – provide options for the orderly disposition or reallocation of assets
• Risk Assessment – to protect long-term settlement structures
• Financial Impact – provide long-term projections of the likely impacts of settlement options
Concierge
Colony offers a distinct set of non-advisory services designed to address the needs and aspirations of our clients. These
include health and wellness, cybersecurity, career development, and lifelong learning. Colony has selected and vetted
unaffiliated third-party providers that it believes are best suited to offer clients the quality and professionalism they
may need currently or at some time in the future. Where possible, Colony has arranged for the providers to offer
preferential services or pricing for our clients. Colony receives no compensation from the service providers and no
compensation from its clients that use the services of such providers.
C. Client-Tailored Advisory Services
Investment Management Services
Colony tailors its investment management services to the needs of its clients. Colony seeks to understand each client’s
goals, objectives, time horizon, risk tolerance, and tax position. The client and Colony then decide on an investment
plan that may include the utilization of Colony’s fixed-income, mutual fund, exchange-traded fund, and equity
strategies; alternative investments and other private offerings; third-party separate account managers; and supervision
of certain non-discretionary accounts and assets. With respect to accounts managed on a discretionary basis, a client
is free to impose reasonable restrictions with respect to the management of his/her accounts.
Financial Counseling Services
Each client’s needs are different, and Colony seeks to tailor its financial counseling services to the specific needs of
each client. Each financial counseling client is provided with a wealth advisor whose role is to facilitate the provision
of financial counseling services that are tailored to the client’s unique circumstances.
Family Office Services
Colony can help high net worth families manage their wealth across generations. It can guide a family through complex
technical and family issues. It can organize and choreograph the intricate elements of a family’s legacy by teaming with
the family’s other advisors to implement a wealth management strategy tailored to the family’s unique needs and
objectives. Through a dedicated team, a family can have the benefit of Colony’s full array of wealth management
services and access to many money managers and investment solutions.
D. Wrap Fee Programs
Colony does not participate in or sponsor wrap fee programs.
E. Regulatory Assets Under Management (RAUM)
Colony has the following regulatory assets under management:
Discretionary RAUM: $19,058,988,095
Non-Discretionary RAUM: $2,413,660,085
Total RAUM: $21,472,648,180
Date Calculated: 12/31/23