Ownership
Monument Capital Management (“we”, “our”, the “Firm”) is an investment advisor registered with the
Securities and Exchange Commission since June 2012. We are a limited liability company formed under
the laws of the state of Delaware. David Armstrong and Dean Catino are the principal owners of the firm.
General Description of Primary Advisory Services
The following are brief descriptions of Monument Capital Management’s primary services. A detailed
description of our services is provided in Item 5 – Fees and Compensation so that clients and prospective
clients (“clients” or “you”) can review the description of services and description of fees in a side-by-side
manner. We offer several investment programs designed to help our clients meet their specific goals and
investment objectives, descriptions of each program can be found in Item 5 – Fees and Compensation,
below.
Monument Capital Management Asset Management Services. We offer asset management services that
involve providing you with continuous and on-going supervision over your accounts. The Account is
managed by Monument Capital Management based on your financial situation, investment objectives and
risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting
or holding securities, cash or other investments of the Account and make trades in your accounts when
necessary.
When you engage Monument Capital Management, you appoint Monument Capital Management as your
investment advisor of record on specified accounts (collectively, the “Account”). The Account consists
only of separate account(s) held by qualified custodian(s) under your name. Qualified custodians maintain
physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g.,
right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction
confirmations) of the Account.
Financial Planning and Consulting Services. We offer financial planning services that can include
preparation of a financial plan covering specific or multiple topics. Monument Capital Management
provides financial plans typically addressing the following topics: investment planning, retirement
planning, insurance planning, tax planning, education planning, portfolio reviews, asset allocation, real
estate planning and estate planning. Under this program, the
role of your investment advisor
representative as a financial planner is to find ways to help you understand you
r overall financial situation
and help you set financ
ial objectives. Monument Capital Management also provides modular financial
plans which only cover those specific areas of concern mutually agreed between us. A modular
(segmented) financial plan is limited and does not involve the creation of a full financial plan. You should
be aware that other important issues may not be taken into consideration when your investment advisor
representative develops his analysis and recommendations under a modular financial plan. Financial
plans prepared by Monument Capital Management may include specific recommendations of individual
securities.
Monument Capital Management also provides consultations in order to discuss financial planning issues
when you do not need a full financial plan. Monument Capital Management offers a one-time
consultation, which covers mutually agreed upon areas of concern related to investments or financial
planning. Monument Capital Management also offers “as-needed” consultations which are limited to
Monument Wealth Management 5 Disclosure Brochure
consultations with us in response to a particular investment or financial planning issue raised or a request
made by you. Under an “as-needed” consultation, you identify those particular issues needing our advice
or consultation.
To begin the process for either a full or modular (segmented) plan, our representatives meet with you to
gather information and documentation needed to perform an analysis and review of your situation as well
your objectives and goals. One or more meetings may be required in order to gather all needed
information and determine the services best suited to help meet your needs. We rely on the information
provided by you. Therefore, it is very important that the information you provide is complete and
accurate. We are not responsible for verifying the information you supply. Our services do not include
legal or tax advice. You are urged to work closely with your attorney, accountant or other professionals
regarding your financial and personal situation.
If requested by the client, Monument Capital Management may recommend the services of other
professionals for implementation purposes. 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 Monument Capital Management.
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 Monument Capital Management, shall be responsible for the quality and competency
of the services provided.
It remains the client’s responsibility to promptly notify Monument Capital Management if there is ever
any change in their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising our previous recommendations and/or services.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services.
As indicated above, to the extent requested by a client, Monument Capital Management may provide
financial planning and related consulting services regarding non-investment related matters, such as
estate planning, tax planning, insurance, etc. for a separate and additional fee per the terms and
conditions of a
Financial Planning and Consulting Agreement. Neither Monument Capital Management
nor its investment adviser representatives assist clients with the implementation of any financial plan,
unless they have agreed to do so in writing. Monument Capital Management does not monitor a client’s
financial plan, and it is the client’s responsibility to revisit the financial plan with Monument Capital
Management, if desired.
Monument Capital Management does not serve as an attorney or accountant, and no portion of our
services should be construed otherwise. Accordingly, Monument Capital Management does not prepare
estate planning documents or tax returns. To the extent requested by a client, we may recommend the
services of other professionals for certain non-investment implementation purpose (i.e., attorneys,
accountants, insurance, etc.). 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 Monument Capital Management and/or its
representatives.
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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 Monument Capital Management, shall be responsible for the quality and competency
of the services provided.
Unaffiliated Private Investment Funds. Monument Capital Management may recommend that certain
qualified clients consider an investment in unaffiliated private investment funds. Monument Capital
Management’s role relative to the private investment funds shall be limited to its initial and ongoing due
diligence and investment monitoring services. Clients are under absolutely no obligation to consider or
make an investment in a private investment fund(s).
Risks: Private investment funds generally involve various risk factors, including, but not limited to,
potential for complete loss of principal, liquidity constraints and lack of transparency, a complete
discussion of which is set forth in each fund’s offering documents, which will be provided to each client
for review and consideration. Unlike liquid investments that a client may own, private investment funds
do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for
investment in the fund, and acknowledges and accepts the various risk factors that are associated with
such an investment.
Valuation: If Monument Capital Management bills an investment advisory fee based upon the value of
private investment funds or otherwise references private investment funds owned by the client on any
supplemental account reports prepared by Monument Capital Management, the value for all private
investment funds owned by the client will reflect the most recent valuation provided by the fund
sponsor. The current value of any private investment fund could be significantly more or less than the
original purchase price or the price reflected in any supplemental account report.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer
typically 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 Monument Capital Management provides a recommendation
as to whether a client should engage in rollover or not, we are acting as an ERISA fiduciary by making such
a recommendation. Furthermore, should the rollover result in the client’s retirement plan assets
transitioning into an account to be managed by us, such a recommendation creates a conflict of interest.
If Monument Capital Management provides a recommendation as to whether a client should engage in a
rollover or not, Monument Capital Management 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 Monument Capital Management.
Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange traded funds are available
directly to the public. Therefore, a prospective client can obtain many of the funds that may be utilized by
Monument Capital Management independent of engaging Monument Capital Management as an
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investment advisor. However, if a prospective client determines to do so, he/she will not receive
Monument Capital Management’s initial and ongoing investment advisory services.
Independent Managers. Monument
Capital Management may 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. Monument Capital Management 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. Monument Capital Management 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, Monument Capital Management’s ongoing investment advisory fee,
subject to the terms and conditions of a separate agreement between the client and the Independent
Manager(s). Monument Capital Management’s advisory fee is set forth in the fee schedule at Item 5
below.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation
of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence
process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments:
Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in
which a company manages relationships with its employees, customers, and the communities in which
it operates); and Governance (i.e., company management considerations). The number of companies
that meet an acceptable ESG mandate can be limited when compared to those that do not and could
underperform broad market indices. Investors must accept these limitations, including potential for
underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are
limited when compared to those that do not maintain such a mandate. As with any type of investment
(including any investment and/or investment strategies recommended and/or undertaken by Monument
Capital Mangement), there can be no assurance that investment in ESG securities or funds will be
profitable or prove successful. Monument Capital Mangement does not maintain or advocate an ESG
investment strategy but will seek to employ ESG if directed by a client to do so. If implemented,
Monument Capital Mangement shall rely upon the assessments undertaken by the unaffiliated mutual
fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or
portfolio’s underlying company securities meet a socially responsible mandate.
eMoney Advisor Platform and Orion Advisor Services. Monument Capital Management may provide its
clients with access to online platforms hosted by “eMoney Advisor” (“eMoney”) and Orion Advisor
Services (“Orion”). The eMoney platform and Orion, through its use of Quovo, allow clients to view their
complete asset allocation, including those assets that Monument Capital Management does not manage
(the “Excluded Assets”). Monument Capital Management does not provide investment management,
monitoring, or implementation services for the Excluded Assets. Therefore, Monument Capital
Management shall not be responsible for the investment performance of the Excluded Assets. Rather, the
client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not
Monument Capital Management, shall be exclusively responsible for such investment performance. The
client may choose to engage Monument Capital Management to manage some or all of the Excluded
Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Monument
Capital Management and the client.
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Cash Positions. Monument Capital Management continues to treat cash as an asset class. As such, unless
determined to the contrary by Monument Capital Management, all cash positions (money markets, etc.)
shall continue to be included as part of assets under management for purposes of calculating Monument
Capital Management’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), Monument Capital Management 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, Monument Capital Management’s advisory fee could
exceed the interest paid by the client’s money market fund.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other
money market accounts. When this occurs, to help mitigate the corresponding yield
dispersion Monument Capital Mangement shall (usually within 30 days thereafter) generally (with
exceptions) purchase a higher yielding money market fund (or other type security) available on the
custodian’s platform, unless Monument Capital Mangement 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.
The above does not apply to the cash component maintained within a Monument Capital Mangement
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.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions and
corresponding transactions for cash balances maintained in any Monument Capital Mangement
unmanaged accounts.
Portfolio Activity. Monument Capital Management has a fiduciary duty to provide services consistent
with the client’s best interest. As part of its investment advisory services, Monument Capital Management
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, and/or a change in the client’s investment objective. Based upon these
factors, there may be extended periods of time when Monument Capital Management determines that
changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to
the fees described in Item 5 below during periods of account inactivity.
Cybersecurity Risk. The information technology systems and networks Monument Capital Management
and its third-party service providers use to provide services to our clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that
could cause significant interruptions in Monument Capital Management’s operations and result in the
unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and
Monument Capital Management are nonetheless subject to the risk of cybersecurity incidents that could
Monument Wealth Management 9 Disclosure Brochure
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 we have established our procedures to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially
considering Monument Capital Management 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.
Client Obligations. In performing its services, Monument Capital Management shall not be required to
verify any information received from the client or from the client’s other designated professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility
to promptly notify Monument Capital Management if there is ever any change in their financial situation
or investment objectives for the purpose of reviewing, evaluating or revising Monument Capital
Management’s previous recommendations and/or services.
Disclosure Statement. Copies of our written Brochure and Client Relationship Summary, as set forth on
Part 2A of Form ADV and Form CRS respectively, shall be provided to each client prior to, or
contemporaneously with, the execution of an Advisory or Financial Planning Agreement.
When providing asset management services, Monument Capital Management typically constructs each
client’s account holdings using ETFs, mutual funds and individual equities to build diversified portfolios.
We do not typically attempt to time the market but we may increase cash holdings modestly, as deemed
appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our
investment strategy to accommodate special situations such as low basis stock, stock options, legacy
holdings, inheritances, closely held businesses, collectibles or special tax situations. Please refer to Item
8, Methods of Analysis, Investment Strategies and Risk of Loss for more information.
Monument Capital Management’s services are provided based on the individual needs of each client. This
means, for example, that clients are given the ability to impose restrictions on the accounts we manage
for them, including specific investment selections and sectors. We work with each client on a one-on-one
basis through interviews and questionnaires to determine their investment objectives and suitability
information. However, we reserve the right to not enter into an investment advisor relationship with a
prospective client whose investment objectives may be considered incompatible with our investment
philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment
guidelines.
Client Assets Managed by Monument Capital Management
As of December 31, 2023, Monument Capital Management had $417,200,309 in assets under
management on a discretionary basis and $16,623,561 in assets under management on a non-
discretionary basis.
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