A. Capital Investment Management, Inc. (“Registrant”) is a corporation formed on April 16,
1998 in the State of Missouri. The Registrant became registered as an Investment Adviser
Firm in June 1998. The Registrant is owned by David M. Garrison, Troy R. Schuster, and
Matthew T. Shull. Mr. Schuster is the Registrant’s President.
B. As discussed below, the Registrant offers to its clients (individuals, trusts, etc.) investment
advisory services, and, to the extent specifically requested by a client, financial planning
and related consulting services.
INVESTMENT ADVISORY SERVICES
The client can determine to engage the Registrant to provide discretionary or non-
discretionary investment advisory services on a
fee basis. The Registrant provides
investment advisory services through a number of programs as set forth below.
ASSET MANAGEMENT
Co-Advisory Services
WealthPort
Capital Investment Management (CIM) participates, under a co-advisory relationship with Cambridge
Investment Research Advisors, Inc. (CIRA), in fee-based services sponsored through CIRA’s WealthPort
Wrap Programs. The wrap fee programs charge an inclusive fee, covering custodial, brokerage, and investment
advisory services. WealthPort Wrap Programs encompass the Cambridge Asset Allocation Platform
(CAAP®) and Unified Managed Account. A full and complete description of each Program is provided
in the WealthPort Wrap Brochure. All investors participating in WealthPort Programs will be
provided with and should review the WealthPort Wrap Brochure prior to
investing.
https://www.joincambridge.com/content/dam/joincambridge/documents/wealthport_wrap
_brochure.pdf
CAAP®
The CAAP® program is a discretionary portfolio management solution offering access to
multiple individual portfolio strategists. Each strategist offers a unique approach to investing
and may offer multiple model portfolios. CIM IARs work with clients to identify an
appropriate strategist(s) and model portfolio(s) based on individual circumstances, investment
objectives, risk tolerance, and time horizon. Clients are provided an Investment Policy
Statement (IPS) which confirms the selected strategist(s) and model portfolio(s), as well as the
investment objective and time horizon.
The IAR will meet with the client at least annually to review personal circumstances and
investment objectives and confirm the appropriateness of the strategist(s) employed and model
portfolio(s) utilized. CAAP® strategists are not affiliated with CIM or CIRA.
Unified Managed Account
A Unified Managed Account (“UMA”) offers you the ability to select multiple CAAP® strategies
in one account. The UMA holds the investments recommended by each selected Strategist in a
separate sleeve. Utilizing the proposal generation tools, the CIM IAR customizes the asset
allocation models for you or alternatively, selects proposed asset allocations for types of
investments fitting your profile and investment goals. CIM IARs then further customizes your
portfolio by selecting the specific underlying investment strategies or investments in the portfolio
to meet your needs.
Cambridge Managed Account Platform (CMAP)
Through the Cambridge Managed Account Platform (“CMAP”) CIM IARs will be
responsible for determining investment recommendations and implementing transactions.
The CIM IAR 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 the CIM IAR. In order to
have trading authorization on your account(s) the CIM IAR must be granted limited power
of attorney over the account(s).
The Cambridge Managed Account Platform (CMAP) is a flexible, low cost, advisor
representative driven and controlled platform. CMAP allows rep-advisors to use a broad
array of investment products, including individual general securities, load funds at NAV,
no-load funds, bonds, etc.
Cambridge rep-advisors can choose between two clearing firms: National Financial
Services LLC (NFS), a Fidelity Investments® company, Pershing LLC, an affiliate of the
Bank of New York Mellon. Both are members of FINRA/SIPC.
FINANCIAL PLANNING AND CONSULTING SERVICES
Generally, there is no extra charge to the fee-based clients of CIM for planning services. In
addition, the Registrant’s representatives may implement securities transactions and/or
insurance products for the client and earn commissions in their individual capacities as
registered representatives of
Cambridge.
The Registrant’s representatives will gather information through interviews with the client
on pertinent topics that may include: current financial status, assets and investments,
current and future employment, future goals, attitudes toward risk, income needs, projected
rates of return, inflation assumptions, social security assumptions, pension projections,
inheritances, income distribution projections, dependent needs, estate topics, long term
care planning, insurance planning, etc. Written plans may include any or all these topic
areas. (See Written Retirement Plans)
Written Retirement Plans
Clients contracting for written retirement plans will receive a written plan prepared by the
Registrant’s representatives. Retirement planning can include, but is not limited to, the
following areas:
• Retirement Planning and Projections
• Retirement Feasibility Reports
• Retirement Income Distribution
• IRC Rule 72t Calculations
• Investment Portfolio Analysis
• Life Insurance Needs
• Long Term Care Needs
• Educational Planning
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a
Financial Planning Agreement with Registrant setting
forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the portion of the fee that is due from the client
prior to Registrant commencing services. If requested by the client, Registrant may
recommend the services of other professionals for implementation purposes, including
the Registrant’s representatives in their individual capacities as registered representatives
of a broker-dealer and/or licensed insurance agents. (See disclosure at Item 10.C.1 to
10.C.2 ). 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 the Registrant. Please Note: If the
client engages any such recommended professional, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against
the
engaged professional. Please Also Note: It remains the client’s responsibility to promptly
notify the Registrant if there is ever any change in his/her/its financial situation or
investment objectives for the purpose of reviewing/evaluating/revising Registrant’s
previous recommendations and/or services.
MISCELLANEOUS
Non-Investment Consulting/Implementation Services. To the extent requested by the
client, the Registrant may provide consulting services regarding non-investment related
matters, such as estate planning, eldercare planning, tax planning, insurance, etc. Neither
the Registrant, nor any of its representatives, serves as an attorney or accountant, and no
portion of the Registrant’s services should be construed as same. To the extent requested
by a client, the Registrant may recommend the services of other professionals for certain
non-investment implementation purposes (i.e. attorneys, accountants, insurance agents,
etc.), including representatives of the Registrant in their separate registered/licensed
capacities as discussed below. 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 the
Registrant. Please Note: If the client engages any such recommended professional, and a
dispute arises thereafter relative to such engagement, the client agrees to seek recourse
exclusively from and against the engaged professional. Please Also Note: It remains the
client’s responsibility to promptly notify the Registrant if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
• For households above $500,000 in AUM, the annualized advisor's fee include's tax planning and
preparation in conjunction with Capital Tax and Consulting.Households above $1,000,000 in AUM
qualify for a Living Trust, Will(s) or Power of Attorney documents by the Trust and Will Center or an
approved Estate planning firm.
• No credit is due if client does not use these services.
Independent Managers. The Registrant may allocate (and/or recommend that the
client allocate) a portion of a client’s investment assets among unaffiliated
independent investment managers in accordance with the client’s designated
investment objective(s). In such situations, the Independent Manager[s] shall have
day-to-day responsibility for the active discretionary management of the allocated
assets. The Registrant shall continue to render investment advisory services to the
client relative to the ongoing monitoring and review of account performance, asset
allocation and client investment objectives. Factors which the Registrant shall consider
in recommending Independent Manager[s] include the client’s designated investment
objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research.
Please Note (Wrap/Managed Account programs). In the event that Registrant is engaged
to provide investment management services as part of a wrap program not sponsored by
the Registrant, Registrant will be unable to negotiate commissions and/or transaction costs.
Under a wrap program, the wrap program sponsor arranges for the investor participant to
receive investment advisory services, the execution of securities brokerage transactions,
custody and reporting services for a single specified fee. Participation in a wrap program
may cost the participant more or less than purchasing such services separately. In the event
that Registrant is engaged to provide investment management services as part of an
unaffiliated managed account program, Registrant will likewise be unable to negotiate
commissions and/or transaction costs. If the program is offered on a non-wrap basis, the
program sponsor will determine the broker-dealer though which transactions must be
affected, and the amount of transaction fees and/or through commissions to be charged
to the participant investor accounts.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains
his/her/its responsibility to promptly notify the Registrant if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
Written Acknowledgement of Fiduciary Status
When The Registrant provides investment advice to you regarding your retirement plan
account or individual retirement account, we are fiduciaries 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. The way we 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 this 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 our services; and
• Give you basic information about conflicts of interest.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. Registrant does not sponsor a wrap fee program for its investment advisory services.
However, Registrant is a participating investment adviser in certain unaffiliated wrap and
managed account fee programs. Please Note: When managing a client’s account on a
wrap fee basis, the Registrant shall receive as payment for its investment advisory
services, the balance of the wrap fee after all other costs incorporated into the wrap fee have
been deducted.
E. As of December 2023, the Registrant had $ 425,863,045 in assets under management on
a discretionary basis, and $ 0 in assets under management on a non- discretionary basis.