Cetera Investment Management LLC (CIM) is a registered investment advisor that provides model portfolio services and
market commentary services to its related broker-dealers and registered investment advisors.
CIM is wholly owned by Cetera Financial Group, Inc. (Cetera Financial Group). Please refer to Item 10 of this brochure for
more information on our corporate structure and affiliates.
Our Advisory Activities
We are primarily engaged in the business of providing model portfolio services, strategist services, and market research.
Our services are available primarily to related registered investment advisers (Related RIAs) and broker-dealers (Related
BDs) (certain of our Related RIAs are also Related BDs), or investment advisers owned by representatives of related
broker-dealers (ORIAs).
Related RIA Programs
As described below, certain of our Related RIAs have developed and co-sponsor investment advisory programs on the My
Advice Architect Platform (MAA), and also sponsor investment advisory programs on the RIA Services Platform.
MAA Platform
Within MAA, the Unified and Guided Programs (the “MAA Programs”), among other investment program options, offers
Related RIA clients asset allocation model investments based on a particular investment strategy and philosophy of an
investment adviser (Strategist). We, as well as investment adviser firms not affiliated with or related to us, act as a Strategist
in the MAA Programs and provide the Programs with model portfolios of securities (Model Portfolios) consisting of select
mutual funds and/or exchange traded funds (ETFs). We do not receive any compensation for providing this service nor do
we act as an investment adviser to you. Our Related RIAs that co-sponsor the MAA Programs, and not us as Strategist,
make the investment decisions for client accounts regarding the selection of a particular Strategist and Model Portfolio in
the MAA Programs. Envestnet Asset Management, Inc. (Envestnet), an independent investment adviser, also acts as a co-
sponsor and investment adviser in the MAA Programs and has trading discretion in the MAA Programs.
RIA Services Platform
Within RIA Services, the Unified Managed Account Program and Advisor as Portfolio Manager Program (the “RIA Services
Programs”), among other investment program options, offers Related RIA clients asset allocation model investments based
on a particular investment strategy and philosophy of a Strategist. Like in MAA, we, as well as investment adviser firms not
affiliated with or related to us, act as a Strategist in the RIA Services Programs and provide these Programs with Model
Portfolios consisting of select mutual funds and/or ETFs. Like MAA, we do not receive any compensation for providing
this service to the RIA Services Programs, nor do we act as an investment adviser to you in the RIA Services Programs.
Our Related RIAs, and not us as Strategist, make the investment decisions for client accounts regarding the selection of a
particular Strategist and Model Portfolio in the RIA Services Programs.
As described further below, we provide the following different sets of Model Portfolios (collectively the “CIM Portfolios”): for
MAA and RIA Services Platforms, Tactical model portfolios of securities (Tactical Portfolios) and strategic model portfolios
of securities (Strategic Portfolios); for the Freedom Program, model portfolios of securities (Freedom Portfolios), for the
InvestPath Program, model portfolios of securities (InvestPath Portfolios); and for two investment management programs,
Legacy Advance and Trust Connection (together, Trust Programs), that offer tactical and strategic asset allocation model
portfolios of securities (described below). These Trust Programs are offered only by Cetera Trust Company, N.A., which is
related to CIM, as it is also a wholly-owned subsidiary of Cetera Financial Group.
Tactical Portfolios and Strategic Portfolios
Our strategies provide clients with the opportunity to participate in an asset allocation strategy using either a tactical model,
a strategic model, or a combination of tactical and strategic models. The Program Sponsor will recommend a CIM Portfolio
that is consistent with a client’s Asset Allocation Model, choosing from the applicable set of CIM Portfolios made available
by us for the Program. Each Portfolio has a broad equity/fixed income asset allocation based on risk tolerance level.
The Strategic and Tactical Model Portfolios are based on certain key principles. First, we believe that diversified portfolios
provide a prudent approach to achieving long-term investment goals. Second, we believe that many different investment
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strategies can be valuable if implemented in a consistent, disciplined manner. Finally, we believe that top quartile performance
over a complete market cycle is achievable by outperforming blended benchmarks by 2% per annum, although there is no
guarantee we will achieve our objective.
Strategic Asset Allocation
Strategic asset allocation is a portfolio strategy that involves the periodic rebalancing of the portfolio in order to maintain
a long-term goal of a chosen asset allocation mix. The initial investments are chosen based on expected returns and risk
tolerance. Because the value of the assets can change based on market conditions, the portfolio constantly needs to be
re-adjusted to meet the policy. This is often called rebalancing, and may be done at regular intervals. This strategy does
not purposely deviate from the original determined asset allocation percentages. The emphasis is on preserving this initial
chosen asset allocation mix because the mix ultimately relates to a larger performance objective based on historical data.
Tactical Asset Allocation
Tactical asset allocation is a portfolio strategy that involves the rebalancing of assets held in various categories in order to
take advantage of market pricing anomalies or strong market sectors, as chosen by the portfolio managers. This strategy
provides the opportunity to try and create extra value by taking advantage of these potential situations in the markets. It
is a moderately active strategy and may use short-term trading methods. This investment philosophy is usually based on
the belief that investor psychology and market forces can lead to periods of misevaluation. A tactical allocation process
attempts to capture these misevaluations. It is not a fixed asset weight mix and the allocation and risk level of the portfolio
may change quite dramatically.
Freedom Program
The Freedom program (Freedom) is a wrap fee program available for certain Advisors to offer and is discretionary which
means that our applicable Related RIA, Advisor, the Strategist, and/or a third-party overlay manager are able to make
allocation changes or trades without Client’s prior approval. Clients and their Advisor will initially
select one of the pre-
defined strategist portfolios for Client’s Freedom account which includes the Freedom Portfolios. Advisor must obtain
Client’s authorization to change Client’s risk profile or to elect another portfolio, including the Freedom Portfolios. Strategists,
including CIM, manage assets in a comprehensive perspective using mutual fund-based models and/or exchange-traded
product-based models.
CIM Portfolios
CIM does not receive any compensation for making available any of the CIM Portfolios. The CIM Portfolios include Strategic
Partner funds as discussed further below.
Conflict of Interest in Model Portfolios with Strategic Partner Funds
A conflict of interest exists in that our Related BDs are paid more revenue-sharing fees if you invest in a Model Portfolio,
like the CIM Portfolios, that includes Strategic Partner funds or more Strategic Partner funds than a Model Portfolio offered
by another or the same Strategist. Thus, we have a financial incentive to recommend the Model Portfolios over non-
affiliated Portfolios that do not include Strategic Partner funds or do not include as many Strategic Partner funds because
of the additional compensation our Related BD receives as the result of such investments in funds sponsored by our
Strategic Partners. Our Related RIAs mitigate this conflict of interest by supervising the suitability of the Model Portfolios
that are made available against each client’s goals and objectives. Additionally, Client’s Advisor does not receive any of the
additional compensation that our Related BD receives from our Strategic Partners. For a more detailed description of the
Related BDs Strategic Partner Program and a list of Strategic Partners as well as the conflicts of interest associated with
the Strategic Partner Program, please refer to Cetera Advisory Services ADV Part 2A.
Investment Fiduciary Manager Program
CIM provides investment advisory services to its Related RIAs that offer investment fiduciary advisory services to participant
directed employer-sponsored plans that are subject to Section 3(38) of ERISA (Plans) in a program entitled the Investment
Fiduciary Manager Program (Program). To support the Related RIA’s Program, CIM’s investment advisory services are
limited to creating recommended investment lineups for each record keeper platform that the Related RIA makes available
in the Program. The investment lineups developed and recommended by CIM are a subset of the available investments at
certain platforms of record keepers that are also strategic partners (Retirement Partners) in the Related RIA’s Retirement
Strategic Partner Program. Prior to recommending the investment lineups, which are composed primarily of Strategic
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Partner (as opposed to Retirement Partner) funds, CIM reviews the appropriate selection and monitoring criteria. In addition
to selecting and monitoring the investment lineups, CIM’s process may include the addition, removal, and/or replacement of
investment product(s) within a particular investment lineup, as needed. Under the Program, the Related RIAs, and not CIM,
provide investment advisory services to the Plans. The Related RIAs determine whether to adopt the investment lineups
recommended by CIM and the Plan grants the Related RIA the discretion to choose an investment lineup at a particular
record keeper for that Plan. For a more detailed description of a Related RIA’s Investment Fiduciary Manager Program,
please refer to the applicable Related RIA’s ADV Part 2A.
Information about Model Portfolio Services
We do not maintain custody of your accounts. The firms that engage us to provide services on their behalf enter into relationships
with qualified custodians. The majority of accounts that utilize our services result from our relationships with our Related RIAs
or Related BDs.
CIM is not an ERISA Fiduciary because it:
• Does not provide individualized models,
• Does not contract directly with clients for services,
• Does not execute trades in clients’ portfolio,
• Does not agree to assume fiduciary responsibility,
• Does not have control on whether its model is used in any specific client account, and
• Does not receive any fee or compensation directly from end clients who use the models.
We communicate with you primarily through your Advisor who registered with the Program Sponsor. We rely on that Advisor
to analyze your goals and needs when implementing any CIM service. The Advisor will collect suitability information and
ensure that the investment strategy chosen is appropriate for the client.
CIM Research Team & Reports
CIM provides market research that is made available only to the broker-dealers and registered investment advisers related
to Cetera Financial Group and their Advisors. These materials include detailed market information as well as investment
perspectives, asset allocation strategies, and investment ideas and recommendations. The research team provides Advisors
with specific recommendations of mutual funds and Exchange Traded Products (includes both ETFs and exchange traded
notes) through a “Research Select List” as well as certain other internal lists. The CIM Research Team supports Advisors
by giving them access to a large-scale body of research, including: (1) market perspectives, (2) economic insights, and (3)
asset allocation recommendations.
Managed Wealth ADVANTAGE®
CIM oversees the design and ongoing management of asset allocation models for the Managed Wealth ADVANTAGE (MWA)
wrap-fee program offered by the Related RIAs. CIM also independently selects and adds or removes the mutual funds and/
or exchange-traded funds that the Related RIAs will make available through MWA. CIM determines the investment allocation
targets for client accounts under the MWA program. CIM does not receive any compensation for providing services to the
MWA Program.
InvestPath Program
We provide support to the InvestPath Program, an asset allocation strategy sponsored and managed by a Related RIA,
Cetera Investment Advisers LLC (CIA), as described more fully in its Form ADV. This investment solution offered through
partner financial institutions, uses mutual funds and ETFs to establish the portfolio allocations. Our approach offers five
different risk tolerance-based models and within each model, provides a diversified portfolio with a strategic approach
to portfolio construction. CIM is responsible for determining asset allocation and model portfolio construction, selecting,
and monitoring the mutual funds and ETFs that are included in the InvestPath Program. CIA is ultimately responsible for
overseeing CIM’s performance.
Assets Under Management
As of December 31, 2019, CIM does not have assets under management or assets under advisement.
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