CSA was established in September 2013. CSA provides customized investment management, refers clients to third-party investment advisers (the “Manager”) in accordance with a Solicitor's Agreement in place with the respective Manager, and provides financial planning services. CSA is a wholly-owned subsidiary of Center Street Holdings, Inc. The parent holding company has another wholly owned subsidiary, Center Street Securities, Inc that is a broker-dealer. Center Street Holdings is owned by Arete Wealth, Inc. Some of CSA’s investment advisor representatives may be able to offer both investment advisor and brokerage service. Clients should speak to their CSA representative to understand the different types of services available through CSA and its associated companies. Types of Advisory Services Offered CSA offers:
•Investment management services
•Investment account management with third-party managers
•Retirement Plan Consulting Services
•Financial planning services The client is under no obligation to act upon the Advisor’s recommendation, if the client elects to act on any of the recommendations; the client is under no obligation to affect the transaction through in the investment advisor. CSA Investment Management Services CSA provides customized investment management services for its clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management services. CSA works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. CSA will then construct a portfolio, consisting of stocks, bonds, exchange traded funds (“ETFs”), mutual funds and other types of investments, as appropriate, to help achieve the Client’s investment goals. Morningstar® Managed PortfoliosSM CSA may offer clients the Morningstar Managed Portfolios program (“Program”). This Program is a discretionary investment advisory program offered by Morningstar Investment Services, Inc. (“MIS”), a federally registered investment advisor. The Program is available to clients through an arrangement MIS has with CSA. MIS will receive compensation for their investment advisory services provided under the Program as a percentage of assets. In addition, MIS will delegate certain services to CSA such as assisting each client in completing a questionnaire and other applicable account opening forms, determining suitability, meeting with the client at least annually to obtain any changes in their financial situation and acting as liaison between MIS and the CSA client. For these services, the CSA will receive a portion of the fee paid by each client participating in this Program. Minimum Account Size The minimum initial investments are as follows: Mutual Fund Strategies .........................................................................................................................$50,000 Individual 401(k) Account ....................................................................................................................$40,000 For each of the above: Minimum subsequent investment ....................................................................................................$500 Minimum subsequent investment–IRA Accounts .............................................................................$250 Select Stock Basket Custom Strategy ...................................................................................................$250,000 Select Stock Basket Strategist Strategy .................................................................................................$100,000 ETF Strategy .......................................................................................................................................$50,000 *At MIS’ sole discretion, an initial or subsequent investment of less than the above stated minimums may be allowed.
Pursuant to the discretionary authority granted within the Investment Management Agreement (signed prior to opening an account), MIS will execute transactions as frequently as MIS considers necessary.
Third-Party Asset Managers (“TPAMs”) Overlay Management and Sub-Advisory Relationships CSA may delegate the active discretionary management of all or part of a discretionary client’s assets in their managed account(s) to one or more independent TPAM based on the client’s stated investment objectives, guidelines, and restrictions. Access to TPAMs may be provided by CSA through a sub-advisory relationship between CSA and the TPAM, and/or through a direct TPAM contractual engagement with the client (CSA provides overlay management.) The TPAMs will have discretionary authority over those assets allocated to them for management and they will be authorized to buy, sell, and trade in securities in accordance with the client’s investment objectives. CSA’s fees could differ, if and when it allocates a client’s assets to one or more TPAMs and such client may be required to enter into a separate advisory agreement directly with the TPAM selected, which is in addition to the agreement entered into between the client and CSA. Once a TPAM is selected, CSA continues to monitor the chosen TPAM to ensure the TPAM adheres to the philosophy and investment style for which they were selected. In its sole discretion, CSA has the authority (pursuant to the investment management agreement between CSA and each client) to add, replace or change any TPAM on behalf of a client (to the extent that the client has not entered into a direct engagement agreement with the TPAM), without the client’s prior consent. Solicitor Referrals to TPAMs CSA may make referrals to TPAMs as a solicitor. Clients are required to enter into a discretionary agreement with the Manager. Clients should refer to each Manager’s Firm Brochure or other disclosure document for a full description of the services offered. CSA will receive a solicitor fee from each Manager, ranging between .5% and 2.5% of client assets under management. Solicitor fees are also based on the type of services offered by the Manager and the investment model chosen by the client. Clients may go directly to the Manager without having a contractual arrangement with CSA. Clients should refer to

Item 14, Client Referrals and Other Compensation, for additional information. Third-Party Money Managers Acting as Sub-Advisors CSA may engage other registered investment advisors to assist it with advisory services to its clients. In this case, CSA will enter into a sub-advisory agreement with these third-party money managers. Unlike the arrangement under the Solicitor’s Agreement, CSA will be acting as the Registered Investment Adviser and the Client will be paying the combined investment advisory fees to CSA. CSA will then use the payment of the combined fee to pay its sub-advisor. In some cases, for greater transparency, this combined fee may be separately itemized on Client’s statements. Advisors may offer Client access to the Virtu Platform. Virtu gives Client access to model portfolios of a wide variety of third-party investment managers as well as a portal through which to view and consolidate outside accounts, lending, and directly held investments. Virtu is administered by Axxcess Wealth Management, LLC (“Axxcess”), a Registered Investment Advisor with the SEC. Axxcess will act as a sub-advisor and fiduciary to Client, and will have discretionary authority over Client’s accounts. Axxcess charges fees for access to Virtu and for its sub- advisory services. Axxcess will arrange for delivery of disclosure documents for itself and the third-party managers on Virtu. Client should refer to these disclosure documents for a full description of the services offered and the fees charged by Axxcess and the applicable third-party managers. Arete, CSA’s parent company, and Axxcess have a revenue sharing arrangement whereby revenues generated from Virtu are shared between them. Accordingly, CSA and its Advisors have a financial incentive to direct Client to the third-party model portfolios available on Virtu rather than to strategies offered by other third-party managers. Fees charged for access to the third-party managed strategies on Virtu may be higher than those charged by the same third-party managers outside of Virtu. Retirement Plan Consulting Services Generally, these services are designed to assist plan administrators (i.e., a person or person(s) designated by the employer as having discretionary authority or control over the management of the plan) meet their fiduciary obligation to administer the plan in the best interests of the participants and their beneficiaries. A description of the different types of retirement plan services offered by CSA appears below. Administrative Support
•Assist Sponsor in reviewing objectives and options available through the plan
•Review plan committee structure and administrative policies/procedures
•Recommend participant education and communication policies under ERISA 404(c)
•Assist with development/maintenance of fiduciary audit file and document retention policies
•Deliver fiduciary training periodically or upon reasonable request
•Coordinate and reconcile participant disclosures under 404(a)(5)
•Develop requirements for responding to participant requests Service Provider Oversight
•Assist fiduciaries with a process to select, monitor and replace service providers
•Assist fiduciaries with review of Covered Service Providers (“CSP”) and fee benchmarking
•Provide reports and/or information designed to assist fiduciaries with monitoring CSPs
•Assist with use of ERISA Spending Accounts or Plan Expense Recapture Accounts (PERA)
•Assist with preparation and review of Requests for Proposals (RFPs) and/or Information (RFI)
•Coordinate and assist with CSP replacement and conversion Investments
•Periodic review of investment policy in the context of plan objectives
•Assist the plan committee with monitoring investment performance
•Provide analysis of investment managers and model portfolios
•Assist with Designated Investment Managers (DIMs) and/or third-party advice providers as necessary
•Educate plan committee members, as needed, regarding replacement of Designated Investment Alternatives (DIA) and/or Qualified Default Investment Alternatives
•(QDIA) Participant Services
•Facilitate group enrollment meetings
•Coordinate employee education regarding plan investments and fees
•Assist plan participants in understanding plan benefits, retirement readiness and impact of increasing deferrals General Information about Retirement Plan Services Provided to Retirement Plans and Participants Advisory services provided to retirement plans and their participants may be solely provided by Investment Advisory Representatives of CSA or in combination with third parties (e.g., third party administrators and record-keepers). CSA shall never have custody of any client funds or securities, as the services of an independent qualified custodian will be used for these asset management services. The services provided to any retirement plan sponsor may vary based on plan type (i.e., participant directed or trustee directed plan), plan features (i.e., automatic enrollment of participants) and the specific needs of the plan sponsor, participants and their beneficiaries. Financial Planning Services CSA offers financial planning services and advice to clients. Financial planning may consist of a number of services, depending on the client’s needs. The planning process evaluates a client’s current financial situation and proposes an action plan to help move towards setting and achieving the client’s financial goals. Each Advisor will have conversations with the client and review documents, such as income tax returns and current investments, to determine a client’s current financial situation and long- term financial goals. Clients may retain CSA to prepare a full financial plan, or to only give advice about a particular area of concern CSA may provide education services to clients about general investment principles. Education presentations will not take into account the individual circumstances of each client. Restrictions Imposed by Clients The client is under no obligation to accept any recommendation in the Financial Plan, and is free to impose restrictions on investing in certain types of securities in the Plan. Assets Under Management As of December 31, 2022, CSA managed $336,007,103 on a discretionary basis.