A. Firm Information
Well Done, LLC dba CapTrust Financial Advisors (hereinafter “CapTrust” or the “Advisor”) is a registered
investment advisor with the U.S. Securities and Exchange Commission (“SEC”). CapTrust is organized as a
limited liability company (“LLC”) under the laws of the State of Michigan. The Advisor was founded in
1997 and became a registered investment advisor in January 2015. CapTrust is primarily owned by Brian
VandenBrink, Shawn Pacanowski, Bryan Linn, Brendon Johnson, and Rhonda Carter , all of whom
believe in an employee-ownership structure.
While this Disclosure Brochure generally describes the business of CapTrust, certain sections also discuss the
activities of its Supervised Persons, which refer to the Advisor’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or any other person who provides
investment advice on CapTrust’s behalf and is subject to the Advisor’s supervision or control.
For information regarding this Disclosure Brochure, please contact Rhonda Carter, the Chief
Compliance Officer at (616) 392-5332.
B. Advisory Services Offered
CapTrust offers a variety of advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, businesses and retirement plans (each a “Client”).
The Advisor serves as a fiduciary to its Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate conflicts of interest. CapTrust’s fiduciary commitment is further described in the Advisor’s Code
of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics.
Wealth Planning and Investment Management Services
The Advisor’s Wealth Planning and Investment Management service includes regular and continuous Client
interactions integrated with ongoing guidance and planning and portfolio management services. These
services are defined below and may be offered on a stand-alone basis.
Wealth Planning Services
CapTrust offers Clients a broad range of Wealth Planning services as part of its comprehensive wealth
management services or pursuant to a Client agreement. Services include any or all of the following
functions:
• Business Planning
•
Cash Flow Forecasting
•
Trust and Estate Planning
• Investment Consulting
• Education Savings
• Retirement Planning
• Risk Management
Charitable Giving
Tax Planning
• Social Security Planning
Generally, such planning services involve preparing a formal financial plan or rendering a specific financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including but not limited to, investment planning, retirement planning, personal
savings, education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
CapTrust may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor might not provide a written summary.
Wealth Planning recommendations pose a conflict between the interests of the Advisor and the interests of
the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
Investment Management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client
elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to
implement the transaction through the Advisor.
Investment Management Services
CapTrust manages Client investment portfolios on a discretionary or non-discretionary basis. CapTrust
primarily allocates Client assets among various mutual funds, exchange-traded funds (“ETFs”), individual
debt and equity securities, variable annuities and independent investment managers, as described below, in
accordance with their stated investment objectives. In addition, CapTrust also recommends that certain
eligible Clients invest in privately placed securities, which includes debt, equity and/or interests in collective
investment vehicles (e.g., hedge funds, private equity funds, etc.).
Where appropriate, the Advisor also provides advice about any type of legacy position or other investment
held in Client portfolios. Clients may engage CapTrust to manage and/or advise on certain investment
products that are not maintained at their primary custodian, such as variable life insurance and annuity
contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
In these situations, CapTrust directs or recommends the allocation of Client assets among the various
investment options available with the product. These assets are generally maintained at the underwriting
insurance company or the custodian designated by the product’s provider.
CapTrust tailors its advisory services to meet the needs of its individual Clients and seeks to ensure, on a
continuous basis, that Client portfolios are managed in a manner consistent with those needs and objectives.
CapTrust consults with Clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their portfolios.
Clients are advised to promptly notify CapTrust if there are changes in their financial situation or if they
wish to place any limitations on the management of their portfolios. Clients may impose reasonable
restrictions or mandates on the management of their accounts if CapTrust determines, in its sole discretion,
the conditions would not materially impact the performance of a management strategy or prove overly
burdensome to the Advisor’s management efforts.
At no time will CapTrust accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s]
at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12
– Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual
retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of
the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the
Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account
or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA
sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the
Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any
obligation to roll over a retirement account to an account managed by the Advisor.
Use of Independent Managers – When deemed to be in the Client’s best interest, CapTrust will recommend
to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated
money managers or investment platforms (collectively “Independent Managers”). Independent Managers may
be sourced directly or accessed through an investment management platform. CapTrust serves as the Client’s
primary Advisor and Relationship Manager. However, the Independent Manager[s] will assume discretionary
authority for the day-to-day investment management of those assets placed in their control. CapTrust will assist
and advise the Client in establishing investment objectives for their account[s], the selection of the Independent
Manager[s], and defining any restrictions on the account[s]. CapTrust will continue to provide oversight of the
Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent
Manager[s] will implement the selected investment strategies based on their investment mandates. The Client
may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these
third parties. CapTrust does not receive any compensation from these Independent Managers, other than its
investment advisory fee as described in Item 5 below.
Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to
non-purpose loan programs available through the Custodian’s banking partner (“Lending Program”). In such
instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral for a non-
purpose loan. The recommendation of a Lending Program presents a conflict of interest as the Advisor will
continue to receive investment advisory fees for managing the collateralized assets in the Client’s account[s].
Clients are not obligated to engage the Advisor for the Lending Program. For additional information related
to the risks involved non-purpose loans, please see Item 8 - Methods of Analysis, Investment Strategies and
Risk of Loss.
Fully Paid Securities Lending – The Custodian allows Clients to enroll in their Fully Paid Securities Lending
program (“FPSL”) which enables Clients to lend certain securities to the Custodian in exchange for additional
income in their portfolios. Securities lending is when a Client temporarily loans securities to a financial
institution. The Client will enter into a separate loan agreement that will cover the terms of the loan. Pershing
utilizes the securities to satisfy both internal and external borrowing needs. The Custodian will earn revenue
from lending these securities and a portion of that revenue will be shared with the Client. The Advisor does
not earn any additional revenue for Clients who choose to enroll in FPSL.
Retirement Plan Advisory Services
CapTrust provides advisory services on behalf of company retirement plans (each a separate “Plan”) and the
company/sponsor (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to
assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
Vendor Analysis
• Investment Policy Statement (“IPS”) Design and Monitoring
Plan Participant Enrollment and Education Tracking
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
•
Performance Reporting
• Ongoing Investment Recommendation and Assistance
These services are provided by CapTrust serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section
408(b)(2), the Plan Sponsor is provided with a written description of CapTrust’s fiduciary status, the specific
services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the
engagement.
C. Client Account Management
Prior to CapTrust rendering any of the aforementioned advisory services, the Client is required to enter into
one or more written agreements with CapTrust setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
• Establishing an Investment Strategy – CapTrust, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
•
Asset Allocation – CapTrust will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
•
Portfolio Construction – CapTrust will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – CapTrust will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CapTrust typically includes the securities transaction fees together with its Investment Management fee.
The combination of these fees into a single, “bundled” fee is called a Wrap Fee Program. CapTrust serves
as the sponsor and portfolio manager of the CapTrust Wrap Fee Program. In the event the Client is provided
Investment Management services under the CapTrust Wrap Fee Program, securities transaction fees for the
Advisor’s discretionary trading in the Client’s account[s] will be covered under the Wrap Fee Program.
Clients may pay a higher or lower aggregate fee than if investment management and brokerage services are
purchased separately, depending on the level of trading in the Client’s account[s]. A complete description
of the CapTrust Wrap Fee Program is contained in the Appendix 1 – Wrap Fee Program Brochure, which
is included as part of this overall Disclosure Brochure. CapTrust manages wrap fee accounts in substantially
the same fashion as non-wrap fee accounts.
E. Assets Under Management
As of December 31, 2022, CapTrust manages $1,516,340,746 in Client assets, $1,507,734,827 of which
are on a discretionary basis and $8,605,919 of which are on a non-discretionary basis. Clients may request
more current information at any time by contacting the Advisor.