A. Firm Information
Capital CS Group, LLC (“CCSG” or the “Advisor”) is an SEC registered investment adviser. CCSG is organized as
a limited liability company under the laws of the State of California. CCSG was founded in 2019 and has been in
business as an investment adviser since that time. CCSG is owned by Jessica McConnell and Todd Carbone. This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by CCSG.
For questions regarding this Disclosure Brochure, please contact Jessica McConnell, Chief Compliance Officer at
(844) 390-2797.
B. Advisory Services Offered
CCSG offers investment advisory services to high-net-worth individuals, families, trusts, estates, and businesses
(each referred to as a “Client”). CCSG provides Comprehensive Investment Management, Financial Planning and
Consulting services tailored to the individual needs of each Client.
Investment Advisory Services
CCSG provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management, planning and related
advisory services. CCSG typically offers these as a bundled advisory engagement, but may, in certain
circumstances, offer as individual services. CCSG works closely with each Client to develop an investment strategy
that seeks to achieve the goals of the Client.
Investment Management
CCSG customizes its investment management services for its Clients. Portfolios are primarily constructed using
mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. For certain Clients,
the Advisor may also utilize alternative investments and other types of investments, as appropriate, to meet the
needs of particular Clients. For some Clients, CCSG has the ability to employ a hedging strategy involving
concentrated or restricted stock positions held at a Custodian. The Advisor generally constructs portfolios in
alignment with its internal strategies but may retain legacy securities due to portfolio fit and tax considerations.
CCSG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. CCSG’s investment strategy is primarily long-term focused, but the Advisor may buy, sell, or re-
allocate positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. If it is consistent with the Client’s goals, the Advisor may also engage in an investment strategy that
utilizes frequent trading in securities, please see Item 8 for more information. CCSG will construct, implement, and
monitor the Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to
by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to
be held in their respective portfolio, subject to acceptance by the Advisor.
CCSG, in its discretion, may redistribute investment allocations to diversify the portfolio. CCSG may recommend
specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash
positions as a possible hedge against market movement. CCSG may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk
tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
CCSG will provide investment management and related advisory services. At no time will CCSG accept or maintain
custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees and dispersing client
funds to a third party under a standing letter of instruction. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the investment advisory agreement.
CCSG 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.
CCSG 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]. CCSG 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. CCSG does not receive any compensation from these Independent Managers or Investment
Platforms, other than its investment advisory fee (described in Item 5).
*Use of Pontera® to manage assets “held away”: We provide an additional service for accounts not directly held
in our custody, but where we do have discretion, and may leverage an Order Management System to implement
tax-efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily
401(k) accounts, HSA’s, and other assets we do not custody. We regularly review the available investment options
in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other
accounts, though using different tools as necessary.
Portfolio Monitoring
CCSG may also provide for general asset allocation guidance within parameters of a plan held with outside
custodians. This guidance is solely consultative in nature and involves no on-going supervision, trading, or
discretion with respect to securities transactions. Clients are responsible for placing and executing their own trades,
either on their own or with another investment adviser. We provide non-continuous and periodic outside account
monitoring.
Account Monitoring
This service provides for safekeeping/housekeeping of Client Assets on Client’s behalf. CCSG is not authorized to
effectuate securities transactions unless specifically requested by the Client. Otherwise, Client is responsible for
the execution of trades on their own or with another registered investment adviser. CCSG will provide financial
planning or consulting services with respect to the Assets.
Financial Planning and Consulting Services
CCSG
will typically provide a variety of financial planning services to Clients. Services are offered in several areas of
a Client’s financial situation, depending on their goals, objectives and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a 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, estate planning,
personal savings, education savings and other areas of a Client’s financial situation. For some Clients, CCSG has
the ability to employ a hedging strategy involving concentrated or restricted stock positions held at a Custodian.
A financial plan developed, 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. CCSG may also refer Clients
to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning
engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and
recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans
or consultations are typically completed within six months of contract date, assuming all information and documents
requested are provided promptly.
CCSG may utilize the sub-advisory services of a third-party investment advisory firm or individual advisor to aid in
the formation of a financial plan. Before selecting a firm or individual, CCSG will ensure that the chosen party is
properly licensed or registered.
Consulting/Margin Loan Program - CCSG has partnered with its custodian and negotiated low interest rate margin
loans to be offered to its Clients. In this program, CCSG is engaged as a consultant to assist in procuring the margin
loan between the Client and the custodian. CCSG provides ongoing consulting and other related services to these
accounts as requested by the Client. CCSG will consult and assist in securing low rate margin loans with its
custodians while also providing research and other advice to their clients.
Retirement Plan Consulting Services
CCSG provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally,
such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing
their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising
could include: investment options, plan structure and participant education. Retirement Plan Consulting services
typically include:
Establishing an Investment Policy Statement – CCSG will assist in the development of a statement that
summarizes the investment goals and objectives along with the broad strategies to be employed to meet
the objectives.
Investment Options – CCSG will work with the Plan Sponsor to evaluate existing investment options and
make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – CCSG will develop strategic asset allocation models to aid
Participants in developing strategies to meet their investment objectives, time horizon, financial situation
and tolerance for risk.
Investment Monitoring – CCSG will monitor the performance of the investments and notify the client in the
event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, CCSG does not provide any advisory services with respect to
the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded
REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window
programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the
applicable state laws regulating retirement consulting services. This applies to Client accounts that are retirement
or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the Client accounts are part of a Plan, and CCSG accepts appointment to provide services
to such accounts, CCSG acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA
as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described
therein.
Please note: CCSG does not determine if securities held by Clients are the subject of a class action lawsuit or whether
Clients are eligible to participate in class action settlements or litigation nor does CCSG initiate or participate in
litigation to recover damages on a Client’s behalf for injuries as a result of actions, misconduct, or negligence by
issuers of securities held by Clients.
C. Client Account Management
Prior to engaging CCSG to provide investment advisory services, each Client is required to enter into one or more
advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
Establishing an Investment Strategy – CCSG, in connection with the Client, will develop an investment
strategy targeted to achieve the Client’s investment goals and objectives.
Asset Allocation – CCSG 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 – CCSG will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
Investment Management and Supervision – CCSG will provide investment management and ongoing
oversight of the Client’s portfolio.
Financial Planning and Consulting – For Clients engaging for investment advisory services, the Advisor
provides ongoing financial planning and related services regarding the Client’s overall financial situation.
D. Wrap Fee Programs
CCSG does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of 12/31/2023, CCSG manages $110,725,890 worth of assets on a discretionary basis and $18,777,476 worth of
assets on a non-discretionary basis, totaling $129,503,366 in aggregate Assets Under Management.