A. Firm Information
CIC Wealth, LLC (“CIC Wealth” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws
of the State of Delaware. CIC Wealth was founded in 2017 and is a wholly-owned subsidiary of CIC Wealth
Holdings, LLC. The majority owners of CIC Wealth Holdings, LLC are Michael Fein and Ryan Wibberley. This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by CIC Wealth.
B. Advisory Services Offered
CIC Wealth offers investment advisory services to individuals, high net worth individuals, trusts, estates,
businesses, retirement plans, and charitable organizations (each referred to as a “Client”).
The Advisor serves as a fiduciary to 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 potential
conflicts of interest. CIC Wealth’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
CIC Wealth provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services. CIC Wealth works closely with each Client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio
strategy. CIC Wealth will then construct an investment portfolio, consisting of low-cost, diversified mutual funds
and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks or bonds contracts to meet the needs of its Clients. The Advisor may retain certain legacy
investments based on portfolio fit and/or tax considerations.
CIC Wealth will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial
and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans, CIC
Wealth will select, recommend and/or retain a mutual fund share class that does not have trading costs, but do
have higher internal expense ratios than institutional share classes. CIC Wealth will seek to select the lowest
cost share class available that is in the best interest of each Client and will ensure the selection aligns with the
Client’s financial objectives and stated investment guidelines.
CIC Wealth’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. CIC Wealth will construct, implement and monitor the 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.
CIC Wealth evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. CIC Wealth may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. CIC Wealth 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. CIC Wealth
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 the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
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At no time will CIC Wealth accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outline in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement, 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.
Financial Planning Services
CIC Wealth will typically provide a variety of financial planning and consulting services to Clients, pursuant to a
written financial planning agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives.
Generally, such financial 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.
CIC Wealth 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 may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations poses 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.
Retirement Plan Advisory Services
CIC Wealth provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (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 its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
● Plan Participant Enrollment and Education Tracking
● Investment Oversight Services (ERISA 3(21))
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These services are provided by CIC Wealth 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 CIC Wealth’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Use of Independent Managers
CIC Wealth may recommend that a Client utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such
instances, the Client may be required to authorize and enter into an investment management agreement with the
Independent Manager that defines the terms in which the Independent Manager will provide its services. The
Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure
the strategy remains aligned with its Clients’ investment objectives and overall best interests. The Advisor will
also assist in the development of the initial policy recommendations and managing the ongoing Client
relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with
the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures).
Private Fund Advisor
CIC Wealth also serves as the investment advisor to the CIC Private Credit Fund, a series of the Glide Fund
Series, LLC. These services are detailed in the offering documents for the Fund, which include as applicable,
operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate
disclosure documents, series supplements and all amendments thereto (“Offering Documents”). The Advisor
manages the Fund based on the investment objectives, policies and guidelines as set forth in the respective
Offering Documents and not in accordance with the individual needs or objectives of any particular investor
therein. Each prospective investor interested in investing in the Fund is required to complete a subscription
agreement in which the prospective investor attests as to whether such prospective investor meets the
qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with
such an investment. CIC Wealth may recommend that certain Clients who meet certain qualifications invest into
the Funds. The Advisor does not receive a separate advisory fee for its Investment Advisory services to the
Funds, nor any other type of compensation from the Funds. Rather, the Advisor’s only compensation is the
advisory fee that it receives from the Client as discussed in Item 5 below.
C. Client Account Management
Prior to engaging CIC Wealth to provide investment advisory services, each Client is required to enter into one or
more 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 – CIC Wealth, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
● Asset Allocation – CIC Wealth 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 – CIC Wealth will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
● Investment Management and Supervision – CIC Wealth will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
CIC Wealth does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by CIC Wealth.
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E. Assets Under Management
As of, December 31, 2023, CIC manages $658,821,740 in Client assets, $650,182,537 of which are managed on
a discretionary basis and $8,639,203 on a non-discretionary basis. Clients may request more current information
at any time by contacting the Advisor.