Columbia Advisory Partners, LLC (“CAP,” “we,” or “our”) was formed in June of 2004 to provide accounting
services. Investment advisory services were added in June of 2014. CAP is owned by Kimberly Smith, Steven Larsen
and Jeremy Russell, all of whom are also investment advisory representatives of CAP.
Investment advisory services of CAP are provided to you through an appropriately licensed and qualified individual
who is registered as an investment advisory representative (“IAR”) of CAP.
Services
We offer both comprehensive financial planning and discretionary investment management services. These
services are separate and distinct. Before providing any services to you, we enter into a written agreement
(“Agreement”). The Agreement describes the specific services we will provide and the related fees. Clients can
terminate their Agreement without penalty within five business days after entering into the Agreement with us.
In addition, we provide investment advisory services to a private investment fund, CAP Private Credit Fund, LP
(the “Fund”). The Fund is structured as a Delaware limited partnership.
Financial Planning Services
We believe a written and comprehensive financial plan is the foundation which will guide you through every
financial decision you make. Our planning is comprehensive and incorporates all aspects of a client’s life, including
but not limited to:
• Cashflow
• Tax planning
• Retirement Planning
• Education Planning
• Estate planning
• Risk Management
• Digital Asset Advice
With a thorough understanding of your objectives and needs, we work with you to formulate a plan that includes
an integrated set of strategies based on established planning and investment techniques. We then periodically
review and measure your progress to remain aligned with your plan. This process keeps our understanding of your
situation fresh and allows us to update your plan as needed. We charge separately for financial planning as
detailed below in Item 5 – Fees.
Clients are under no obligation to implement their financial plan through CAP or engage the services of any CAP
recommended professional. Implementation of your plan is at your sole discretion.
Discretionary Investment Management Services
Once your initial plan is developed, we work with you to systematically implement your strategies, including the
construction of a customized investment portfolio. We manage portfolios on a discretionary basis, typically using
strategies that contain mutual funds, ETFs, individual equities, and fixed income solutions, though we are not
limited to specific security types. Clients enter into the Agreement with CAP that describes the services and fees
we will provide, and also grants us limited power of attorney to enter transactions for you on a discretionary basis.
We also offer the Defi Steward Program for clients with appropriate risk tolerance, liquidity and experience.
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You may place restrictions on how we manage your assets, though we reserve the right to refuse restrictions we
think are too operationally difficult to implement, or that we believe are not in your best interests.
We do not participate in any wrap fee programs.
Amplify Platform
CAP investment adviser representatives utilize the Amplify Platform, the Amplify Platform provides back-office
operational support services such as administrative, trading and reporting services and/or gain access to and select
from independent third-party managers available through the Amplify Platform.
Upon executing the Platform Agreement, the investment adviser firm or investment professional shall be
considered a Platform Member. Platform Members may choose to receive certain back-office services, such as
administrative, trading and reporting services and/or to select independent third-party managers to manage
underlying client assets on a sub-advisory basis. Platform Members may choose to allocate all or a portion of their
underlying client’s assets among the different independent investment managers available through the Amplify
Platform on a discretionary basis.
Platform Members shall have a direct contractual relationship with each of their underlying clients and obtain,
through such agreements, the authority to engage Amplify Platform for services rendered through the Platform.
CAP engages unaffiliated investment advisers to service Platform Members as sub-advisers. Sub-advisers available
through the Amplify Platform will perform discretionary investment management services and shall manage,
invest and reinvest the Platform Member’s underlying client assets designated by the Platform Member. As such,
a selected manager(s) shall be authorized, without prior consultation with the Platform Member or the underlying
client, to buy, sell trade or allocate the underlying client’s assets in accordance with the underlying client’s
investment objectives and to deliver instructions in furtherance this responsibility to the underlying client’s
broker-dealer and or custodian.
Platform Members retain responsibility for the underlying client relationship, including the initial and ongoing
suitability determination. Platform Members shall also retain the responsibility for implementing client
investment recommendations in accordance with the Platform Member’s fiduciary duty to the underlying client.
Platform Members are responsible for obtaining and furnishing information pertaining to sub-advisor selection
and underlying client account guidelines along with any reasonable account restrictions.
Please note: CAP’s investment adviser representatives are required to utilize the various services available through
the Amplify Platform. Therefore, CAP clients may incur fees in addition to the fee associated with the advisory
services provided to the client. CAP receives a portion of the Amplify Platform fees.
Independent Managers
CAP may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among
unaffiliated independent investment managers in
accordance with the client’s designated investment objective(s).
In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary
management of the allocated assets. CAP shall continue to render investment advisory services to the client
relative to the ongoing monitoring and review of account performance, asset allocation and client investment
objectives. Factors which CAP shall consider in recommending Independent Manager[s] include the client’s
designated investment objective(s), management style, performance, reputation, financial strength, reporting,
pricing, and research.
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Certain Independent Manager[s] may offer their services as a Unified Managed Account (UMA) platform or as a
Separately Managed Account (SMA) platform, or both.
Within an UMA platform environment, the Independent Manager makes available a menu of investment models
and strategies maintained by Third-Party Money Managers (TPMMs). The TPMMs maintain model portfolios and
provide allocation and trade instructions/signals to the Independent Manager of the UMA platform. The
Independent Manager then implements the allocation or trade instruction/signal within the client’s UMA platform
accounts for those clients subscribed to such TPMM’s model portfolios. At no time does a TPMM on the UMA
platform have any advisory relationship with the client or have control or discretion of client assets. Trade
discretion lies with the Independent Manager, whose authority is derived from the advisory agreement in place
between the client and CAP. In addition, the Independent Manager has the authority to substitute any security
recommended by TPMM for a security which the Independent Manager has determined is more suitable for the
model and/or the individual client account.
Within an SMA platform environment, the Independent Manager makes available a menu of Portfolio Managers
offered through separate accounts and managed by the Portfolio Manager. Portfolio Managers do have authority
and discretion of the assets in the separately managed accounts and effect trades in such accounts in accordance
with the intended objectives of their stated investment strategy. Trade discretion lies with the Portfolio Manager,
whose authority is derived from the advisory agreement in place between the client and CAP.
The Independent Manager[s] may offer a platform which includes both UMA and SMA services. Independent
Manager[s] may provide other back-office and administrative services for CAP. Independent Manager[s] firm
disclosure brochure will be made available to you, at no charge, upon request. You may opt for CAP to receive any
Independent Manager[s] firm disclosure brochure on your behalf, if you so choose.
Defi Steward Program
We also offer the Defi Steward Program for clients with appropriate risk tolerance, liquidity and experience.
Clients may opt to use a self-custodial digital wallet to implement our Defi Steward Program, in which case CAP
will recommend trades to the client but will not implement them on a discretionary or non-discretionary basis.
Private Investment Fund
We provide investment advisory services to the Fund based on the investment objectives of the Fund. There can
be no assurance that the Fund will achieve its investment objective or avoid substantial losses. An investor should
not make an investment in the Fund with the expectation of sheltering income or receiving cash distributions.
Investors are urged to consult with their personal advisers before investing in the Fund.
This document is not an offer to sell or a solicitation of an offer to buy interests in the Fund. Such an investment
may be made only after receipt and review of the Fund’s Confidential Private Placement Memorandum (the
“Memorandum”). The Memorandum contains important information concerning risk factors and other material
aspects of the Fund and it must be read carefully before making an investment decision. The information in this
document is qualified in its entirety by, and should be read in conjunction with, the information contained in the
Memorandum.
Investors in the Fund are limited partners (“Limited Partners”). We do not provide tailored investment advice to
Limited Partners. However, Limited Partners may utilize our other financial planning and discretionary investment
management services.
Client Obligations
Columbia Advisory Partners P a g e | 7 Form ADV Part 2A: Firm Brochure
In performing its services, CAP shall not be required to verify any information received from the client or from the
client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it
remains his or her responsibility to promptly notify CAP if there is ever any change in his or her financial situation
or investment objectives for the purpose of reviewing, evaluating, and revising CAP’s previous recommendations
and/or services.
Important Information for Retirement Investors
When we recommend that you rollover retirement assets or transfer existing retirement assets (such as a 401(k)
or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional
revenue when we manage more assets. In making the recommendation, however, we do so only after determining
that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover
retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or
both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our
ongoing investment advisory recommendations and discretionary asset management services, as described in the
advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be
described in the advisory agreement.
Amount of Assets Under Management
As of July 31, 2023, Columbia Advisory Partners, LLC had $232,500,000 in assets under management on a
discretionary basis and $0 on non-discretionary basis.