Description of Firm
Capital Developers, LLC d/b/a Milestone Wealth is a registered investment adviser based in
Greenville, North Carolina. We are organized as a limited liability company ("LLC") under the laws of
the State of North Carolina. We have been providing investment advisory services since April 2018.
We are owned by David R. Hunt.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to Milestone Wealth and the
words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Note: We do not provide tax or legal advice or services. You are advised to contact your tax or legal
advisers for tax or legal advice and services.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives. If you retain our firm for portfolio management services, we
will meet with you to determine your investment objectives, risk tolerance, and other relevant
information at the beginning of our advisory relationship. We will use the information we gather to
develop a strategy that enables our firm to give you continuous and focused investment advice and/or
to make investments on your behalf. As part of our portfolio management services, we may customize
an investment portfolio for you according to your risk tolerance and investing objectives. We may also
invest your assets according to one or more model portfolios developed by our firm. Once we
construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's
performance on an ongoing basis, and will rebalance the portfolio as required by changes in market
conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the portfolio
management agreement you sign with our firm and the appropriate trading authorization forms. You
may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
In limited circumstances and in our sole discretion, we also offer non-discretionary portfolio
management services. If you enter into a non-discretionary arrangement with our firm, we must obtain
your approval prior to executing any transactions on behalf of your account. You have an unrestricted
right to decline to implement any advice provided by our firm on a non-discretionary basis.
As referenced above, where suitable, we may invest your assets according to one or more
model portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios are unable to set
restrictions on the specific holdings or allocations within the model, nor the types of securities that can
be purchased in the model. Nonetheless, clients can impose restrictions on investing in certain
securities or types of securities in their account. In such cases, this could prevent a client from
investing in certain models that are managed by our firm.
Recommendation or Selection of Sub-Advisers
As part of our advisory services, we may recommend or select one or more third party investment
advisers/managers (“sub-advisers”) to manage a portion of or all of your account(s) on a discretionary
basis. All recommended/selected sub-advisers must be properly registered or exempt from
registration. You will receive relevant disclosures for each sub-adviser recommended or selected.
Sub-adviser(s) may use one or more of their model portfolios, programs, or platforms to manage your
account. We will regularly monitor the performance of your accounts managed by sub-adviser(s).
Where we do not have discretionary authority to hire and fire sub-adviser(s) and/or to reallocate your
assets to other sub-advisers/programs, we will make such recommendations for you to do so where
we deem such action to be appropriate.
Where we recommend you engage a sub-adviser directly, you will be required to sign a separate
agreement with such sub-adviser. Please consult with the recommended sub-adviser regarding their
policies on imposing restrictions on investments in particular securities or certain types of securities.
Sub-advisers charge separate fees in addition to our advisory fees. Typically, where we have
discretion to hire and fire sub-adviser(s) on your behalf any fees payable to sub-adviser(s) will be
included in the fees you pay to us. Typically, where you engage a sub-adviser directly, the advisory
fee you pay to the sub-adviser is established and payable in accordance with the disclosure brochure
provided by each sub-adviser and the agreement you sign with the sub-adviser. These fees may or
may not be negotiable. In any case, the combined total fee you pay to the sub-adviser and to us will
not exceed 2.0% of the assets under management annually. Lower fees may be available from firms
who do not utilize or recommend the services
of sub-advisers.
Although we receive no additional compensation directly or indirectly from the sub-advisers for
utilizing or recommending their services, they, the account custodian, or we will calculate and/or
deduct the advisory fees from the client’s account held at the qualified custodian upon client written
consent.
You and/or we can terminate the advisory relationship with the sub-adviser according to the terms of
the advisory agreement with the sub-adviser and/or program/platform sponsor. If you are required to
execute a separate advisory agreement with the sub-adviser directly, you should review each sub-
adviser’s advisory agreement and disclosure brochure(s) for specific information on your relationship
with the sub-adviser and how you can terminate your advisory agreement and/or receive a refund, if
applicable.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
clients regarding the management of their financial resources based upon an analysis of their
individual needs.
Our Broad-based financial planning provides an overall view of the client’s financial picture and
generally includes an assessment of your risk tolerance, time horizon, asset allocation, diversification,
analysis of concentrated equity holdings, and preparing a written client investment plan/report
addressing one or more of the following topics, or others, as agreed upon:
• Income Analysis
• Budgeting and Cash Flow Controls
• Investment Planning
• Stock Options Planning
• Restricted Stock Analysis
• Employee Benefits Analysis
• Business Retirement Plan Needs Analysis
• Business Succession Planning
• Business/Key Man Insurance Review
• Long Term Care Plan Sponsorship Review
• Disability Income Protection Analysis
• Non-Qualified Plan(s) Deferred Compensation Review
• Education Funding Analysis
• Retirement Planning
• Retirement Savings Analysis
• Retirement Income Analysis
• Debt Management Review
• Life Insurance Review/Need Analysis
• Disability Insurance Review/Need Analysis
• Long Term Care Insurance Review/Need Analysis
• Estate Planning Review
• Charitable Giving Strategy Review
• Tax Planning
• Other Considerations
If you retain our firm for financial planning services, we will meet with you to gather information about
your financial circumstances and objectives. We may also use financial planning software to
determine your current financial position and to define and quantify your long-term goals and
objectives. Once we specify those long-term objectives (both financial and non-financial), we will
develop shorter-term, targeted objectives. Once we review and analyze the information you provide to
our firm and the data derived from our financial planning software, we will deliver a written plan to you,
designed to help you achieve your stated financial goals and objectives.
Financial plans are based on the financial information you provide to us prior to the time we present
the plan to you.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you can act on our recommendations by placing
securities transactions with any brokerage firm you choose.
Consulting Services
We also offer financial consulting services that primarily involve advising clients on specific financial-
related topics. Written reports will not be provided.
One-Time Consulting Services will include advice based on information you provide to us and may
include recommendations regarding one or more of the following topics, or others, as agreed upon:
• Income Analysis/Cash Flow/Budget Analysis
• Investment Analysis/Asset Allocation
• Education Needs Analysis/Planning
• Retirement Needs Analysis/Planning
• Retirement Plan Review
• Life Insurance Review
• Disability Insurance Review including Policy Analysis
• Estate Analysis/Estate Planning
• Charitable Giving Analysis
• Employee Benefit Analysis
• Investment Counseling
Ongoing Consulting Services will include advice based on information you provide to us and may
include recommendations regarding one or more of the following topic, or others, as agreed upon:
• Portfolio Monitoring
• Group Retirement Enrollment/Education Meetings
Ongoing consulting services will include meeting or discussing with you from time to time as needed
or requested by you.
Wrap Fee Programs
We do not participate in any wrap fee program.
Types of Investments
We primarily offer advice on mutual funds and exchange traded funds (ETFs). However, we may also
advise you on various types of investments based on your stated goals and objectives. Additionally,
we may provide advice on any type of investment held in your portfolio at the inception of our advisory
relationship. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for
additional disclosures on this topic.
Assets Under Management
As of January 16, 2024, we had approximately $159,929,222 in client assets under management on a
discretionary basis, and approximately $2,920,653 in client assets on a non-discretionary basis.