COLORADO WEALTH GROUP, LLC
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USE OF SUB-ADVISORS
We provide investment advice, recommendations and utilize the investment strategies of Outside Investment Managers
(“Managers”) through a sub-adviser relationship. Selected Managers are evaluated by us for use in a client’s account.
Factors we will consider in recommending a particular sub-advisor include, but are not limited to, the client’s stated
investment objectives, management style, independence, stature of the custodian utilized by the sub-advisor,
performance, philosophy, financial strength, continuation of management, client service, reporting, commitment to a
particular investment mandate, fees, trading efficiency, and research.
Managers selected by us may offer multiple strategies. Our Firm will monitor Managers to ensure that it adheres to the
philosophy and investment style for which it was selected and to ensure that its performance, portfolio strategies, and
management remain aligned with the client’s overall investment goals and objectives. We will retain discretionary
authority to hire and fire the Manager. Our ongoing review includes, but is not limited to, assessment of the Manager’s
disclosure brochure, performance information, materials, personnel turnover, and regulatory events.
When we engage a Manager to invest a separately managed account (“SMA”), the SMA will be traded by either the
Manager (externally-traded) or by our Firm (internally-traded). In both cases, all research, investment selections and
portfolio decisions are the responsibility of the Manager, not by our Firm. Performance reporting may be the provided by
the Manager.
Through our Discretionary Investment Management Agreement, the Client grants CWG authority to utilize a sub-advisor.
Our Firm, in conjunction with the Manager, will continue to provide advisory services to the Client for the ongoing
monitoring, review, and reporting of the overall account performance.
Third-party managed programs generally have account minimum requirements that will vary from investment advisor to
investment advisor. A complete description of the Manager’s services, fee schedules and account minimums will be
disclosed in the Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the time an
agreement for services is executed and account is established.
FINANCIAL PLANNING
Through the financial planning process, our team strives to engage our clients in conversations around the client’s goals,
objectives, priorities, vision, and legacy – both for the near term as well as for future generations. With the unique goals
and circumstances of each client in mind, our team will offer financial planning ideas and strategies to address the client’s
holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and client legacy objectives.
Our team partners with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to
ensure a coordinated effort of all parties toward the client’s stated goals. Such services include various reports on specific
goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic
updates.
Our specific services in preparing your plan may include:
Review and clarification of your financial goals
Assessment of your overall financial position including cash flow, balance sheet, investment strategy, risk
management, and estate planning
Creation of a unique plan for each goal you have, including personal and business real estate, education,
retirement or financial independence, charitable giving, estate planning, business succession, and other personal
goals
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Development of a goal-oriented investment plan, with input from various advisors to our clients around tax
suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified
plans, taxable, and trust accounts that require special attention
Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including
liquidity as well as various insurance and possible company benefits
Crafting and implementation of, in conjunction with your estate and/or corporate attorneys as tax adviser, an
estate plan to provide for you and/or your heirs in the event of an incapacity or death
A written evaluation of each client's initial situation or Financial Plan is provided to the client. An annual review will be
provided by the Adviser, if indicated by the Client and Adviser per the Agreement. We offer an optional semi-annual
follow-up and review of the Financial Plan for an additional fee. This is agreed to between the Client and CWG using a
separate Agreement.
Client should be aware a conflict exists between the interests of the investment adviser and the interests of the client.
The client is under no obligation to act upon the investment adviser's recommendation, and if the client elects to act on
any of the recommendations, the client is under no obligation to affect the transaction through the investment adviser.
RETIREMENT PLAN SERVICES
For employer-sponsored retirement plans with participant-directed investments, our Firm provides its advisory services
as an investment adviser as defined under Section 3(21) of the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”).
When serving as an ERISA 3(21) investment adviser, the Plan Sponsor and our Firm share fiduciary responsibility. The Plan
Sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations
in accordance with the terms of a separate ERISA 3(21) Plan Sponsor Investment Management Agreement between our
Firm and the Plan Sponsor. Under the 3(21) agreement, our Firm provides the following services to the Plan Sponsor:
Screen investments
and make recommendations.
Monitor the investments and suggests replacement investments when appropriate.
Provide a quarterly monitoring report.
Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
Recommend QDIA alternatives.
Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial education to Plan
participants, benchmarking the Plan services, education to fiduciary committee members, and monitoring the service
provider. The scope of education provided to participants will not constitute “investment advice” within the meaning of
ERISA and participant education will relate to general principles for investing and information about the investment
options currently in the Plan. We may also participate in initial enrollment meetings and periodic workshops and
enrollment meetings for new participants.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets
to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax
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consequences). Our Firm may recommend an investor roll over plan assets to an IRA for which our Firm provides
investment advisory services. As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their previous employer or roll over the
assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore
has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which presents
a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before
recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the
investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the
services and responsiveness of the plan’s investment professionals versus those of our Firm, (iv) protection of assets from
creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax
consequences, if any. All rollover recommendations are also reviewed by our Firm’s Chief Compliance Officer in a best
effort to determine that the recommendation to a client was reasonable or that the client has determined to make the
rollover after being provided ample information about their options. No client is under any obligation to roll over plan
assets to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the account while maintained with
the client's employer. Our Firm’s Chief Compliance Officer remains available to address any questions that a client or
prospective client has regarding this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding
your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the
way we make money creates some conflicts with your interests.
FINANCIAL INSTITUTION CONSULTING SERVICES
Our Firm has an agreement with Mutual Securities, Inc. (“Mutual Securities”) to provide investment consulting services to
certain brokerage customers of Mutual Securities. Mutual Securities will pay compensation to our Firm for providing
investment consulting services to its brokerage customers. This consulting arrangement does not include assuming
discretionary authority over brokerage accounts or the monitoring of securities. These consulting services offered to
financial institution clients may include a general review of client investments holdings, which may or may not result in a
CWG’s investment adviser representative making specific securities recommendations or offering general investment
advice.
This relationship presents a conflict of interest. The conflict is mitigated by the brokerage customer(s) consenting to
receive investment consulting services from our Firm and the brokerage customer(s) executing a written advisory
agreement directly with CWG. Further, no other additional compensation will be paid by Mutual Securities to our Firm in
connection with the investment consulting services. Our Firm will not hold itself out to the public as engaging in brokerage
activities. Mutual Securities and CWG are separate and unrelated entities.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern such as
divorce planning, estate planning, real estate, retirement planning, or any other specific topic. Additionally, we provide
advice on non-securities matters about the rendering of estate planning, insurance, real estate, and/or annuity advice or
any other business advisory or consulting services for equity or debt investments in privately held businesses. In these
cases, you will be required to select your own investment managers, custodian and/or insurance companies for the
implementation of consulting recommendations. If your needs include brokerage and/or other financial services, we will
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