Introduction Zullo Investment Group, Inc., doing business as Capital Wealth Investments, (hereinafter “CWI”) is a registered investment advisor based in Scranton, Pennsylvania. We are a corporation formed under the laws of the Commonwealth of Virginia. We have been providing investment advisory services since 2020. Tracy A. Zullo is CWI’s principal owner. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment adviser representatives. Currently, we offer the following investment advisory services, personalized to each individual client:
• Portfolio Management Services
• Financial Planning Services
• Pension Consulting Services Portfolio Management Services Our firm offers discretionary portfolio management services, which means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and help you decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals. CWI provides advice on various types of securities, such as exchange listed equities, foreign issues, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities, and interests in partnership investing in real estate. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. Selection of Sub-Advisors As part of our overall portfolio management strategy, we may use one or more sub-advisors to manage all or a portion of your account. All sub-advisors recommended by our firm must either be registered as investment advisors or exempt from registration requirements. These sub-advisors may specialize in private equity investments, private credit markets, hedge funds or other types of alternative investments. Factors that we take into consideration when making our recommendations include, but are not limited to, the following: the sub- advisor’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the sub-advisor’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. We retain the right to hire and fire sub-advisors and the right to reallocate client assets to other model portfolios at the same sub-advisor. Financial Planning Services We offer broad-based financial planning, which includes a variety of services, mainly advisory in nature, regarding management of financial resources. Such management is based upon an analysis of the client’s individual needs and begins with an initial consultation. Once we collect and analyze all documentation, we provide a financial plan designed to achieve the client’s financial goals and objectives. The plan may be delivered in writing, or in the form of one or more meeting or telephone consultations. In this way, CWI assists the client in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services may include any one or all of the following, along with any other investment related topic that the client would like to discuss:
• Cash Flow Analysis – Assessment of a client’s present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk, coordinate, and organize records, and estate information.
• Retirement Analysis – Identification of a client’s long-term financial and personal goals and objectives includes advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management

associated with advisory recommendations based on a combination of insurance types to meet a client’s needs, e.g., life, health, disability, and long-term care insurance. This will necessitate an analysis of cash needs of family at death, income needs of surviving dependents, and disability income analysis.
• Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset allocation, and effect on a client’s portfolio. We evaluate economic and tax characteristics of existing investments as well as their suitability for a client’s objectives. We identify and evaluate tax consequences and their implications.
• Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education.
• Estate Analysis – We provide advice with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques.
• Elder Care Planning – We provide advice with respect to client matters related to periods of incapacity and cognitive decline. The recommendations and solutions are designed to achieve the desired goals subject to periodic evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are based on a client’s financial situation based on the information provided to the firm. We should be notified promptly of any change to a client’s financial situation, goals, objectives, or needs. Important Note: Information related to legal or tax matters that is provided as part of our services is for informative purposes only. Clients are instructed to contact their attorneys or tax professionals for legal or tax services. Pension Consulting Services CWI provides several pension consulting related services. While the primary clients for these services will be pension, profit sharing and 401(k) plans, CWI will also offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of the following components. Clients may choose to use any or all of these services. Investment Policy Statement Preparation (''IPS''): CWI will meet with the client (in person or over the telephone) to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. CWI then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles CWI will create or review the plan’s investment lineup, primarily consisting of mutual funds (both index and managed) and clients will select the lineup that is most appropriate for their investment needs. The plan’s investment lineup may also include individual equities, bonds, and other investment products. The number of investments to be recommended will be determined by the plan, based on the plan’s stated goals. Monitoring of Investment Performance Client investments will be monitored and reviewed based on the procedures and timing intervals outlined in the agreement with the client. Where CWI has no access to client account statements, the client is instructed to make such statements available to the firm. Although CWI will not be involved in any way in the purchase or sale of these investments, CWI will make recommendations to the client as market factors and the client's needs dictate. Employee Communications For pension, profit sharing and 401(k) plans where the individual account participant exercises control over assets in their own account (hereinafter ''self-directed plans''), CWI also provides educational support designed for the plan participants. The nature of the topics to be covered will be determined by CWI and the client under the guidelines established in Employee Retirement Income Securities Act (“ERISA”). Educational support services will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. Other pension consulting services are available on request. All of our pension consulting services, whether general or customized, will be outlined in an agreement that shows the services that will be provided and the fees that will be charged for those services. CWI is registered as an investment advisor and represents that it is not subject to any disqualification as set forth in ERISA. To the extent CWI performs Fiduciary Services, CWI acts as a fiduciary of the plan as defined in Section 3(21) under the Employee Retirement Income Security Act (“ERISA”). Wrap Fee Programs We do not sponsor or manage wrap fee programs. Assets Under Management As of December 31, 2023, we manage approximately $315,061,995 in client assets on a discretionary basis and approximately $13,267,735 in client assets on a non-discretionary basis.