This Disclosure document is being offered to you by Colorado Wealth Group, LLC (“CWG” or “Firm”) about the investment
advisory services we provide. It discloses information about our services and the way those services are made available to
you, the client.
Our Firm became a registered investment adviser in August 2020. This Firm is owned by Steven Harp, CEO, and Jacob Ray.
Jacob Ray is the Chief Compliance Officer.
We are committed to helping clients build, manage, and preserve their wealth. Our Firm provides services that help clients
to achieve their stated financial goals. We will offer an initial complimentary meeting upon our discretion; however,
investment advisory services are initiated only after you and CWG execute an Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT & SUPERVISION SERVICES
We manage advisory accounts on a discretionary basis and, in certain cases, on a non-discretionary basis. On a
discretionary basis, once we have determined a profile and investment plan with a client, we will execute the day-to-day
transactions without seeking prior client consent but within the expected investment guidelines. We primarily allocate
client assets among individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public
securities or investments. Portfolios will be designed to meet a particular investment goal, determined to be suitable to
the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly
monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and liquidity
needs. As appropriate, we also review a client’s prior investment history, as well as family composition and background.
Based on client needs, we develop a client’s personal profile and investment plan. We then create and manage the client’s
investments based on that policy and plan. It is the client’s obligation to notify us immediately if circumstances have
changed with respect to their goals.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to meet client financial
objectives. We trade these portfolios based on the combination of our market views and client objectives, using our
investment process. We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio
is managed in a manner consistent with those needs and objectives. Clients have the ability to leave standing instructions
with us to refrain from investing in particular industries or invest in limited amounts of securities. Clients have the ability to
place certain restrictions on the investments we select for your account if circumstances warrant.
Clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We
have limited authority to direct the Custodian to deduct our investment advisory fees from client accounts, but only with
the appropriate written authorization from clients.
Clients may engage us to advise on certain investment products that are not maintained at our Firm’s recommended
custodian, such as variable life insurance, annuity contracts, and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e., 529 plans). Where appropriate, we provide advice about any type of held away account that is
part of a client portfolio.
You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain
market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your
account.
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 the Manager
(externally-traded). All research, investment selections and portfolio decisions are the responsibility of the Manager, not
our Firm. Performance reporting may be 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.
FINANCIAL PLANNING SERVICES
Through our Financial Planning Services, 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 Financial Planning Services begin with the three-to-six-month preparation of your initial Financial Plan and 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.
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 initial Financial Plan is provided to the client during a Financial Plan Delivery Meeting. The written initial Financial
Plan will be delivered regardless of the client’s intention to implement any recommendations through CWG. Upon
culmination of the initial Financial Plan, the client will continue Financial Planning Services per their Financial Planning
Services Agreement.
During continuation of Financial Planning Services, a client can expect a thorough update of the Financial Plan annually,
along with tax projections, estate planning review, investment insights, distribution planning, Roth conversion strategy,
and many other topics. Financial Planning Services clients will have an opportunity to meet with a Wealth Advisor twice
per year, complimented by access to educational webinars, advisor office hours, and client events.
Clients should be aware that 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 recommendations, and if the client elects to
act on any of the recommendations, the client is under no obligation to effect 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.
Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial education to Plan
participants, 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.
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. You have the right to choose whether or not to follow the consulting
advice that we provide.
ASSETS
As of December 31, 2023, our Firm manages $171,843,738 on a discretionary basis and $3,992,827 on a non-discretionary
basis. As of December 31, 2023, our firm advises on an additional $9,007,170.