About Caldwell Sutter Capital
Caldwell Sutter Capital, Inc. ("Caldwell") was formed in 1982 and is primarily owned by the John and
Jinx Helmer Revocable Trust. Caldwell is organized as a corporation under the laws of the State of
California.
Caldwell is dually registered as a SEC registered investment adviser and a FINRA member broker-
dealer and is headquartered in Sausalito, California. Joe Helmer, CFA serves as the firm's President
and Christopher Anderson serves as the Chief Compliance Officer.
Advisory Services
Caldwell is a dually registered investment adviser and securities broker-dealer. Our quarterly fees are
based on securities upon which we have:
•Researched,
•Recommended to our clients,
•Acquired for our clients' accounts, normally as agent in the secondary markets, and
•Monitored thereafter.
Our clients are high net worth individual investors and their families. When making recommendations
to an investment account, we factor in the return objectives and risk objectives of the client. We also
factor in the individual investor's constraints. Constraints include time horizons, tax considerations,
liquidity needs, any legal or regulatory factors, and unique circumstances.
Tailoring Investments for Clients
Caldwell asks for advisory clients to complete an investment profile that helps us to understand your
financial situation, investment goals, and your tolerance for risk. We use this and other information to
help determine whether a particular investment is suitable for the needs and goals of the advisory
client. A client, through discussion with their adviser, is always free to indicate which of the investments
we recommend can be invested in their accounts. This may include restrictions on particular types of
securities, socially responsible investment strategies, or other specific factors that might be desired by
a client.
Wrap Fee Programs
Caldwell does not participate in any wrap fee programs.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"). When we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates
some conflicts with your interests, so we operate under a special rule that requires us to act in your
best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
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•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of September 29, 2023, Caldwell managed $36,851,354 on a non-discretionary basis, meaning that
the client gave their approval for each purchase we gave each investment. Caldwell managed
$451,557,844 on a discretionary basis, meaning the client does not need to give their approval for
each transaction in their portfolio. In total, Caldwell managed $488,409,198.