Item 5: Account Requirement and Type of Clients ...................................................................................... 4
Item 6: Portfolio Manager Selection and Evaluation ................................................................................... 4
Item 7: Client Information provided to Portfolio Managers. ....................................................................... 5
Item 8: Client Contact with Portfolio Managers .......................................................................................... 5
Item 9: Additional Information .................................................................................................................... 5
Brochure Supplement ................................................................................................................................ 8
Item 2 Educational Background and Business Experience ............................................................... 8
Item 3 Disciplinary Information ......................................................................................................... 9
Item 5 Additional Compensation ...................................................................................................... 9
Item 6 Supervision ............................................................................................................................... 9
Brochure Supplement ................................................................................................................................... 2
Item 1 Cover Page ................................................................................................................................ 2
Item 2 Educational Background and Business Experience ................................................................... 2
Item 3 Disciplinary Information ............................................................................................................ 3
Item 5 Additional Compensation .......................................................................................................... 3
Item 6 Supervision ................................................................................................................................ 3
Brochure Supplement ................................................................................................................................... 4
Item 1 Cover Page ................................................................................................................................ 4
Item 2 Educational Background and Business Experience ................................................................... 4
Item 3 Disciplinary Information ............................................................................................................ 4
Item 5 Additional Compensation .......................................................................................................... 4
Item 6 Supervision ................................................................................................................................ 5
Brochure Supplement ................................................................................................................................... 6
Item 1 Cover Page ................................................................................................................................ 6
Item 2 Educational Background and Business Experience ................................................................... 6
Item 3 Disciplinary Information ............................................................................................................ 6
Item 5 Additional Compensation .......................................................................................................... 6
Item 6 Supervision ................................................................................................................................ 7
INFORMATIONAL BROCHURE
CAPSTONE INVESTMENT FINANCIAL GROUP, LLC (“CIFG” or “Capstone”) has been in business since 2005. James
Cornehlsen and Elizabeth Cornehlsen are the firm’s only principal owners.
CIFG provides personalized investment management services. We typically work with individuals, investment companies,
pension and profit sharing plans, trusts, estates, charities, corporations, other business entities and other investment
advisory firms.
Financial Planning
Financial planning is the process by which the client’s current circumstances (which include assets as well as liabilities,
insurance, tax, retirement, education and other perspectives) are viewed against the client’s goals, and a plan is
developed to help the client reach those goals. In order for us to perform this service, the client will provide all
information relevant to their financial position (income, savings, insurance, other investments, age, liabilities, personal
obligations, etc.) and ultimate financial goals (retire dates, estate objectives, spending targets, etc.). Information is
collected by personal interview, phone conference and/or in writing. Once collected, an investment plan will be created
for the purpose of evaluating present status to the likelihood of accomplishing ultimate goals, as well as to monitor
client progress through time.
This work is intended to be a general guide to aid in the overall planning process, with a key element of an early alert if a
plan is falling off target and at risk of missing a major goal. Not every plan will be the same for every client, as
circumstances and goals are highly personal. Because a plan is based on client provided information, accurate and
complete data is essential, as well as updates regarding material changes in life circumstances.
Asset Management
CIFG requires each client to place at least $50,000 with the firm. This minimum may be waived at the discretion of CIFG.
We believe that successful investing comes from correctly assessing and acting on risk, not by attempting to predict the
future course of the market. Incorrectly assessing risk potentially leads to a painful loss of money. In addition to
traditional asset management, CIFG also designs, implements and monitors various model strategies. Many CIFG clients
have assets managed using one or more of these proprietary models. The models are more fully discussed in Item 8.
We manage our portfolios by acting on the current market environment for risk, valuation, economic growth, investor
sentiment, and relative strength. Our investment decisions are based on a monthly review of the portfolio unless global
and/or portfolio specific
events require a more frequent review. We tailor our investment advice to your needs based on
a financial profile you complete at the onset of our relationship.
Asset management services are provided on a “discretionary” basis. When CIFG is engaged to provide asset
management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset
allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may
involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any
time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security
type. You will receive written or electronic confirmations from your account custodian after any changes are made to
your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a
discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the
client accounts) as well as an Investment Management Agreement that outlines the responsibilities of both the client
and CIFG.
In certain limited circumstances, and in the discretion of the firm, a client may engage the firm to provide investment
management services on a non-discretionary basis. This means the firm monitors the accounts in the same way as for
discretionary services. The difference is that changes to your account will not be made until we have confirmed with
you (either verbally or in writing) that our proposed change is acceptable to you.
Wrap Program
CIFG may include certain transactional costs in the client’s management fee. This arrangement is referred to a “Wrap
Program”. For accounts in the Wrap Program, CIFG pays a fee to the account custodian based on the transactions
executed through the Wrap Program, thus taking on many of the clients’ transactions cost. Fees included in the wrap
fee include transaction fees for the purchase or sale of securities, but do not include expenses related to the use of
margin, wire transfer fees, the fees charged to shareholders of mutual funds or ETFs, mark-ups and mark-downs,
spreads, odd-lot differentials, fees charged by regulatory agencies, and any transaction fees for securities trades
executed by a broker-dealer other than the account custodian. Expenses for the management fees of third party
managers are also not included in the Wrap Program, and to the extent utilized, you will be responsible for such fees.
Because CIFG will be managing the assets of wrap fee program clients the same way as other non-wrap fee program
clients, the use of external portfolio managers within the wrap program is expected to be limited. To the extent a third
party manager is utilized, the fees payable to such managers will not be included in the wrap program. Therefore, there
is no difference between how CIFG manages wrap free accounts and how CIFG manages other accounts.
Because of the nature of a wrap fee program, where wrap fees are not tied to an account’s frequency of trading and
apply to generally all assets in the account, the wrap fee program client may pay more or less than if the client had
compensated CIFG outside of the wrap fee program. For example, if a client’s account is rarely traded, the transaction
fees the client would have paid would be minimal, thus limiting the benefits of “wrapping” management fees and
transaction fees. Clients whose accounts will be rarely traded should carefully consider whether the Wrap Program is
appropriate. Clients are not required to participate in the Wrap Program. CIFG receives a portion of the wrap fee for our
services.
CIFG does not engage other portfolio managers to manage assets within the wrap fee program. To the extent a third
party manager is utilized, the fees payable to such managers will not be included in the wrap program. CIFG is the sole
portfolio manager in the wrap program, which means that CIFG receives a portion of the wrap fee for our
services. Transaction fees are paid to various broker-dealers, mutual funds and ETFs. The remainder of the wrap fee is
the management fee payable to CIFG. As discussed more fully in the wrap brochure, the transaction fees paid to the
account custodian are based on a fixed rate that is based on the total amount of assets CIFG clients have in custody with
the account custodian, where the rate drops as the amount of assets in custody increase. Accordingly, CIFG does not
receive greater compensation for placing or not placing trades. However, CIFG does have an incentive to recommend
the account custodian to clients in order to reduce the fixed fee for transactions. CIFG attempts to mitigate this conflict
by requiring that the firm’s employees acknowledge their fiduciary duty to place client interests ahead of their own,
evaluating all aspects, including the wrap program asset-based transaction pricing when considering what broker-
dealers to recommend.
CIFG will receive no additional compensation for offering the wrap fee program.
Please see the separate Wrap Fee Brochure for a more complete description of the Wrap Program.
Pooled Investment Vehicle
CIFG acts as the investment manager for a pooled investment vehicle, Rocky Mountain Capital Fund, LP (Rocky
Mountain). The investment program of Rocky Mountain involves the investment of assets, both directly and indirectly in
a select group of privately sourced debt instruments. Clients may be invited to invest in the private placement, but only
if the respective investment is appropriate for the client. Capstone Investment Financial Group, LLC charges a
management fee to the private placement (please see Item 5 for details). The assets in the pooled vehicle are managed
in accordance with its offering documents. Clients invested in the pooled vehicle should consult that vehicle’s offering
documents.
Services offered to Unaffiliated Investment Advisors
In some cases, we provide sub-advice to unaffiliated investment advisors to assist them with management of a portion
of their assets. This advice may be similar or different than the advice we provide to clients.
In one instance, with Meld Financial, Inc., we provide investment subadvice and our primary owner, James Cornehlsen,
is also an owner of the firm. This is a conflict of interest.
Assets under Management
As of December 2022, CIFG has $104.545.159 in discretionary assets under management and $4.048.658 in non-
discretionary assets under management.