Firm Description
Caplan Financial Group, LLC (“CFG”) is a limited liability company formed on February 1,
2002, in the state of Maryland. CFG became registered as an Investment Advisory Firm on
February 1, 2002. CFG is owned by Mitchell Caplan, who is also its Managing Member.
CFG offers its clients investment advisory services and financial planning services. The firm’s
compensation is derived from fees paid directly by clients. The firm does not receive
commissions based on the clients’ purchases of securities. No referral fees are paid or accepted.
As discussed below, Mitchell Caplan, individually, may earn commissions from the sale of
insurance products.
Assets under management of CFG are held by independent custodians. Fidelity Investments is
the primary custodian holding CFG directed investments. Clients may hold investments with
other custodians, such as TD Ameritrade and Charles Schwab, and still fall under the
management of CFG.
Principal Owners
Mitchell Caplan is 100% owner of Caplan Financial Group, LLC.
Types of Advisory Services
CFG offers investment advisory/asset management services and financial planning services.
INVESTMENT ADVISORY SERVICES
Clients can engage CFG to provide discretionary or non-discretionary investment advisory
services on a fee basis. CFG primarily allocates client investment assets among open-end mutual
funds in accordance with the client’s designated investment objective(s). Many of these mutual
funds will contain common stocks or other equity positions that offer the possibility of
substantial gains in value but also contain the risk of loss of value. Some of these mutual funds
are comprised of bonds or other fixed income securities that have a lower potential for gain but
also a lower possibility of losing value. The division of client assets between equity/risk
positions and conservative/bond vehicles varies on a case-by-case basis in accordance with the
client’s investment objectives and risk tolerance. Information on our investment strategies is
located under Item 8 on page 14.
CFG generally reviews portfolios with the client twice per year. These review meetings are
generally held on the month of the client’s birthdate and the month of the client’s half birthdate.
Clients who engage CFG on a non-discretionary investment advisory basis must be willing to
accept that CFG cannot affect any account transactions without obtaining prior consent to any
such transaction(s) from the client. Therefore, in the event CFG wishes to make changes to the
client’s investment portfolio at a time when the client is unavailable, CFG will be unable to
effect such transactions.
FINANCIAL PLANNING SERVICES
CFG may provide financial planning services. Customarily, clients will engage CFG to provide
an initial financial plan and ongoing financial planning services and updates.
If requested by the client, the initial financial plan, as well as ongoing financial planning services
and updates, will address the following eight areas of planning:
1. GOAL SETTING AND ONGOING MONITORING AND ASSESSMENT
• Identify short, medium and long term financial goals.
• Evaluate progress towards goals and recommend changes as needed.
2. INVESTMENT ANALYSIS
• Provide asset allocation services regarding investments not directly managed by
Caplan Financial Group such as 401(k) retirement plan assets.
• Recommend investments to implement the agreed-upon allocation.
• Recommend changes to investment selections to implement the revised portfolio
allocation.
3. INSURANCE REVIEW*
• Review the amount and type of all life insurance policies.
• Review ownership and beneficiary designations and their integration with current
estate plan.
• Review amount and type of individual and group long-term disability insurance.
• Review need for long-term care insurance as well as benefit amount and type of
policy.
4. EMPLOYEE BENEFIT UPDATE
• Review new and amended employee benefits programs offered by employer.
• Discuss how to utilize available benefits.
• Review and consider changes to elections for retirement plans, insurance options,
flexible spending accounts, and other benefits.
• Review stock options, restricted stock, and other deferred compensation programs.
5. TAX PLANNING UPDATE**
• Review previous tax planning recommendations.
• Discuss implementation issues.
• Evaluate effectiveness of implemented planning.
• Discuss relevant changes in the tax laws.
• Consider revised or new tax planning ideas.
• Discuss involvement of other service providers (e.g., CPA and attorney).
• Set or revise plan to implement established goals.
6. ESTATE PLANNING UPDATE**
• Review previous estate planning recommendations.
• Discuss implementation issues.
• Discuss relevant changes in family status and personal goals that may impact
planning.
• Consider need for asset protection planning.
• Discuss changes in the tax laws.
• Consider revised or new planning ideas.
• Discuss involvement of other service providers (e.g., CPA and attorney).
• Set or revise plan to implement established goals.
7. REAL ESTATE/REAL ESTATE FINANCING ANALYSIS
• Discuss planning issues related to purchase of a new primary residence, vacation
property and/or investment real estate property.
• Review terms of current financing programs and consider alternatives.
• Participate, as requested, in phone conferences and meetings with mortgage lenders.
8. OTHER
• Discuss planning for pending or recent inheritance.
• Review planning considerations for providing care to parents and other relatives
including any requirements for financial assistance.
• Discuss impact of any planned or possible significant life events and consider impact
on current and future financial plans.
*Caplan Financial Group’s review of your insurance program is limited to a review of and/or
recommendations relating to the adequacy of life, long-term disability, and long-term care insurance only. In
conjunction with ongoing financial planning, we recommend that clients consult their current insurance
agent(s) to discuss the adequacy of homeowners, automobile, excess liability, health, major medical, business
liability, errors and omissions and/or any other property and casualty, business liability or related type
insurance. Although Mitchell Caplan, in his individual capacity, is a licensed life and health insurance
broker, clients do not need to effect insurance transactions through Mitchell Caplan. See Item 10 on
page 15 for additional information.
**All listed services require the input of a licensed tax and/or legal professional. Clients understand that any
tax and/or legal strategies discussed must be approved by their tax and legal advisors prior to implementation.
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Important Disclosures Related to Advisory Services
Limitations when providing Financial Planning Services. To the extent requested by the client,
CFG may provide services regarding non-investment related matters, such as estate planning, tax
planning, insurance, etc. Neither CFG nor its representatives serve as an attorney and no portion
of CFG’s services should be construed as legal services. Accordingly, CFG does not prepare
estate planning documents. To the extent requested by a client, CFG may recommend the
services of other professionals for certain non-investment implementation purposes (e.g.,
attorneys, accountants, insurance agents, identity theft prevention specialists, and others),
including CFG’s representatives in their separate and individual capacities as licensed insurance
agents and/or certified public accountants as disclosed in Item 10 below. The client is under no
obligation to engage the services of any such recommended professional. The client retains
absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from CFG.
If the client engages any recommended unaffiliated professional and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional (i.e. attorney, accountant,
insurance agent, etc.), and not CFG, shall be responsible for the quality and competency of the
services provided.
Separate Contracts and Services. Generally, clients will engage CFG for each of the above two
types of advisory services in a separate and distinct contract for each service. Many clients have
agreed separately for both investment advisory services and financial planning services. In some
cases, clients will engage CFG for only one of the two aforementioned areas of planning of
services.
Fees for Advice Provided Outside the Scope of Contract with CFG. When requested, CFG may
furnish advice to clients in an area of investment management or financial planning services
outside the scope of the single contract that the client has signed with CFG for a specific area.
At its discretion, CFG may not charge a separate fee for providing services outside the scope of
the single contract agreement between client and CFG. The decision as to whether to require a
separate fee be paid and/or contract signed for services is based on various objective and
subjective factors.
Retirement Account Rollovers – Conflict of Interest. A client or prospective client 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) roll over 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 consequences). If CFG
recommends that a client roll over their retirement plan assets into an account to be managed by
CFG, such a recommendation creates a conflict of interest if CFG will earn new (or increase its
current) compensation as a result of the rollover. If CFG provides a recommendation as to
whether a client should engage in a rollover or not, CFG is acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by CFG.
Disclosure Statement. A copy of CFG’s written disclosure statement and client relationship
summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to
each client prior to, or contemporaneously with, the execution of the applicable form of client
agreement.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are
available directly to the public. Therefore, a prospective client can obtain many of the funds that
may be utilized by CFG independent of engaging CFG as an investment advisor. However, if a
prospective client determines to do so, he/she will not receive CFG’s initial and ongoing
investment advisory services. In addition to CFG’s investment advisory fee described below, and
transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual
fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management
fees and other fund expenses).
Portfolio Activity. CFG has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, CFG will review client portfolios on an
ongoing basis to determine if any changes are necessary based upon various factors, including,
but not limited to, investment performance, fund manager tenure, style drift, account
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these
factors, there may be extended periods of time when CFG determines that changes to a client’s
portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees
described below during periods of account inactivity.
Cash Positions. CFG treats cash as an asset class. As such, all cash positions (money markets,
etc.) shall be included as part of assets under management for purposes of calculating CFG’s
advisory fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), CFG may maintain cash positions for defensive purposes. In addition, while assets are
maintained in cash, such amounts could miss market advances. Depending upon current yields,
at any point in time, CFG’s advisory fee could exceed the interest paid by the client’s money
market fund.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from account
transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep
account. The yield on the sweep account is generally lower than those available in money market
accounts. To help mitigate this issue, CFG generally purchases a higher yielding money market
fund available on the custodian’s platform with cash proceeds or deposits, unless CFG
reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period
to purchase additional investments for the client’s account. Exceptions and/or modifications can
and will occur with respect to all or a portion of the cash balances for various reasons, including,
but not limited to, the amount of dispersion between the sweep account and a money market
fund, an indication from the client of an imminent need for such cash, or the client has a
demonstrated history of writing checks from the account.
Cybersecurity Risk. The information technology systems and networks that CFG and its third-
party service providers use to provide services to CFG’s clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional
actions that could cause significant interruptions in CFG’s operations and result in the
unauthorized acquisition or use of clients’ confidential or non-public personal information.
Clients and CFG are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur losses, including for example: financial losses, cost and
reputational damage to respond to regulatory obligations, other costs associated with corrective
measures, and loss from damage or interruption to systems. Although CFG has established its
systems to reduce the risk of cybersecurity incidents from coming to fruition, there is no
guarantee that these efforts will always be successful, especially considering that CFG does not
directly control the cybersecurity measures and policies employed by third-party service
providers. Clients could incur similar adverse consequences resulting from cybersecurity
incidents that more directly affect issuers of securities in which those clients invest, broker-
dealers, qualified custodians, governmental and other regulatory authorities, exchange and other
financial market operators, or other financial institutions.
Data Aggregation. CFG has a contractual agreements with Morningstar ByAllAccounts and
eMoney Advisor Platform to provide data aggregation services for clients who elect to have
investment, insurance, and other financial data aggregated in CFG’s portal and on their financial
statements. The data aggregation services allow CFG to see and analyze financial data for
investment accounts, insurance policies, 401(k) plans, 529 plans, and various other financial
vehicles without having to ask the client to provide updated statements and data.
In conjunction with the services provided by the data aggregation services, CFG may also
provide periodic asset allocation and/or investment performance reporting services, which can
incorporate all of the client’s investment assets, including those investment assets that are not
part of the assets managed by CFG (the “Excluded Assets”). CFG’s service relative to the
Excluded Assets is limited to reporting services only, which does not include investment
implementation. Because CFG does not have trading authority for the Excluded Assets, to the
extent applicable to the nature of the Excluded Assets (assets over which the client maintains
trading authority vs. trading authority designated to another investment professional), the client
(and/or the other investment professional), and not CFG, shall be exclusively responsible for
directly implementing any recommendations relative to the Excluded Assets. The client and/or
their other advisors that maintain trading authority, and not CFG, shall be exclusively
responsible for the investment performance of the Excluded Assets. CFG shall not be responsible
for any implementation error (timing, trading, etc.) relative to the Excluded Assets.
Tailored Relationships
Whether a client has contracted with CFG to provide investment management services, financial
planning services, or both offerings, all recommendations and planning are tailored to the
individual needs of the client. Client goals and objectives are clarified in meetings and used to
determine the course of action for each individual client. There is no “one size fits all” portfolio,
allocation or financial plan. Portfolio allocation and all recommendations are customized for
each client relationship.
It remains the client’s responsibility to promptly notify CFG if there are changes in their
financial situation or investment objectives for the purpose of reviewing, evaluating or revising
previous recommendations and/or services.
In performing its services, CFG shall not be required to verify any information received from the
client or from the client’s other professionals, and is expressly authorized to rely thereon.
Clients may impose restrictions on investing in certain types of securities. Clients must clearly
communicate the type of securities that they wish to exclude from the assets managed by CFG.
Types of Agreements
One of CFG’s core offerings is discretionary investment management services. Clients contract
for this service offering by signing a Discretionary Investment Management Agreement. CFG
will provide a sample contract to any prospective client considering asset management services.
See page 14 in this Brochure for details regarding CFG’s investment strategy.
CFG’s second offering is financial planning services. Among the topics on which CFG may
provide advice are taxation, insurance, estate planning, retirement cash flow analysis and college
funding strategies. Please see pages 6 and 7 in this Brochure which provide a list of potential
areas of planning that CFG can consult on as well as disclaimers for areas we are not qualified to
consult on for clients.
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Wrap Fee Program
CFG does not participate in, manage, or sponsor any wrap fee programs.
Managed Assets
As of December 31, 2022, CFG had $290,373,664 in assets under management on a
discretionary basis and $2,376,748 in assets under management on a non-discretionary basis.