Firm Description
The Adviser provides comprehensive wealth management services to a broad range of clients,
including individuals, high net worth clients, pensions, profit sharing and 401(k) plans,
corporations, business entities, trusts, estates, foundations, and charitable organizations. The
Adviser provides continuous investment advice and management based upon the individual
needs and objectives of each client. The Adviser was founded in 2015.
Principal Owner
The Adviser is privately held, and its employees own all the outstanding stock of the firm. The
principal owners of the Adviser are Todd Krieg and the Todd M. Krieg 2020 Trust.
Types of Advisory Services
Pegasus provides discretionary and non-discretionary investment advisory services to its clients.
Clients will enter into an Investment Management Agreement (“IMA”) with the Adviser
indicating the type of advisory services to be provided. At the beginning of the relationship, the
client will work closely with one of the Adviser’s Investment Advisory Representatives (“IAR”) to
develop an Investment Policy Statement (“IPS”). The IPS outlines the investment goals and
objectives and the risk tolerance of the client. The IPS includes general guidelines as to how the
IAR will make investment decisions to meet the goals of the client. These general guidelines
cover such things as the relative proportion of debt securities and equity securities within the
overall asset allocation of a client portfolio.
Discretionary Investment Advisory Services
For clients who grant the Adviser complete discretionary authority, the Adviser will develop an
asset allocation strategy that will incorporate investing in stocks, bonds, mutual funds, and
exchange-traded funds (“ETFs”).
Stocks and Bonds
Pegasus has entered into agreements with various third-party managers to act as sub-adviser to
separately managed accounts (“SMA”), some of which may provide model portfolios to
Pegasus. Under these agreements, the Adviser offers clients various types of programs
sponsored by these third-party managers. These programs generally have account minimum
requirements that will vary from manager to manager. A complete description of the third-
party manager’s services, fee schedules and account minimums will be disclosed in the third-
party manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at
the time an agreement for services is executed. When the Adviser engages a third-party
manager to invest on behalf of the client, the SMA will be traded by either the third-party
manager or, if a model portfolio is provided, by the Adviser. In both cases, all research,
investment selections and portfolio decisions are the responsibility of the third-party manager,
not the Adviser. Performance reporting will be the responsibility of the Adviser for all SMAs.
Such performance reports will be provided quarterly to the client.
Mutual Funds and ETFs
In addition to SMAs, the Adviser will allocate client assets to mutual funds and ETFs to ensure
the client’s risk profile is met. The Adviser uses mutual funds and ETFs to appropriately weight
sectors, geographies, market-caps and styles to ensure portfolios accurately reflect opportunity
within capital market assumptions over time.
The Adviser looks at the underlying assets in a mutual fund or ETF to determine if there is
significant overlap in the underlying investments held in other fund(s) and SMAs in the client’s
portfolio.
Non-discretionary Investment Advisory Services
Private Investments
Pegasus provides non-discretionary investment advice with respect to Private Investments.
Private Investments include illiquid investments such as private real estate, private debt, and
private equity funds. Private Investments selected for recommendation need to meet several
quantitative and qualitative criteria established by the Adviser as described in Item 8. Pegasus
will recommend Private Investments based on the investment objectives and risk tolerance of
the client and only to those clients that meet the definitions of Accredited Investor or Qualified
Purchaser. The IAR will assist the client in completing the necessary subscription agreements
and will work with the client to facilitate the funding of Private Investments recommended by
the Adviser.
Other Investments
The Adviser will monitor a client’s activities and accounts maintained by other investment
advisers. Pegasus will not have any authority or ability to purchase or sell any assets held within
these accounts. The accounts are monitored as non-discretionary assets of the Adviser.
Financial Planning
The Adviser also offers financial planning
services to clients. Financial planning services include
financial position planning, retirement planning, business planning, charitable giving, trust and
estate planning, benefit plan advice, manager due diligence and preparation of a financial plan.
All financial planning advice is provided on a non-discretionary basis and clients are responsible
for deciding what advice to act upon. Clients are advised that it remains their responsibility to
promptly notify the Adviser of any change in their financial situation or investment objectives
for the purpose of reviewing, evaluating or revising the Adviser’s recommendations and/or
services. There is no additional fee to clients for financial planning services.
Pension Consulting
The Adviser also provides several advisory services separately or in combination. While the
primary clients for these services will be pension, profit sharing and 401(k) plans, the Adviser
offers these services, where appropriate, to individuals and trusts, estates, and charitable
organizations. Pension Consulting Services are comprised of four distinct services. Clients will
choose to use any or all these services.
IPS Preparation:
The Adviser 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 plan. The Adviser 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:
The Adviser assists plan sponsors in constructing appropriate asset allocation models. Pegasus
will then review various mutual funds (both index and managed) to determine which
investments are appropriate to implement the client’s IPS. The number of investments to be
recommended will be determined by the client, based on the IPS.
Monitoring of Investment Performance:
The Adviser monitors client investments continually, based on the procedures and timing
intervals delineated in the Investment Policy Statement. Although Pegasus is not involved in
any way in the purchase or sale of these investments, the Adviser will supervise the client’s
portfolio and will make recommendations to the client as market factors and the client’s needs
dictate.
Employee Communications:
For pension, profit sharing and 401(k) plan clients with individual plan participants exercising
control over assets in their own account (‘’self-directed plans’’), the Adviser also provides
periodic educational support and investment workshops designed for the plan participants
when the plan sponsor engages the Adviser to provide these services. The nature of the topics
to be covered will be determined by the Adviser and the client under the guidelines established
in ERISA Section 404(c). The educational support and investment workshops will NOT provide
plan participants with individualized, tailored investment advice or individualized, tailored asset
allocation recommendations.
Consulting Services
On a limited basis the Adviser will provide clients investment advice on isolated areas of
concern such as estate planning, real estate, retirement planning, or any other specific topic.
Additionally, the Adviser may provide advice on non-securities matters in connection with the
rendering of estate planning, insurance, real estate, and/or annuity advice. In these cases, the
client may be required to select investment managers, broker-dealer and/or insurance
companies for the implementation of consulting recommendations. If a client’s needs include
brokerage and/or other financial services, the Adviser may recommend the use of one of
several investment managers, brokers, banks, custodians, insurance companies or other
financial professionals. The client must independently evaluate these independent firms before
opening an account or transacting business and have the right to effect business through any
firm the client chooses. The client is under no obligation to follow the consulting advice that the
Adviser provides.
Wrap Fee Programs
The Adviser does not place any client assets into a Wrap Fee Program.
Client Assets
As of December 31, 2023, total regulatory assets under management were approximately $3.09
billion. Client assets managed on a discretionary basis totaled approximately $2.45 billion;
client assets managed on a non-discretionary basis totaled approximately $632 million. Pegasus
had assets under advisement of approximately $3.14 billion.