1024 East Grand River Avenue Brighton, Michigan Office: Fax:

Transcription

1 FORM ADV PART 2A CAITLIN JOHN, LLC Item 1 Cver Page Fiduciary (N) In law, a persn in a psitin f authrity whm the law bligates t act slely n behalf f the party he/she represents in gd faith Missin T help Client(s) and their families plan, implement, and successfully manage every phase f pre and pst retirement life Abut Us Caitlin Jhn, LLC is a private wealth management firm based in Brightn, Michigan As a Registered Investment Advisry Firm, we wrk with bth individual and institutinal investrs Our hlistic wealth management services enable Client(s) t enjy the many benefits f ur decades f experience, white glve service, industry leading slutins, and fiduciary bligatin At Caitlin Jhn, each relatinship begins with an understanding f yur unique circumstances tday and visin fr the future Building upn this fundatin f mutual understanding, yu and yur Advisr can begin t map the path twards yur successful retirement Caitlin Jhn Private Wealth Management prvides each f ur Client(s) ur best thinking fr them utilizing transparent premier slutins As fiduciaries, we are bund t always act exclusively in yur best interests and this cmmitment permeates everything we d Yur Caitlin Jhn Advisr will wrk with yu, as bth architect and engineer, t design yur hlistic wealth slutins t cnfidently address specific bjectives spanning investments, cashflw, planning, preservatin, tax efficiency, and advanced wealth transfer 1024 East Grand River Avenue Brightn, Michigan Office: Fax: wwwcaitlinjhncm Brchure Updated On September 24, 2018 This brchure prvides infrmatin abut the qualificatins and business practices f Caitlin Jhn, LLC als referred t as Caitlin Jhn Private Wealth Management, Caitlin Jhn, CJ, r Firm If yu have any questins abut the cntents f this brchure, please cntact us at r by t inf@cjadvisrcm The infrmatin in this brchure has nt been apprved r verified by the United States Securities and Exchange Cmmissin r by any state securities authrity Using the term Registered Investment Advisr des nt imply a certain level f skill r training Additinal infrmatin abut Caitlin Jhn, LLC als is available n the SEC s website at wwwadviserinfsecgv Yu can search this site by a unique identifying number, knwn as a CRD number Our Firm s CRD number is Caitlin Jhn, LLC All Rights Reserved

2 FORM ADV PART 2A Item 2 - Material Changes This Firm Brchure, dated September 24, 2018, is ur disclsure dcument prepared accrding t the SEC s requirements and rules This Item will be used t prvide ur Client(s) with a summary f new and/r updated infrmatin We will infrm yu f the revisin(s) based n the nature f the updated infrmatin Cnsistent with the rules, we will ensure that yu receive a summary f any material changes t this and subsequent Brchures within 120 days f the clse f ur business fiscal year Furthermre, we will prvide yu with ther interim disclsures abut material changes as necessary Material Changes since the last update n April 20, 2018: 1) Update f Assets Under Management t reflect the mst current status Item 3 - Table f Cntents Item 1 Cver Page 1 Item 2 - Material Changes 2 Item 3 - Table f Cntents 2 Item 4 - Advisry Business 2 Item 5 - A&B - Fees and Cmpensatin 5 Item 6 Perfrmance-Based Fees and Side-By-Side Management 9 Item 7 - Types f Client(s) 9 Item 8 - Methds f Analysis, Investment Strategies, and Risk f Lss 9 Item 9 - Disciplinary Infrmatin 11 Item 10 - Other Financial Industry Activities and Affiliatins 11 Item 11 - Cde f Ethics, Participatin r Interest in Client Transactins and Persnal Trading 12 Item 12 - Brkerage Practices 13 Item 13 - Review f Accunts 13 Item 14 - Client Referrals and Other Cmpensatin 14 Item 15 Custdy 14 Item 16 - Investment Discretin 14 Item 17 - Vting Client Securities 14 Item 18 - Financial Infrmatin 14 Item 4 - Advisry Business A Advisry Firm With currently ver 34 years f financial services experience, Rnald J Briggs Jr FIC, CRPC launched Caitlin Jhn, LLC, als referred t as Caitlin Jhn Private Wealth Management, Caitlin Jhn, r CJ, and was apprved as a Registered Investment Advisry Firm with the State f Michigan n January 01, 2011 and is registered with the United States Securities and Exchange Cmmissin (SEC) as f June 26, 2017 Rnald J Briggs Jr is Caitlin Jhn s Principal and cntrls 100% f this cmpany CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 2

3 B Advisry Services The wner, Rnald J Briggs Jr, created Caitlin Jhn Private Wealth Management t ffer persnalized advisry services that may utilize investment management, financial planning, and insurance prducts t deliver services in accrdance with its fiduciary bligatin t each Client(s) based n their needs, gals, bjectives and risk tlerances Client(s) will interface with individuals assciated with CJ t prvide its investment advisry services These individuals are apprpriately licensed, qualified, and authrized t prvide advisry services n behalf f CJ Such individuals are knwn as Investment Adviser Representative, als referred t as an Advisr r IAR CJ prvides tw primary financial advisry services: 1) investment management services, and 2) financial planning and cnsulting services CJ manages Client(s) persnal investment assets, bth nn-ira and IRA plans, 401K, 403B plans, pensin and prfit sharing plans, trusts and estates CJ may als manage investment assets held by charitable rganizatins, crpratins and ther business entities as Client(s) NOTE: In rder t cmmunicate effectively with the Client(s), the Client(s) Advisr will verify, in writing, if the Client(s) have access t r the internet fr all crrespndences If a Client(s) disclses that they d nt have access t an r the internet, all crrespndences will be mailed C Individual Services CJ is able t prvide individual Client(s) tailred hlistic financial planning and investment management services Investment Management Services Befre investing, CJ Advisrs will establish with each Client(s), an understanding f their investment gals, risk tlerance, and any ther pertinent factrs by having the Client(s) cmplete an Asset Allcatin Questinnaire (AAQ), Investment Plicy Statement (IPS), and Investment Advisry Agreement (IAA) CJ may als utilize risk analysis and financial planning sftware t assist in determining a Client(s) risk tlerance, investment gals, and bjectives CJ Client(s) may impse reasnable restrictins n the management f their accunt, including the designatin f specific securities r a specific categry f securities that shuld nt be purchased fr the accunt r that shuld be sld if held in the accunt, and may reasnably mdify such restrictins frm time t time The Client(s) may chse t establish their accunts, implementing these restrictins, n individual securities, categries, r sectrs CJ reserves the right t decline t accept an accunt if it determines, in its sle discretin, that the restrictins impsed by the Client(s) are nt reasnable The Client(s) understands and acknwledges that any restrictins placed n the management f their accunt impsed by the Client(s), including restrictins in a categry r categries f securities due t scial screening r ther restrictins, may cause accunt perfrmance t deviate frm the perfrmance f the Client(s) chsen cre prtfli The Client(s), at any time, can accept r decline any investment recmmendatins frm their Advisr Because sme types f investments invlve certain additinal degrees f risk, they will nly be implemented/recmmended when cnsistent with the Client(s) stated investment bjectives, tlerance fr risk, liquidity, and suitability CJ manages these advisry accunts n a discretinary basis Accunt supervisin is guided by the Client(s) stated gals, bjectives, and risk tlerance Once the Client(s) prtfli has been established, the Advisr will review the prtfli annually, at a minimum, with their Client(s) Client(s) are nt restricted n the number f times they can meet with their Advisr If the Client(s) chses t meet with their Advisr prir t r during an annual review f their accunt, a rebalance f the Client(s) prtfli can be recmmended based n the Client(s) individual needs CJ ffers seminars n general investment strategies, retirement planning principles, and/r t highlight particular services such as financial planning r investment management These seminars are given t assist in educating the general public and t fster greater financial literacy Seminars are pen t any type f Client(s) and attendance is free f charge The materials, if any, prvided during such seminars and educatinal services are intended t be exclusively educatinal in nature and t prvide seminar participants with infrmatin regarding certain investmentrelated and retirement planning tpics The infrmatin cntained in the seminar materials is nt intended as specific individual investment advice and des nt purprt t meet the investment bjectives r needs f specific individuals r accunts An individual wh attends a seminar will be cnsidered CJ s Client fr the purpse f seminar participatin; hwever, such classificatin shall be limited t the duratin f the seminar Such seminar attendees d nt cntinue t be CJ s Client fllwing cmpletin f the seminar unless CJ subsequently prvides frmalized investment advisry services t the attendees Financial Planning and Cnsulting Services CJ is able t prvide Client(s) financial plans t efficiently quantify Client(s) lng term financial needs and bjectives Fr each Client(s), the financial planning prcess begins with defining the Client(s) current verall financial circumstance and their lng-term financial gals, bjectives, and needs Once this understanding has been established between CJ s Advisr and their Client(s), CJ s Advisr will design and prpse a custm financial plan Depending n the cmplexity f the Client(s) plan, financial planning sftware CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 3

4 may be used fr their Client(s) The Advisr will explain t each Client(s) their psitin, research, and recmmendatins within each prpsal t maximize the value and understanding f CJ s prpsed services CJ Advisrs will als wrk with Client(s) ther accredited financial prfessinals where applicable and desired by the Client(s) t further maximize the value f each financial plan Each Plan will be based n the infrmatin the Client(s) supplies, alng with the cmplexity and number f planning mdules needed t generate a thrugh financial plan fr the Client(s) The Advisr s initial infrmatin gathering prcess may include but nt limited t the fllwing planning mdule items: Asset Allcatin Review Asset Allcatin Recmmendatins (ie Investment advice) Benefits Planning Budgeting Cash Management Cash Flw Analysis Cllege Savings Planning Estate Planning Funding Plans, Liquidity, and Majr Expense Assistance General Financial Planning Insurance Review Legacy Planning Lng-Term Care Review Miscellaneus Services Retirement Planning Risk Management and Insurance Analysis Tax-Efficiency Evaluatin Tax Planning In sme cases, CJ may refer the Client(s) t ther vetted independent prfessinals, such as attrneys r accuntants fr their nn-cnflicted expertise CJ will wrk and cmmunicate with such independent prfessinals, nly with the Client(s) specific written authrizatin A cnflict f interest exists between the interests f the CJ and the interests f the Client(s) because CJ receives cmpensatin fr financial plans The Client(s) is under n bligatin t act upn the Advisr s recmmendatins If the Client(s) chses t act n any f the recmmendatins, the Client(s) is under n bligatin t affect any transactins thrugh CJ It is ultimately the respnsibility f the Client(s) t implement the cmpnents f each Financial Plan CJ Advisrs will nly recmmend financial planning services in accrdance with their fiduciary bligatin t Client(s) The Client(s) is under n bligatin t initiate the Onging Financial Planning and Cnsulting Services nce the initial Financial Planning and Cnsulting Services have been cmpleted Once the Client(s) initial Financial Planning and Cnsulting Services has been cmpleted, the Client(s) may chse Caitlin Jhn s Onging Financial Planning Services fr further assistance The Onging Financial Plan and dynamic access, where applicable, fr the Client(s) will be delivered within thirty (30) days f signing the Onging Financial Planning and Cnsulting Services Agreement The Client(s) may terminate the Onging Financial Planning and Cnsulting Services Agreement fr a full refund within five (5) business days f signing the Onging Financial Planning and Cnsulting Services Agreement A pr rata refund is available at any time befre delivery f the financial plan with payment due nly fr wrk cmpleted prir t terminatin After delivery f the initial financial plan and access t the Client prtal, the Client(s) may terminate their subscriptin at any time If the Client(s) terminates their subscriptin, such terminatin will becme effective at the end f the current mnthly billing perid alng with their prtal access t their financial plan Retirement Plan Services CJ ffers investment management services t pensin and prfit sharing plans fr a fee Pensin and prfit sharing plans are generally rganized as a trust, investing the assets f plan participants Plan participants are the individuals enrlled in pensin r prfit sharing plans seeking individualized advice independent f their plans spnsr Fr accunts gverned by the Emplyee Retirement Incme Security Act f 1974, as amended ( ERISA ), CJ is a fiduciary t the plan under Sectin 3(38) f ERISA In prviding its services, the sle standard f care impsed upn us is t act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters wuld use in the cnduct f an enterprise f a like character and with like aims As a registered investment adviser, CJ and it s IARs wrk clsely with plan spnsr and participants prviding advisry services and supprt t them Additinally, CJ and its IARs emplys TPIAs t specifically prvide prtfli management services f the plan assets Bth CJ and the TPIA act in a fiduciary capacity under Sectin 3(38) f ERISA As a 3(38) advisr and TPIA t the plan, we are authrized by the Client(s) t exercise ur best judgment in all aspects f wrking with the plan spnsr and their plan participants fr the plan assets We d nt hld any assets f the plan but rather such assets are held by an independent custdian selected by the Client(s) As an advisr wrking with TPIAs fr the plan, it is ur duty t help create an investment guideline (selectin, remval and replacement f the plan s investment ptins), select investments ptins, supprt and service the plan as needed CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 4

5 D Investment Accunt Management CJ makes available and suggests a variety f investment management services t best meet Client(s) diverse specific investment needs Each Client(s) may utilize tailred prtflis spanning varius strategies including Wrapped Separately Managed Accunts (SMA) and an Unwrapped Fee Prgram (als referred t as Advisr Managed Prtflis ) t best match their gals and risk tlerance Separately Managed Accunts Separately Managed Accunts are made available t Client(s) within the Wrap Fee Prgram t prvide Client(s) access t dynamic strategies ffered by Third-Party Prtfli Managers Each SMA has a unique investment strategy and will be cnsidered fr investment n a per Client(s) basis based n specific individual factrs CJ has the ability t access additinal SMAs, as apprpriate, t best meet Client(s) needs CJ Wrap Fee Prgram CJ receives a prtin f the fees charged frm the Wrap Fee Prgram CJ charges a single transparent fee fr investment management, custdial services, financial advisry services, and Third-Party Mney Management Fees are paid frm the CJ Wrap Fee Prgram t each Third-Party Prtfli Manager fr sub-advisry services prvided t the Client(s) These fees vary frm firm t firm, based n factrs such as strategy type, cmplexity, trading frequency, and ttal assets managed by each Third-Party Prtfli Manager acting as sub-advisrs fr CJ Client(s) If these services were rendered separately, the Client(s) may be able t secure a lwer ttal cst r higher ttal cst, depending n the sub-advisry services being used CJ believes the nature f ur Wrap Fee Prgram is cnsistent with the Fiduciary bligatin wed t each Client(s) This is because CJ Advisrs are able t select frm the suite f varius Third-Party Prtfli Managers made available n the custdial platfrms utilized by the Firm withut such decisins adversely affecting the Client(s) ttal wealth management csts In additin, CJ is incentivized t cntrl investment management expense t within the pricing f ur Wrap Fee Prgram All Third-Party Prtfli Managers that the Firm recmmends t its Client(s) must either be registered as investment advisrs with the Securities and Exchange Cmmissin r with the apprpriate state authrity(ies) Unwrapped Fee Prgram Advisr Managed CJ Client(s) may authrize their Advisr t manage all r a prtin f their investment prtfli using an Unwrapped Fee Prgram, als referred t as Advisr Managed Prtflis In this prgram, high frequency trading per the Client(s) prtfli, is managed slely by the Advisr and nrmally des nt invlve any ther Third-Party Prtfli Managers but may blend individual securities alng with mdels managed by Third Party Prtfli Managers Each Client(s) Advisr may utilize 1, 2, 3 times leveraged and sectr-based exchange-traded funds (ETFs), cmmn stck, preferred stck, cnvertible stcks, mutual funds, warrants, rights, crprate bnds, municipal bnds, gvernment bnds, ntes, ptins, r bills when authrized and in accrdance with each Client(s) risk tlerance, gals and bjectives E Assets Under Management As f September 24, 2018, the ttal amunt f assets under management is apprximately $156,430,094 All assets managed will be n a discretinary r nn-discretinary basis Currently, there is apprximately $156,430,094 in discretinary assets under management and $000 in nndiscretinary assets under management Item 5 - A&B - Fees and Cmpensatin Advisry Services Cmpensatin & Fee Deductin The quarterly CJ Management and advisry Fee is calculated based n the frmulas detailed herein and agreed upn in each Client(s) Investment Advisry Agreement (IAA) CJ maintains varius fee structures in rder t best accmmdate the wrk, services and asset management style f its advisrs necessary in an attempt t best reach each individual Client(s) gals, bjective and risk tlerance The structure fr a wrapped accunt, managed via Third-Party Prtfli Managers, is referenced belw in Table 1 - Wrap Fee Prgram ; refer t the Firm s, Wrap Fee Prgram Brchure The structure fr an unwrapped accunt, as an Advisr-managed prtfli, is referenced in Table 2 - Unwrapped Fee Prgram ; refer t the Firm s, Unwrapped Investment Advisry Agreement In the specific case f a transitining Advisr, the new advisr may request t maintain the same Client(s) fee structure implemented at the previus firm The Firm will draft an investment advisry agreement that accmmdates and maintains this fee structure fr ease f Client(s) transitin This structure will cntinue until the Advisr intrduces ther methds f prtfli management and a subsequent fee structure that aligns accrdingly This may include, Wrapped r Unwrapped: Tapered, Tiered, in arrears r in advance fee structures, they may als have varius billing rates which d nt exceed 248% This will be specifically utlined in the Firm s Investment Advisry Agreement (IAA) fr Transitining Advisrs and their Client(s) The Advisr may utilize varius methds f management in accrdance with a Client(s) unique bjectives and accunt types Additinally, the Advisr may utilize a cmbinatin f different methds t best serve the Client(s) needs CJ s Management Fees are calculated as a per annum fee equal t the fllwing applicable percentages f the Client(s) assets under management, which shall be billed in advance fr the quarter are based n the ending accunt balance as f the last business day f the prir quarter mnth Fr Client(s) electing TD Ameritrade Institutinal as their CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 5

6 custdian, the management fees are calculated by the CJ accunting team Fr Client(s) electing Fli Institutinal, A divisin f FOLIOfn Investments, Inc, as their custdian, the management fees are calculated by Fli Institutinal s billing team Such billing shall ccur within 15 days f the quarter beginning either by direct payment by the Custdian frm the Client(s) Custdial Accunt r frm anther persnal accunt f the Client(s) paid t CJ CJ Advisrs reserve the right t negtiate fees with Client(s) based n the cmplexity f the Client(s) needs and level f service required Client(s) have the ptin t have the advisry fee deducted directly frm their assets being managed r billed t them and paid frm anther surce per the fee schedule listed in the Wrap and/r the Unwrapped Fee Prgram Client(s) f CJ lcated in the state f Wiscnsin shall receive a quarterly invice frm CJ ten (10) business days prir t any fees being debited frm their accunt This pre-billing ntificatin specifies the Client(s) assets under management, annual fee level, the frmula used t calculate fees, the dllar amunt t be debited Cmparable services vary, and lwer fees fr cmparable services may be available frm ther surces In rder t cmply with the Califrnia Cde f Regulatins (CCR Sectin (J)), we are disclsing that lwer fees fr cmparable services may be available frm ther surces If a Client(s) wishes t dispute a fee amunt, the frmula used fr calculatin, r any ther issues relating t the CJ quarterly billing, the Client(s) may d s by cntacting their Advisr, call and ask fr the Client Relatins Manager, r yur dispute t inf@cjadvisrcm Once the dispute has been cnfirmed, a manual crrectin will be made accrdingly t the Client(s) accunt Wrap Fee Prgram CJ acts as spnsr and Advisr fr the CJ Wrap Fee Prgram Fli Institutinal, TD Ameritrade Institutinal, and Kingdm Trust are the nly custdians utilized fr Client(s) in the Wrap Fee Prgram Kingdm Trust is nly used when assets can nt be held in Fli Institutinal r TD Ameritrade Institutinal The types f assets that utilize Kingdm Trust wuld be unregistered REITs, individual bnds, self-directed IRA(s), etc CJ reserves the right t negtiated fees t Client(s) Client(s) may als chse t have their prtfli blended between a wrapped and unwrapped fee structure based upn their gals, bjectives, and risk tlerance They may chse t blend specific mdels, individual hldings, and third-party mney manager making up their ttal prtfli This prgram may cst the Client(s) mre r less than purchasing securities r advisry services separately The factrs that bear upn the relative cst f the prgram may include sme r all f the fllwing: Trading activity n behalf f the Client(s) accunt Windw trading fees Recrd keeping services Administrative services Advisry and financial plan services Prprietary prtfli management services Custdial fees Cmparable services vary, and lwer fees fr cmparable services may be available frm ther surces CJ is cmpensated frm the fees paid thrugh the Wrap Fee Prgram CJs cmpensatin is the remainder f the fees paid after all included csts and expenses are paid fr Prtfli Managers f sub accunts within the Wrap Fee Prgram are cmpensated between basis pints fr prviding prtfli management services Fli custdial fees are inclusive f windw trading fees, recrd keeping, and administrative services Client(s) wishing t place a nnwindw individual securities trade will have a separate cst These additinal csts are referred t as Step Out Fees Please see the Step Out Fees sectin n this page fr further cst details Wrap fees withdrawn frm the Client(s) accunt by Fli Intuitinal will be calculated by the Fli Institutinal s Billing Department Wrap fees withdrawn frm the Client(s) accunt by TD Ameritrade Institutinal will be calculated by CJ s accunting department Please reference Table 1 Wrapped Fee Prgram belw t calculate the quarterly fee Table 1 Wrap Fee Prgram Managed Assets Percentage f Assets Assets under $250, % Assets between $250,001 - $500,00099 Assets between $500,001 - $750,00099 Assets between $750,001 - $1,000,00099 Assets between $1,000,001 - $1,500,00099 Assets between $1,500,001 - $2,000,00099 Assets between $2,000,001 - $3,000, % 228% 218% 208% 198% 188% $3,000,00100 and abve 178% CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 6

7 The Wrap Fee Prgram will be calculated as fllws: The ttal amunt f assets per Client(s) accunt at end f calendar quarter x annual percentage f assets charged t Client(s) 4 quarters = quarterly amunt deducted frm Client(s) accunt Fr example, assume the ending ttal amunt f a Client(s) accunt in a calendar quarter was $100,000 which puts the Client(s) in the 248% managed asset range In this case, the amunt f the deducted quarterly Client(s) fee wuld be $62000 Calculatin: $100,000 x 248% = $2, quarters = $62000 The Advisr recmmending the Wrap Fee Prgram t the Client(s) receives cmpensatin as a result f the Client(s) participatin in the prgram The prtin f the cmpensatin may be mre than what the persn wuld receive if the Client(s) participated in ther prgrams r paid separately fr ther advice r services, therefre the persn may have a financial incentive t recmmend the Wrap Fee Prgram ver ther prgrams r services The minimum amunt required t pen an accunt is $250,000 fr asset management services Hwever, in its sle discretin, the CJ Advisr may waive r lwer this minimum Advisrs that elect t lwer the required minimum amunt t pen an accunt fr a Client(s) will specify that a minimum quarterly fee f $7500 will take precedence ver the Caitlin Jhn, LLC Management Fee, shuld the result be a greater dllar amunt than that prvided fr in Table 1 Further explanatin: Fr example, assume the ending ttal amunt f a Client(s) accunt in a calendar quarter was $10,000 which puts the Client(s) in the 248% managed asset range In this case, the amunt f the deducted quarterly Client(s) fee wuld be $7500 Calculatin: $10,000 x 248% = $ quarters = $6200 Since $6200 is less than the minimum quarterly fee f $7500, $7500 will be assessed t meet the minimum custdial quarterly charge f $5000 and CJ management fee f $2500/quarter Step ut fees Client(s) participating in the Wrap Fee Prgram may als incur additinal charges, where applicable, such as Annual IRA fee and ETF internal expense fees Additinally, Client(s) may purchase individual securities utside f the Wrap fee prgram The Client(s) will incur a $395 charge fr the purchase and $395 fr the sale f each individual securities the Client(s) chses t hld utside f Third- Party managed mdels and allcatins CJ and its Advisrs receives n cmpensatin frm these charges/fees stated abve Unwrapped Fee Prgram CJ ffers an Unwrapped Fee Prgram cnsidered t be Advisr managed fr any Client(s) requesting high frequency trading Custmarily, a Third-Party Mney Managers is nt utilized but instead, the CJ Advisr manages a prtfli f individual stcks, ETFs, r mutual funds themselves n behalf f their Client(s) There are sme instances where a lw cst Third-Party Mney Manager r SMA may be recmmended by the Advisr as part f the verall Client(s) prtfli CJ reserves the right t negtiated fees t Client(s) Client(s) may als chse t have their prtfli blended between a wrapped and unwrapped fee structure based upn their gals, bjectives, and risk tlerance They may chse t blend specific mdels, individual hldings, and third-party mney managers which will make up their ttal prtfli This prgram may cst the Client(s) mre r less than purchasing securities r advisry services separately Please reference Table 2 Unwrapped Fee Prgram t calculate the quarterly fee Table 2 Unwrapped Fee Prgram Managed Assets Percentage f Assets Assets Under $2,500, % Assets Between $2,500,001 - $5,000, % Assets Over $5,000, % The Unwrapped Fee Prgram (referred t as Advisr Managed Prtflis ) will be calculated as fllws: The ttal amunt f assets per Client(s) accunt at end f calendar quarter x annual percentage f assets charged t Client(s) 4 quarters = quarterly amunt deducted frm Client(s) accunt Fr example, assume the ending ttal amunt f a Client(s) accunt in a calendar quarter was $1,000,000 which puts the Client(s) in the 15% managed asset range In this case, the amunt f the deducted quarterly Client(s) fee wuld be $3,75000 (($1,000,000 x 150%) = $15, quarters = $3,75000) Client(s) participating in the Unwrapped Fee Prgram may als incur additinal charges such as SRO/SEC fees, trading fees, custdial fees, IRA fees, transactinal fees, ETF, and mutual fund expenses fr underlying hldings CJ is nt cmpensated in any way by these additinal fees described abve These fees are incidental t rendered Advisry services prvided by yur CJ Advisr CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 7

8 C Other Types f Fees/Expenses 1 Financial Planning Services Fees When a Client(s) wishes t engage a CJ Advisr fr financial planning services, the Client(s) will cmpensate CJ based upn an agreed fee schedule that is n an hurly fee, fixed fee, r nging financial planning fee The fee structure is decided by the Client(s) and is finalized by signing the Financial Planning and Cnsulting Services Agreement r the Onging Financial Planning and Cnsulting Services Agreement a) Fixed Fee Financial Planning Services are ffered based n a negtiable fixed fee based n cmplexity and unique needs fr each Client(s) The cmplete financial plan cnsists f the number f mdules chsen by the Client(s) A detailed example f mdules can be fund listed under 4C Individual Services sub-grup Financial Planning and Cnsulting Services Ttal cst fr the financial plan is nt slely based n the Client(s) ttal asset under management and is nly used as a cnsideratin t determine the cmplexity f mdule chices The Advisr will als take int cnsideratin the number f meetings required t cmplete the plan, alng with the Client(s) request fr a number f face t face meetings per year with the Advisr (Unlimited phne calls are always welcmed) An additinal cnsideratin fr the cst f the plan is due t the rbust capability f the sftware which can include all utside investment assets, banking, insurance, and annuities alng with a private dcument vault tailred fr each Client(s) All f this can all be incrprated int the sftware s algrithm alng with Advisr versight f the Client(s) ttal financial plan nce cmpleted Once the financial planning and cnsulting services agreement have been reviewed and signed by the Client(s), payments are received in tw installments: ne-half at the cmmencement f the planning prcess with the balance f the final payment due upn delivery f the cmpleted plan The Client(s) may terminate the Financial Planning and Cnsulting Services Agreement fr a full refund within five (5) business days f signing the agreement A pr rata refund is available at any time befre delivery f the financial plan with payment due nly fr wrk cmpleted prir t terminatin Financial plans will be cmpleted and delivered within thirty (30) days f signing the agreement b) Hurly Fee Financial Planning Services are ffered based n an hurly fee negtiated with the Client(s) The number f hurs estimated will be based n cmplexity and unique Client(s) needs Fr Client(s) engaging financial planning services n an hurly basis, the initial payment will prvide fr half f the estimated hurs required t cmplete the plan The final payment will reflect the ttal amunt f hurs wrked, less the initial payment The Client(s) may terminate the Financial Planning and Cnsulting Services Agreement fr a full refund within five (5) business days f signing the agreement A pr rata refund is available at any time befre delivery f the financial plan with payment due nly fr wrk cmpleted prir t terminatin Financial plans will be cmpleted and delivered within thirty (30) days f signing the agreement 2 Onging Financial Planning and Cnsulting Services Fees Once the financial plan is cmpleted, the Client(s) may chse t pen and maintain a dynamic real-time encrypted prtal t access their financial plan using a selected sftware prgram This is cnsidered t be part f ur nging financial planning sftware service that is ffered t Client(s) that cmplete a financial plan with CJ The Onging Financial Planning and Cnsulting Services Agreement is based n the cmplexity, level f service, unlimited changes/updates, Client(s) specific factrs and general nging financial planning supprt/cnsultatin by their Advisr Client(s) will be inviced n the first business day f each mnth t maintain this nging financial planning service CJ will nt charge any accunt pening fee, set-up, r clsing fee 3 Plan Spnsr Fees Plan Spnsr Fees Our fee fr investment advisry services fr plan spnsrs varies based n the amunt f assets we manage Typically, fees are a fixed percentage f the assets under management Our cmpensatin range is 118% t 148% inclusive f the TPIA service fees f the assets under management at the end f a given calendar quarter D Advanced Fee Payment & Refund Structure CJ s Management Fees are calculated as a per annum fee equal t the fllwing applicable percentages f the Client(s) assets under management, calculated the last day f each quarter CJ shall bill quarterly in advance fr the new quarter based n the prir quarter s ending accunt balance n last day f the quarter After a ntificatin has been sent t the Client(s), billing shall ccur within 15 days f the quarter beginning by direct debit by the Custdian frm the Client(s) Custdial Accunt t CJ in accrdance with the payment prtcls fr each Custdian described belw Client(s) als have the ptin t have the advisry fees deducted frm their assets being managed r billed t them and paid frm anther surce per the fee schedule listed in the Wrap and/r the Unwrapped Fee Prgram The Investment Advisry Agreement between CJ and the Client(s) may be mdified upn such terms as may be mutually agreed upn in writing The Investment Advisry Agreement is terminable within five (5) business days, withut penalty, frm the date f acceptance Either party may terminate the Investment Advisry Agreement by written ntice t the ther, and any such terminatin will be CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 8

9 effective five (5) business days after receipt f such written ntice CJ will ntify the applicable Custdian abut the terminatin Once a Client(s) accunt has been transferred (clsed), the Client(s) will be cntacted by CJ t facilitate a pr rata fee refund CJ will refund the pr rata fees t the Client(s) custdial accunt t be swept t Client(s) chsen financial institutin The pr-rata refund amunt wed t Client(s) will be calculated as fllws: Fees paid t CJ during the current calendar quarter divided ( ) by the number f days in the current quarter multiplied(x) by the number f days remaining until the end f current calendar quarter equals the amunt t be refunded Fr example, assume the amunt paid t CJ in the current calendar quarter was $2,500, there are 90 days in this example calendar quarter (depending n the calendar year, there may be mre r less than 90 days The exact number f days in the quarter will be used t calculate the refund), and the Agreement is terminated with 45 days remaining in the quarter In that case, the amunt f the refund wuld be $1,250 ($2, days = $2778 per day x 45 days = $1,250) *NOTE: Ntice f terminatin by Client(s) shuld be sent t the Firm at 1024 E Grand River Ave, Brightn, MI r t inf@cjadvisrcm E Other Cmpensatin CJ and its Advisrs d nt receive any cmmissins r additinal cmpensatin fr any mutual fund r variable annuity 12b-1 fees r any ther securities related transactins CJ may wrk with a custdian/brker dealer that can receive and reimburse/credit t the Client(s) fr the variable annuity 12b-1 fees In this instance nly, CJ wuld charge the Client(s) an apprpriate advisry fee fr the versight, advisry services, and sub-accunt management f the variable annuity, as part f the Client(s) ttal managed prtfli Advisrs f CJ acting in a fiduciary capacity may recmmend the use f fixed life insurance r annuity prducts based n the specific circumstances, gals, bjectives, and risk tlerance f each Client(s) Client(s) are under n bligatin t act n the Advisrs insurance recmmendatins, but this may generate an additinal review f the Client(s) gals and bjectives based n this decisin If a Client(s) elects t act n any recmmendatin, the Client(s) is under n bligatin t affect the transactins thrugh their CJ Advisr If the Client(s) des act n this recmmendatin, the advisr will receive cmmissin cmpensatin directly frm the insurance carrier This cmpensatin is in additin t assetbased fees that are currently being charged fr advisry and prtfli management services Item 6 Perfrmance-Based Fees and Side-By-Side Management CJ des nt accept r charge perfrmance based r side by side management fees at this time Item 7 - Types f Client(s) We ffer services t accredited investrs, qualified purchasers and retail Client(s) as defined by the federal securities laws These may include, but nt limited t, the fllwing types f Client(s): Individuals High net wrth individuals & family ffices Operating businesses Private investment cmpanies Small t mid-sized banks and credit unins Trusts Spnsrs f private cmpany defined cntributin plans (qualified and nn-qualified) Nn-prfit entities Plan participants (403(b), 457, 401(k)) Municipalities Nn-prfit entities Multinatinal citizens Nn-US citizens The minimum amunt required t pen an accunt is $250,000 fr asset management services Hwever, in its sle discretin, the CJ Advisr may waive r lwer this minimum Fr retail Client(s), accunts must be held at a qualified custdian designated fr retail Client(s) The respective custdian has its wn accunt pening, maintenance and cmpliance requirements Each accunt must be apprved by the respective custdian Fr institutinal Client(s), the Cmpany may be retained as an investment manager ver a Client(s) accunt at a financial institutin which the Cmpany may r may nt have an existing relatinship The minimum accunt size fr institutinal Client(s) is $1,000,000, unless therwise agreed by management and the respective custdian The Firm may enter int agreements with ther registered investment adviser firms t serve as a sub-adviser The assets managed are reprted as AUM f the primary adviser and nt included in ur AUM We may refer t these assets as assets under advisement Item 8 - Methds f Analysis, Investment Strategies, and Risk f Lss A&B Methds f Analysis / Investment Strategies Investing in securities invlves risk f lss which ur Client(s) shuld be prepared t bear N amunt f analysis r diversificatin can whlly accunt fr r eliminate market CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 9

10 vlatility and systematic risk Investment strategies will be subject t methds f analysis by the Third-Party Prtfli Manager, the Firm and/r its s advisrs as described herein Methds f Analysis Methds f analysis and investment strategies include charting, fundamental, tactical, cyclical and technical analysis, independent research, and asset allcatin implementatin strategies Prprietary prgrams and sftware may be used t identify market pints where either buy r sell signals are recgnized These signals assist the prtfli managers and/r IAR s in implementing the specified management strategies f the varius managed prgrams Quantitative analysis can als be used when analyzing securities This analysis uses current and histrical pricing infrmatin t help identify trends in bth the dmestic and freign equity and fixed incme markets Technical indicatrs such as mving averages and trend lines may be further used t identify entry and exit pints Varius fundamental data such as verall ecnmic cnditins, industry utlk, interest rates and plitical climate are als cnsidered CJ and its Advisrs methds f analysis may include sme f the fllwing criteria: analysis pertaining t the selectin f Third-Party Prtfli Managers t be made available within the Wrapped Fee Prgram, as well as the fllwing criteria: incme, risk tlerance, sectr, market capitalizatin, lng term needs and bjectives Investment Strategy: CJ s Client(s) may participate in a variety f strategies which generally fall int either f the fllwing tw categries: active and passive investment management a) Active Investment Management Active asset management entails cntinuus evaluatin and investment selectin in accrdance with the gals and bjectives f each Client(s) CJ Client(s) have tw ptins t participate in active investment management, Advisr Managed Prtflis r Third-Party managed accunts within the CJ Wrap Fee prgram Fr detailed infrmatin n active investment management with CJ, see Item 4 Advisry Business Investment Accunt Management abve b) Passive Investment Management Passive asset management entails selecting investments based n apprpriateness with regards t each Client(s) risk tlerance, gals, and bjectives Once investments are chsen, they are usually held fr the lng-term and replaced nly as apprpriate with regards t changing market cnditins and each Client(s) risk tlerance, gals, and bjectives Fr detailed infrmatin n passive investment management with CJ, see Item 4 Advisry Business Investment Management abve CJ and its advisrs may use several investment strategies t implement investment advice prvided t ur Client(s), including but nt limited t: Lng-term purchases (t hld mre than ne year) Shrt-term purchases Trading Relative value Lng/shrt ETFs & Mutual Funds Tactical rtatin Sectr rtatin Margin transactins Optins writing, including spread strategies CJ als analyzes the type f investment strategy each Third- Party Prtfli Manager prvides, if that strategy is an effective vehicle t achieve particular investment bjectives if the strategy is within the brad risk tlerances f ur Client(s) Third-Party Prtfli Manager Review: Third-Party Prtfli managers prviding sub-advisry services t CJ Client(s) are reviewed at least annually in accrdance with the criteria described belw in rder t determine their nging utility t CJ Advisrs and their Client(s) In particular, CJ will emphasize in its review the criteria relating t underlying expenses, relative perfrmance, limitatins f strategies, and crrelatins t ther Third- Party Prtfli Managers CJ will cntinually seek t prvide its Client(s) with a suite f tactically and sectr diverse Third- Party prtfli managers Perfrmance Histry: CJ evaluates the relative and abslute perfrmance histry f each prspective Third-Party Prtfli Manager t examine perfrmance during varius market cnditins CJ will nly wrk with Third-Party Prtfli Managers that have at least 3 years f prtfli management experience Investment Cst: CJ examines the cst f underlying hldings, where applicable, in rder t determine if a given Third-Party Prtfli Manager has any cnflicts f interest r if a Third- Party Prtfli Manager has an excessively expensive strategy Because ur managed fees are wrapped, CJ lks t minimize any expense which cannt be reimbursed such as ETF and mutual fund expenses Third-Party Prtfli Managers using 1X s, 2X s, 3X s times leveraged and sectrbased exchange-traded funds (ETFs) will be evaluated t ensure they are seeking t minimize excessive csts r have the reasnable expectatin f delivering alpha ver time t ffset such csts Ttal Assets Under Management: CJ will evaluate the level f assets managed by each Third- Party Prtfli Manager and within each strategy ffered by each Third-Party prtfli manager This is t determine the lng-term viability and limitatins f each strategy which may arise frm either insufficient capital r excess capital being assciated with each strategy MAR Rati: CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 10

11 CJ may examine each Third-Party Prtfli Manager s MAR rati t determine the relative value f annual perfrmance realized against the largest drawdwn each strategy has had ver a specific perid f time Each Third-Party Prtfli Manager emplys their wn methds f analysis in prviding sub advisry services; each Third-Party Prtfli Manager s specific methds f analysis may be fund in their Frm ADV 2 Brchure r Prspectus which is made available t ur Client(s) via ur website wwwcaitlinjhncm r in a paper versin if requested C Risk f Lss Investment Risk An investr shuld cnsider the investment bjective, risks, charges, and expenses carefully befre investing Investing, including int the strategies and analyses detailed abve, invlves expsure t risks These include the fllwing: Interest Rate Risk Geplitical Risk Plitical Risk Default Risk Regulatry Risk Civil r Criminal Actin Risk Liquidity Risk Manager Errr Business Cycle Risk Macrecnmic Risk Systematic Risk Risk f Lss f Principal Other Nnsystematic Risks Any and all perfrmance data quted represents past perfrmance frm actual accunts selected n the basis f the lngest hlding perid Past perfrmance is nt a guarantee, r an implied guarantee, f future results Current perfrmance may vary frm the perfrmance quted Investment returns and principal value will fluctuate There is n guarantee that any investment mdel will achieve its stated investment bjectives An investment is subject t the risks listed abve, including the pssible lss f the principal amunt invested Investments are nt FDIC insured, may lse value, and have n bank guarantees Item 9 - Disciplinary Infrmatin N disciplinary, judgment, criminal, regulatry, r civil actin r event has been taken against CJ, r any wner, partner, Advisr r emplyee There have been n cmplaints, barring r suspensin frm investment related services CJ perfrms due diligence by cnducting a backgrund check n all assciated wners, partners, and emplyees Each individual licensed Advisr is respnsible fr accurately and truthfully cmpleting a Frm U-4 and prmpt disclsure t the Firm f any and all disciplinary r legal actins taken against them CJ will als update the Frm ADV2A and 2B Brchures t reflect this material change Item 10 - Other Financial Industry Activities and Affiliatins A Brker-Dealer Affiliatin CJ des nt have anyne registered r pending t register as a brker-dealer r a registered representative f a brkerdealer B Cmmdity Affiliatin CJ des nt have anyne registered r pending t register as a futures cmmissin merchant, cmmdity pl peratr, a cmmdity trading advisr, r an assciated persn f the freging entities C Relatinships/Cnflicts Advisrs f CJ may be licensed and appinted t sell insurance prducts thrugh varius insurance cmpanies These insurance prducts whether it is life insurance, disability insurance r fixed r indexed annuities, may be ffered thrugh Elite Advisrs Edge, Inc t assist CJ Advisrs with fulfilling their Client(s) planning needs, as necessary Advisrs will receive cmmissins and incentives paid directly frm the insurance carrier These cmmissins are in additin t and separate frm the advisry fee This creates a mnetary cnflict thrugh the benefit f cmmn cntrl f Elite Advisrs Edge which is wned by Kristin Briggs, spuse f Rnald J Briggs, Jr In additin, Rnald J Briggs, Jr is the Funder, Principal, Chief Cmpliance Officer, Chief Investment Strategist, and Investment Advisr Representative f Caitlin Jhn, LLC (CJ) These cnflicts are mitigated because CJ des nt receive any cmmissin cmpensatin fr the sale f insurance prducts by its Advisrs As a fiduciary, the Advisr will always d what is in the best interest f the Client(s), independent f the amunt f cmmissin received CJ Client(s) are nt required t purchase any insurance prducts recmmended by the CJ Advisr, but this may generate an additinal review f the Client(s) gals and bjectives based n this decisin Rnald J Briggs, Jr is the C-Funder, Owner, Chief Executive Officer, Chief Cmpliance Officer, & Chief Investment Strategist f A Smarter Way T Invest, Inc (ASWTI) A Smarter Way t Invest, Inc is a Third-Party Investment Advisr (TPIA) and a SEC registered investment advisry firm which slely ffers asset management services t Registered Investment Advisry Firms, and grants such Firms access t ASWTI s varius prprietary and nnprprietary dynamic asset allcatin strategies and investment mdels CJ Advisrs may als utilize ASWTI s prtfli management services fr their Client(s) This may create a cnflict due t the fact that Rnald J Briggs, Jr is als the wner f CJ and will financially benefit frm Client(s) assets placed with ASWTI This cnflict can be mitigated as CJ Advisrs wrking with their Client(s) can chse frm numerus third-party mney managers/subadvisrs, mutual funds, etc, that are made available t them CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 11

12 thrugh the tw (2) custdial platfrms (Fli Institutinal & TD Ameritrade Institutinal) CJ will nt refer Client(s) t A Smarter Way t Invest, Inc r any ther Sub-Advisr r Third-Party Mney Manager that is nt apprpriately registered Rnald J Briggs Jr is Chief Investment Strategist, Chief Cmpliance Officer and C-Funder f Guardian Pinte Private Wealth Management, LLC ( GPPWM ), a SEC Registered Investment Advisr Firm This affiliatin is nt material t CJ s business r its Client(s) because GPPWM des nt in any way engage with the Advisrs r Advisry Client(s) f CJ All Service and Supprt Emplyees f the abve 3 registered Advisry Firms are emplyed thrugh a single management cmpany called Entry Pint Advisr Netwrk ( EPAN ) EPAN is wned under cmmn cntrl by Kristen Briggs spuse f Rnald J Briggs, Jr EPAN emplys business develpment advisrs t recruit, supprt, and service IARs f CJ and GP These business develpment advisrs are bth W-2 and 1099 emplyees and receive cmpensatin in the frm f salary and cmmissins Part f this cmpensatin may reflect cmpensatin based n ttal AUM f the IARs they supprt D Advisr Recmmendatins CJ des nt recmmend r select ther investment advisrs fr their Client(s) CJ des nt receive cmpensatin directly r indirectly frm utside Advisrs Item 11 - Cde f Ethics, Participatin r Interest in Client Transactins and Persnal Trading A Cde f Ethics Our Firm has adpted a Cde f Ethics which sets frth high ethical standards f business cnduct that we require f ur emplyees, including cmpliance with applicable federal securities laws Caitlin Jhn Private Wealth Management and ur persnnel we a duty f lyalty, fairness and gd faith twards ur Client(s), and have an bligatin t adhere nt nly t the specific prvisins f the Cde f Ethics but t the general principles that guide the Cde Our Cde f Ethics includes plicies and prcedures fr the review f quarterly securities transactins reprts as well as initial and annual securities hldings reprts that must be submitted by the Firm s access persns Amng ther things, ur Cde f Ethics als requires the prir apprval f any acquisitin f securities in a limited ffering (eg, private placement) r an initial public ffering Our cde als prvides fr versight, enfrcement, and recrd-keeping prvisins by the CJ Cmpliance Department Caitlin Jhn Private Wealth Management's Cde f Ethics further includes the Firm's plicy prhibiting the use f material nn-public infrmatin relating t Client(s) accunt prtflis r transactins f CJ While we d nt believe that we have any particular access t nn-public infrmatin, all emplyees are reminded that such infrmatin may nt be used in a persnal r prfessinal capacity Any emplyee r Advisrs will nt disclse any nn-public infrmatin relating t the business r peratins f CJ unless prperly authrized t d s A cpy f ur Cde f Ethics is available t ur advisry Client(s) and prspective Client(s) Yu may request a cpy by sent t inf@cjadvisrcm, r by calling us at (810) B Material Financial Interest and Cnflict f Interest Caitlin Jhn Private Wealth Management r individuals assciated with ur Firm may buy securities fr the Firm r fr themselves frm ur advisry Client(s); r sell securities wned by the Firm r the individual(s) t ur advisry Client(s) We will ensure, hwever, that such transactins are cnducted in cmpliance with all the prvisins f Sectin 206(3) f the Advisers Act gverning principal transactins t advisry Client(s) CJ, its Advisrs, and emplyees currently have n material financial interest in any publicly traded securities Advisrs shall avid any actin, whether fr persnal prfit r therwise, that results in a cnflict f interest with CJ r its Client(s) accunts, r which may be therwise detrimental t the interests f Client(s) f CJ They will nt attempt t imprperly use influence fr their persnal benefit In additin, access persns f ur Firm are required t reprt all persnal securities transactins cnducted in ur affiliated mutual fund(s) Our Cde f Ethics is designed t assure that the persnal securities transactins, activities and interests f ur emplyees will nt interfere with (i) making decisins in the best interest f advisry Client(s) and (ii) implementing such decisins while, at the same time, allwing emplyees t invest fr their wn accunts Our Firm and/r individuals assciated with ur Firm may buy r sell fr their persnal accunts securities identical t r different frm thse recmmended t ur Client(s) In additin, any related persn(s) may have an interest r psitin in a certain security(ies) which may als be recmmended t a Client(s) It is the expressed plicy f ur Firm that n persn emplyed by us may purchase r sell any security prir t a transactin(s) being implemented fr an advisry accunt, thereby preventing such emplyee(s) frm benefiting frm transactins placed n behalf f advisry accunts CJADV2A_ Caitlin Jhn, LLC All Rights Reserved Page 12