Firm Information
Founded in March 2017 as a Delaware limited liability company (“LLC”), Cresset Asset Management, LLC
(the “Adviser,” “Cresset,” “us,” “we,” or “our”) is a registered investment adviser with the U.S. Securities
and Exchange Commission (“SEC”). The Adviser also conducts business under the names of “Meristem |
Cresset,” “TRUE Cresset,” and “TRUE Cresset | Sports + Entertainment.”
Cresset is a majority-owned subsidiary of Cresset Capital Management, LLC, which is a majority-owned
subsidiary of Cresset Manager, LLC, which was founded and is controlled by Avy Stein and Eric Becker.
Cresset is operated by Doug Regan, Co-Chairman, William Rudnick, Executive Managing Director, Chief
Legal Officer, Jack Ablin, Chief Investment Officer, Michael Costabile, Chief Financial Officer, Randall
Conte, Chief Operating Officer, Jessica Malkin, Chief Marketing Officer, and Robert Pagliuco, Chief
Compliance Officer.
Advisory Services Offered
We provide investment advisory and family office services to retail investors which includes individuals, high
net worth individuals, trusts, estates, retirement plans, charitable organizations, corporations, other business
entities, and pooled investment vehicles (each referred to as a “Client”). Our advisory services are provided
to individual, joint, retirement, trust and estate, and separately managed accounts (“SMAs”) (each a Client
“account” or “portfolio”). These services include wealth management, which generally encompass a
combination of comprehensive financial planning, family office services and consulting strategies, as well as
discretionary and non-discretionary investment advisory services (further described below).
Cresset also provides these services on a stand-alone basis and can be offered as a wrap fee program where
we combine securities transaction fees and other fees with the costs associated with our investment advisory
services (further described below).
Client Account Management
Investment Advisory Services
Prior to engaging Cresset to provide investment advisory services, each Client is required to enter into one or
more agreements with the Adviser (a “Client Agreement”) that define the terms, conditions, authority, and
responsibilities of the Adviser and the Client. Pursuant to such Client Agreements, Cresset provides continuous
and ongoing investment advice and portfolio management services. These services may include:
• Establishing an Investment Strategy – Cresset, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and destinations.
• Asset Allocation – Cresset will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Cresset will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Cresset will provide investment management and
ongoing oversight of the Client’s investment portfolio.
Discretionary vs. Non-Discretionary Account Management
Clients retain Cresset on both a discretionary and non-discretionary basis. In providing discretionary
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management services, Cresset maintains a limited power of attorney to effect securities transactions (in
accordance with Client’s investment objectives set forth in the respective Client Agreement) on behalf of a
Client without such Client’s prior approval of each specific transaction. Clients reserve the right to limit our
discretionary authority by providing us with a written communication that details restrictions and other
guidelines. Such discretionary authority and engagement will continue until a Client notifies us otherwise in
writing.
We also offer our services on a non-discretionary basis, whereby we are required to obtain Client consent
prior to executing any trades on a Client’s behalf. Accordingly, the Client maintains the ultimate decision-
making authority regarding the purchase or sale of investments in its account. Prospective clients should be
aware that pursuant to such non-discretionary arrangement, Cresset could be limited in aggregating such trades
with other Client orders, which could result in the execution of a transaction at a different price from those
aggregated trades.
Monitoring and Adjustment
Our advice and services are tailored to meet each Client’s individual needs, life circumstances and investment
goals. We engage with each Client to determine their investment objectives, risk tolerance, time horizons and
liquidity needs. Clients can impose reasonable restrictions and guidelines on investing in certain securities,
types of securities or industry sectors.
As part of our services, we monitor investments and securities in Client accounts on a regular and continuous
basis, unless otherwise agreed, and make adjustments and reallocations as necessary due to changes in market
conditions and the Client’s circumstances as communicated to us. We also meet with Clients at least annually,
or more frequently, depending on each Client’s needs.
Private Fund Clients
Cresset also provides discretionary investment management services to a number of private investment funds
that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”)
and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”)
(each such Client referred to as a “Fund”). The Funds make investments across a variety of asset classes,
including public equities of various types (e.g., small-cap, large-cap and non-U.S. securities), specialized fixed
income, hedge funds, private real estate holdings and private equity investments. Certain Funds are sub-
managed by specialty professional investment managers that we research and recommend.
Such discretionary investment management services primarily consist of sourcing, structuring, and negotiating
investments and dispositions, monitoring the performance of investments and performing certain
administrative services. These services are detailed in the offering documents for each Fund, which include
as applicable, operating agreements, private placement memorandum and/or term sheets, subscription
agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”).
The Adviser manages each Fund based on the investment objectives, policies and guidelines as set forth in
the respective Fund’s Offering Documents and not in accordance with the individual needs or objectives of
any particular investor therein. Each prospective investor interested in investing in a Fund is required to
complete a subscription agreement in which the prospective investor attests as to whether or not such
prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the
various risk factors associated with such an investment.
In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Adviser
has entered and could in the future enter into side letter or other written agreements with one or more Fund
investors which have the effect of establishing rights under, or altering, modifying, or changing the terms of
interest held by investors. Certain types of side letters create a conflict of interest among the Adviser and
investors, and/or between investors themselves.
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For more detailed information on investment objectives, policies, and guidelines, please refer to each
Fund’s Offering
Documents.
Financial Planning Services
Cresset also provides financial planning services as a component of its wealth management services or
pursuant to a financial planning or consulting agreement. Such services generally involve a comprehensive
evaluation of the Client’s financial situation by using currently known facts and variables. We create a
financial plan for the Client, which is designed to assist the Client achieve its financial goals and objectives.
From time-to-time, we also prepare reports at the Client’s request.
A financial plan typically addresses one or more of the following areas:
• Financial Position: Understanding a Client’s current financial situation. Sources of evaluation
include the Client’s income, expenses, assets and liabilities, among others.
• Investment Planning: Determining a suitable way to structure investments to meet the Client’s
financial goals, and determine the appropriate account type (e.g., joint tenants, IRA, Roth IRA)
• Income Tax Planning: Evaluating a Client’s current tax situation to help minimize the Client’s
taxes and find more profitable uses for any extra income generated.
• Retirement Planning: Assessing a Client’s retirement needs to help him/her determine how much
to accumulate, as well as distribution strategies designed to create a source of income during
retirement years.
• Credit Planning: Evaluating the Client’s credit needs.
• Insurance Planning and Risk Management: Evaluating the Client’s insurance needs and
reviewing insurance policies and the like.
• Estate Planning: Reviewing the Client’s cash needs at death, income needs of surviving
dependents, and estate planning goals.
• Education Planning: Reviewing the educational needs for the Client and his/her family, along with
planning for educational expenses.
We gather information through interviews and review of documents provided by the Client, including
questionnaires. Information gathered includes, among other things, the Client’s current financial status, future
goals, investment objectives, risk tolerance and family circumstances.
Typical financial planning services include one or more of each of the aforementioned service components.
A financial plan could require the services of a specialist such as an insurance specialist, attorney, or tax
accountant. From time-to-time, Cresset recommends to Clients certain third-party service providers, but the
Client is under no obligation to use any service provider recommended by us. Likewise, the Client is under
no obligation to act on our financial planning recommendations.
Family Office Services
Cresset also offers family office services which encompasses both strategic and tactical advisory consulting
including but not limited to:
• Culture, Values, and Vision Alignment
• Wealth Strategy, Asset Protection & Portfolio Implementation
• Family Governance & Decision Making
• Liquidity and Exit Planning
• Learning and Development
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• Philanthropic Consulting
• Tax Planning & Projections
• Cash and Liquidity Management
• Estate Planning
• Banking and Credit Consulting
• Lifestyle Services
Retirement Plan Advisory Services
Cresset also provides retirement plan advisory services to retirement plans (each a “Plan”) and their respective
company sponsors (the “Plan Sponsor”). Certain of these services are provided by Cresset serving in the
capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of
Cresset’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the
Adviser reasonably expects under the engagement.
The Adviser’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary
obligations to the Plan and its Plan participants. Each engagement is customized to the needs of the Plan and
Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Monitoring Services (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Trust Services
From time-to-time, Cresset will recommend certain trust services to its Clients through Cresset Trust Company,
LLC (“CTC”), an affiliate of the Adviser. In such case, the Client will be charged fees separate and apart from
the compensation paid to Cresset in exchange for its advisory services. However, no Client is obligated to use
the services of CTC and is free to engage the trust services of another non-affiliated trust company.
Other Advisory Services
On occasion, Cresset will engage a third party to provide the Client with class action related services. Clients
can opt out on a security specific basis or in its entirety by providing written notice to Cresset.
Wrap Fee Programs
Cresset sponsors and operates a wrap fee program (“Cresset One Fee Program”) whereby it serves as the sole
portfolio manager. As of October 2023, the Cresset One Fee Program is generally no longer offered to
new clients and continues only to be offered for the benefit of Clients currently in the program, closely
affiliated relationships to those Clients, and in certain extraordinary circumstances.
Under the Cresset One Fee Program, certain brokerage execution services, administrative expenses, and other
fees and expenses are combined and charged together along with the investment advisory fee paid to Cresset.
Accordingly, such program participants generally pay a higher or lower overall fee than if these services were
paid for separately, depending on the volume of trading and other fees associated with the Client account during
the year. For additional important information, please see Appendix 1 – “Wrap Fee Program Brochure,” which
is included as a supplement to this Brochure.
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Client Assets Under Management
As of December 31, 2023, Cresset manages $43,670,122,905 in Client assets – $42,917,610,822 of which are
managed on a discretionary basis and $752,512,083 of which are managed on a non-discretionary basis. Clients
may request more current information at any time by contacting the Adviser.
Client Assets under Supervision
An asset under supervision (“AUS”) is one that does not qualify as Assets Under Management, but on which
the Adviser would otherwise touch the asset in some manner on behalf of the Client. Examples include:
1. Provides analysis or includes the asset in reports to the Client,
2. Includes or considers the asset in the client’s financial, tax, estate plan, or as part of another provided
service or other arrangement,
3. Considers the asset for purposes of overall portfolio allocation, or
4. Reviews the asset on an intermittent basis or at the Client’s request.
Note: AUS can include assets that are non-securities, such as artwork, real estate, collections, jewelry, other
income producing property, etc. Additionally, the absolute value of a loan of other liability could be considered
AUS under similar circumstances.
AUS will be reported based on the current known values of the asset as of the date of reporting. As of December
31, 2023, the Adviser had AUS of $19,504,351,843. Clients may request more current information at any time
by contacting the Adviser.
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