Firm Information
This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications,
business practices, and the advisory services provided by Carr Financial Group Corporation’s
(the “Firm,” “we,” “us,” “ours”).
We are a federally Registered Investment Adviser with the U.S. Securities and Exchange
Commission (“SEC”). We were founded in 2022 and are owned by Richard M. Carr Benjamin W.
Cauley and Andrea L. Lucey.
We provide investment advisory services to individuals, trusts, estates, charitable organizations,
corporations and other business entities, pension and profit-sharing plans. Our investment
advisory services include financial planning, wealth management, consulting, family office
services, and a selection of other services.
Types of Advisory Services
Financial Planning
We offer financial planning services, which may include a review of all aspects of a client’s
current financial situation, including the following components: cash management, risk
management, insurance, education funding, goal setting, retirement planning, estate and
charitable giving planning, tax planning, and capital needs planning. Clients understand that
when engaged to address only certain components, the client’s overall financial and investment
issues may not be taken into consideration.
We meet with the client to review risk tolerance, financial goals and objectives, and time
horizons. Additional meetings may include a review of additional financial information; sources
of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax
returns, investments, and personal and family obligations.
The financial plan may include both long and short-term considerations, depending upon the
individual scenario. Upon completion a plan is presented to the client and the client is provided
with recommendations that are deemed to be compatible with the client’s stated goals and
objectives. The client is under no obligation to utilize the Firm to implement the advice or plan.
Clients may choose all or certain components of advice and recommendations and can
implement the recommendations through the service providers of their choice.
Wealth Management Services
We provide clients with wealth management services which include a broad range of financial
planning and consulting services as well as discretionary and/or non-discretionary management
of investment portfolios.
We allocate client assets among investments in accordance with the client’s stated investment
objectives. The Firm primarily allocates client assets in mutual funds, exchange-traded funds
(“ETFs”). For certain clients, the Firm further allocates among individual debt and equity
securities, options, real estate investment trusts (“REITs”) and independent investment
managers (“Independent Managers”).
Where appropriate, the Firm also provides advice about any type of legacy position or other
investment held in client portfolios, but clients should not assume that these assets are being
continuously monitored or otherwise advised on by the Firm unless specifically agreed upon.
Clients can engage the Firm to advise on certain investment products that are not maintained
at their primary custodian, such as variable life insurance and annuity contracts and assets held
in employer-sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, we direct or recommend the allocation of client assets among the various
investment options available with the product. These assets are generally maintained at the
underwriting insurance company or the custodian designated by the product’s provider.
Retirement Plan Consulting Services
We provide various consulting services to qualified employee benefit plans and their fiduciaries.
This suite of institutional services is designed to assist plan sponsors in structuring, managing
and optimizing their corporate retirement plans. Each engagement is individually negotiated
and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education
Family Office Services
We provide family office services through the business name of Lucey Advisory Group. The
family office services are separately negotiated and can include the following, among other
services:
• Personal and business bill paying and record keeping.
• Reconciling accounts, credit card transactions and other financial activity.
• Reviewing and summarizing vendor contracts (HR service provider, insurance, etc.)
• Handling property
and casualty insurance applications, premium payments, etc.
• Maintaining corporate records including annual meeting minutes and agendas.
• Producing financial reports for clients, CPAs and bookkeeper review.
• Household employee payroll coordination using 3rd party payroll provider.
Use of Independent Managers
As mentioned above, we select certain Independent Managers to actively manage a portion of
client assets. The Firm does not anticipate utilizing Independent Managers frequently. The
specific terms and conditions under which a client engages an Independent Manager are set
forth in a separate written agreement with the designated Independent Manager. That
agreement can be between the Firm and the Independent Manager (often called a subadvisor)
or the client and the Independent Manager (sometimes called a separate account manager). In
addition to this brochure, clients will typically also receive the written disclosure documents of
the respective Independent Managers engaged to manage their assets.
We evaluate a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent
possible, the Firm seeks to assess the Independent Managers’ investment strategies, past
performance and risk results in relation to its clients’ individual portfolio allocations and risk
exposure. The Firm also takes into consideration each Independent Manager’s management
style, returns, reputation, financial strength, reporting, pricing and research capabilities, among
other factors.
We continue to provide services relative to the discretionary or non-discretionary selection of
the Independent Managers. On an ongoing basis, the Firm monitors the performance of those
accounts being managed by Independent Managers. We seek to ensure the Independent
Managers’ strategies and target allocations remain aligned with our clients’ investment
objectives and overall best interests.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Tailored Relationships
We tailor advisory services to the individual needs of the client. Clients may place reasonable
investment restrictions on their portfolios, including bans on investing in particular industries,
and investing in limited amounts of securities. All limitations and restrictions placed on
accounts must be presented to us in writing.
Assets Under Management
As of January 19, 2023, we managed $466,935,78 4in client assets; $463,249,484 managed on a
discretionary basis, and $3,686,300 on a non-discretionary basis.