Creative Planning, LLC (referred to throughout as we, us, our, or the Firm) is owned and controlled by Peter Mallouk through
the following ownership structure: CPI HoldCo B, LLC; CPI HoldCo A, LLC; CPI HoldCo, LLC; CPI HoldCo, Inc, Peter Mallouk
Trust, and the MJG Irrevocable Trust.
Creative Planning has been registered as an investment advisor with the United States Securities and Exchange Commission
(“SEC”) since March 18, 1983.
Client Assets Managed by Creative Planning
Client assets managed by Creative Planning total approximately $175,271,678,869 as of December 31, 2023;
$172,319,359,409 is managed on a discretionary basis, and $2,952,319,460 is managed on a non-discretionary basis.
The Firm also provided monitoring/consulting services to section 404 pension plans with combined assets of approximately
$107,193,193,107. These assets are commonly referred to as assets under advisement.
The Firm’s Executive Officers are:
• Peter Mallouk, President
• Molly Rothove, Vice President
• David Kaye, Chief Financial Officer
• Jamie Battmer, Chief Investment Officer
• Ramesh Poola, Co-Chief Investment Officer
• Jonathan Knapp, Chief Operations Officer
• Lee Richardson Jr., Chief Risk and Compliance Officer
• Chat Scruggs, Chief Technology Officer
Portfolio Management Services
We provide advisory services in the form of Portfolio Management Services. Portfolio Management Services provide clients
with continuous and ongoing supervision over their accounts. This means that Creative Planning will continuously manage a
client’s account and place trades in client accounts when necessary.
We provide investment advice on a large variety of investment types. When providing Portfolio Management Services, the
Firm will typically consider bonds, equities, ETFs, mutual funds, and alternative investments to build diversified portfolios to
meet each respective client’s financial goals and objectives; however, we are not limited to those investments. It is not our
typical investment strategy to attempt to time the market, but we may increase cash holdings as deemed appropriate based
on the client’s risk tolerance and short- and long-term goals. We may modify our investment strategy to accommodate special
situations, including but not limited to low-basis stock, stock options, legacy holdings, inheritances, closely held businesses,
collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for
more information.)
Our services are provided based on the specific needs of each client. For example, the client can impose restrictions on the
accounts we manage, including specific investment sectors and selections. We work with each client on a one-on-one basis
through interviews and questionnaires, as applicable, to determine the client’s investment objectives and suitability
information. We will not necessarily verify any information received from the client or the client’s other professionals, and we
are authorized to rely on the information provided. It is each client’s responsibility to promptly notify us if there is ever any
change in their financial or personal situation or investment objectives for the purpose of reviewing our previous
recommendations. Clients should be aware that there will be periods of time when the Firm determines that changes to a
client’s portfolio are neither necessary nor prudent, but clients will still be subject to the fees described in their client
agreement. Creative Planning does not participate in a wrap fee program.
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Retirement Plan Services
We offer several advisory services for corporate and public retirement plans, separately or in combination. The primary
clients for these services are pension, profit sharing, and participant-directed, individual account plans (i.e., 401(k), 403(b),
etc.).
Specifically, we offer (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory Services,
(3) Retirement Plan Fiduciary Services and/or (4) Advisor Managed Account, FinanceGPS and FinancialGuide to employer-
sponsored retirement plans and their participants in either an ERISA 3(38) fiduciary or ERISA 3(21) co-fiduciary capacity.
Depending on the type of the plan and the specific arrangement with the plan sponsor, we may provide one or more of these
services. Before being engaged by the plan sponsor, we will provide a copy of this Form ADV Part 2A, our Privacy Policy, and
the applicable Agreement containing the information required to be disclosed under Sec. 408(b)(2) of the Employee
Retirement Income Security Act (“ERISA”), as applicable.
A plan participant or beneficiary may request additional services in providing Retirement Plan Services to a plan. Creative
Planning may establish a separate client relationship with one or more plan participants or beneficiaries through a separate
agreement. Such client relationships develop in various ways, including, but not limited to:
• a result of a decision by a plan participant or beneficiary to purchase services from Creative Planning not involving
the use of plan assets;
• part of an individual or family financial plan for which any specific recommendations concerning the allocation of
assets or investment recommendations relating to assets held outside of the plan; and/or
• through a rollover to an Individual Retirement Account (“IRA”).
If a plan participant or beneficiary desires to affect a rollover from the plan to an IRA account advised or managed by Creative
Planning, or if we make a recommendation to affect a rollover, we will have a conflict of interest given that our IRA advisory
fees can reasonably be expected to be higher than those we receive in connection with the Retirement Plan Services due to
the individualized nature of our IRA-related services. To mitigate such conflicts, Creative Planning will disclose relevant
information about the applicable fees we charge for advising or managing an IRA, as well as reviewing the benefits each
retirement account allows for before opening an account to receive the rollover. The decision as to whether to take a
distribution from any retirement account rests
solely with the individual participant and beneficiaries.
Department of Labor Acknowledgement of Fiduciary Duty
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are
fiduciaries 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. How we make money creates some conflicts with your interests,
so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Financial Planning Services
We offer advisory services in the form of financial planning services. Financial planning services do not involve ongoing client
account management but instead focus on a client’s overall financial situation. Financial planning can be described as helping
individuals determine and set thei
r long-term financial goals throug
h investments, tax planning, asset allocation, risk
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management, retirement planning, a
nd other areas. Th
e role of a financial planner is to find ways to help the client
understand their
overall financial situation and help them set financia
l objectives.
We analyze and review the client’s financial documentation, which typically includes the client’s assets and liabilities,
investment portfolio, retirement plan, education plan, risk management plan, risk tolerance, estate plan, and other areas
relevant to the client’s financial health. We then provide an executive summary highlighting the plan of action. Our Wealth
Managers are available to assist with implementing the plan and to answer any client questions. Still, the client is ultimately
responsible for implementing or rejecting our recommendations. You are never obligated or required to implement our
recommendations.
Furthermore, we can implement the plan with the client throughout the year. It remains the client’s responsibility to promptly
notify us of any changes in their financial situation or investment objectives to review, evaluate, or revise our previous
recommendations and/or services.
While certain Wealth Managers and financial planners are certified public accountants, enrolled agents or attorneys, and the
financial planning services described above include an analysis, review and recommendations relating to a client’s tax
situation and estate plan, Wealth Managers and financial planners do not provide tax or legal services. Tax and legal services
are offered through the Firm’s affiliated Tax and Legal entities through separate agreements and compensation
arrangements. (Please refer to Item 10 – Other Financial Industry Activities and Affiliations.)
Sub-Advisory Services
We have entered into sub-advisory agreements for separately managed account(s) with independent registered investment
advisors. These arrangements were established to fulfill specific investment strategies to meet clients’ goals and objectives.
We do not make individual security or stock option selection decisions in the sub-advised account. The sub-advisors buy and
sell securities over time as they manage the account directly on the client’s behalf. We monitor the investment account, but
not to the degree that we would monitor investments in accounts we manage directly. Where the sub-advisor performs
management services for a client of Creative Planning for a fee, clients will receive a copy of the sub-advisor’s ADV Part 2A
brochure.
Persons Residing Outside of the United States
Services for clients living outside the United States may be restricted or limited due to custodial rules or other factors.
Investment options and strategies may differ from our typical recommendations, including but not limited to the foreign tax
treatment of investment transactions in the United States. In addition, foreign laws or requirements may also impact our
ability to service accounts or require additional disclosure as determined on an individual country basis. The client will be
responsible for satisfying all legal and tax reporting requirements of the United States and all applicable foreign governments.
Any person located outside of the United States who wishes to open an account or an existing client who is located outside of
the United States will be subject to the custodian’s policy regarding that country (including their right to decline to open or
maintain the account), and all applicable customer identification and anti-money laundering regulations.
In its sole discretion, Creative Planning reserves the right to decline an engagement with any prospective client outside of the
United States, or terminate an engagement with an existing client, if they move outside of the United States.