Firm Description
Carson Advisory Group is the successor firm to directly related financial services firms dating
to 1959. The original registration with the Securities and Exchange Commission was
approximately two decades later as Carson & Associates.
Carson Advisory Group provides personalized, confidential financial planning and investment
management to individuals, pension and profit-sharing plans, trusts, estates, charitable
organizations, foundations, municipalities, and corporations or small business entities. Advice
is provided through consultation with the client and can include determination of financial
objectives, identification of financial concerns, cash flow management, tax planning, insurance
review, investment management, education funding, retirement planning, and estate planning.
Investment advice, including asset allocation, is an integral part of financial planning.
The initial meeting, which may be by telephone, is free of charge and is considered an
exploratory interview to determine the extent to which financial planning and investment
management may be beneficial to the client. If the client wishes to proceed and engage in our
services, the Investment Advisor Representative (“IAR”) will have the client sign our contract
and obtain the client’s necessary financial and personal information. All of this information,
including the client’s goals, risk tolerance, and current situation form the direction for asset
allocation. Suggested portfolio changes are communicated as needed and based upon client
needs.
For the majority of assets under management, Raymond James & Associates, Inc., member
New York Stock Exchange/SIPC, (“Raymond James”) acts as custodian.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly
by the client on an as-needed basis.
Principal Owners
Robert H. Carson, Jr. 75.10% stockholder; Richard J. Chester, Jr. 18.55% stockholder, and
Kevin Wilson 6.35% stockholder.
Types of Advisory Services
Carson Advisory Group provides investment and asset management services, and on
occasion, issues special reports about securities useful on issues specific to each client.
Carson Advisory Group furnishes advice to clients on matters related to their assets, such as
financial and retirement planning, topical taxation issues (including required minimum
distributions from qualified plans)1, potential trust needs, transitioning wealth, charitable gifting
(including donor advised accounts), college savings opportunities, and general family financial
events.
1 We do not offer professional tax advice. To determine your individual tax situation, please consult a professional tax
advisor.
As of December 31, 2023, Carson Advisory Group had the following in assets under
management:
Discretionary Assets ......................................................$611,918,468
Non-Discretionary Assets...............................................$83,002,973
Assets Under Advisement2.............................................$52,431,626
Total Assets Managed is $747,353,067
Carson Advisory Group owners, employees, and related personnel have a brokerage
relationship with Raymond James Financial Services. Assets serviced in that capacity, when
acting as registered representatives of RJFS, totaled approximately $213,846,132 on 12-31-
23. The total assets serviced for both our fee based and brokerage relationships was
approximately $961,199,199 on 12-31-23.
Tailored Relationships
Advice is tailored to the individual client based on their needs. Goals and objectives for each
client are discussed, documented, and reviewed periodically. Clients may impose reasonable
restrictions on the investments made in their accounts. Reasonable restrictions include the
designation of particular securities or types of securities that should not be purchased in their
account (i.e., Company XYZ or companies involved in a particular industry, etc.), or should be
sold if held in the account. However, in some cases where investment discretion has been
delegated to Carson Advisory Group, or a third-party manager, it may be determined that the
implementation of such a restriction is impractical. In the event such a determination is made,
you will be notified promptly. Please note that investment guidelines and restrictions must be
provided to Carson Advisory Group in writing.
Types of Services
The following arrangements define the typical client relationships:
Advisory Service
Most clients choose to have Carson Advisory Group manage their assets in order to obtain
ongoing, in-depth advice and life planning. To the degree that clients share their
circumstances, and we are aware of changes in a client’s financial affairs, suggestions are
made and implemented.
The scope of work and fee for our advisory services is provided to the client in writing prior to
the start of the relationship. An Advisory Service Agreement includes investment and cash
management responsibilities and all associated expenses.
2 The total assets under advisement listed represent assets in which we have neither discretionary authority nor
responsibility for arranging or effecting the purchase or sale of recommendations provided to and accepted by the ultimate
client. Inclusion of these assets will make our total assets number different from assets under management disclosed in
Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management.
Asset Management
Assets are invested primarily in institutional, no-load mutual funds, closed-end funds,
exchange-traded funds (“ETFs”), individual equities, and bonds (although we can offer advice
on any type of security including alternative investments such as REITs, limited partnerships
and Variable Annuities, among others).
Initial public offerings (“IPOs”) are available through Carson Advisory Group via our
relationship with Raymond James Financial Services, Inc., member FINRA/SIPC, (“RJFS”),
though they are very rarely recommended or used in client accounts. For Discretionary
Ambassador Accounts, participation in IPOs are only permitted if the client expressly
authorizes their purchase on an unsolicited basis. All shares would be purchased net of any
internal offering, such that there is no compensation or client expense. There can also be
offerings with commission, but those are then excluded from advisory billing and treated as a
non-billable asset (see page 7).
Accounts Managed by Carson Advisory Group
Ambassador Program
The Ambassador Program is an all-inclusive wrap fee investment advisory account offered by
Carson Advisory Group and administered by Raymond James, in which the client is provided
with ongoing investment advice and monitoring of securities holdings. This type of account
offers clients the ability to pay an asset-based advisory wrap fee in lieu of a transaction fee for
each investment transaction within the account. There are no separate transaction fees in
Ambassador Program accounts for any type of security. Carson Advisory Group receives a
portion of the advisory fee.
Charges for other account services provided by Raymond James, not directly related to the
advisory, execution, and clearing services provided as part of the wrap fee program may be
incurred. Some of these additional expenses could include but are not limited to, safekeeping
fees, interest charges on margin loans, and fees for legal or courtesy transfers of securities.
The Ambassador Program is offered as both a Discretionary and Non-Discretionary Program.
For Ambassador Discretionary Program accounts, the IAR has the authority to buy and sell
securities without
specific consent from the client, at the IAR’s discretion, as deemed
appropriate in adherence to the investment objectives designated by the client. For
Ambassador Non-Discretionary Program accounts, the IAR will make recommendations to the
client, according to their investment objectives, but the client is responsible for all trading
decisions.
Accounts Managed by Other Asset Managers3
Carson Advisory Group offers to our clients a number of RJA’s managed wrap programs,
including but not limited to Raymond James Consulting Services (RJCS), Freedom, Freedom
Foundation, Freedom UMA, and American Funds Model Portfolios, under a subadvisory
agreement with RJA. Our advisors work with our clients to choose an appropriate
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3Accounts managed by other asset managers are included in our assets under advisement.
program and help the client to select the managers, strategies, or disciplines within the
programs that best fit their financial objective and risk profile, as applicable. Once the program,
described in more detail below, is selected by the client, RJA is appointed as a discretionary
investment adviser under the appropriate advisory agreement. In this way, RJA acts as a
subadviser in directly (or indirectly through other subadvisers) managing client’s assets
through the selected program. Both RJA (and its affiliates and agents, and other subadvisers,
as applicable) and Carson Advisory Group advisors receive a portion of the advisory fee paid
by the client. Below is a list of some of some of the managed platforms available to our clients:
Raymond James Consulting Services (RJCS)
Raymond James Consulting Services (RJCS) serves as a conduit through which clients may
access a number of nationally known money management firms for account sizes far below
normal firm minimums. All managers hired have passed an in-depth quantitative and
qualitative screening process and are subject to on-going monitoring by the Asset
Management Services (AMS) Manager Selection & Due Diligence team at Raymond James.
Based upon the client’s investment objectives and financial needs, the IAR will assist in
selecting an appropriate manager.
Freedom Account (including Freedom Core Mutual Fund, Freedom Hybrid, and Freedom ETF)
Freedom is an AMS-managed account program offering various strategies comprised of
Mutual Funds or Exchange Traded Funds. The program is selected based upon the client’s
investment objectives and financial needs.
Freedom Foundation
Freedom Foundation strategies use mutual funds to achieve asset allocation aligned with
some of the most commonly utilized Freedom portfolios. This program allows for a smaller
initial account requirement and is commonly used for next generation investors.
Freedom Unified Managed Account (UMA)
Freedom UMA is an AMS-managed account that provides higher-net-worth clients numerous
model strategies across multiple investment objectives utilizing both separately managed
account (SMA) managers and mutual funds.
AMS Sustainable Investing Solutions
AMS makes available to us a variety of AMS-managed and Separately Managed account
options that may help clients align their investing goals with their personal values.
American Funds Model Portfolios
The American Funds Model Portfolios are available through AMS and provide clients access to
American Funds mutual funds through model portfolios delivered by American Funds’ Portfolio
Oversight Committee.
Retirement Plan Services
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which
Plan Fiduciaries may retain investment advisers for various types of services with respect to
Plan assets. For certain services, Carson Advisory Group will be considered a fiduciary under
ERISA. For example, Carson Advisory Group will act as an ERISA § 3(21) fiduciary when
providing non-discretionary investment advice to the Plan Fiduciaries by recommending a suite
of investments as choices among which Plan Participants may select. Alternatively, Carson
Advisory Group can act as an ERISA § 3(38) fiduciary when providing discretionary investment
advice to the Plan Sponsor.
Carson Advisory Group offers pension planning and plan implementation services to small and
medium-sized businesses covering Plan Consulting, Plan Investment, and Plan Participation
Services. The service will address the need of a company to install a comprehensive
retirement plan, provide an overview of the various plan design characteristics, and assist with
the selection of a recordkeeper and/or third-party administrator. The particular services
provided will be detailed in the consulting agreement.
Retirement Account Recommendations
In complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02"), when
applicable, Carson Advisory Group provides the following acknowledgment to clients:
When Carson Advisory Group provides investment advice to clients regarding their 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. The way Carson Advisory Group is compensated
could create some conflicts with the clients’ interests, so where applicable, we operate under an
exemption that requires us to act in the client’s best interest and not put our interests ahead of
the client’s. Under this exemption, we must:
• Meet a professional standard of care (give prudent advice),
• Never put our financial interests ahead of clients’ (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 the client’s
best interest,
• Charge no more than is reasonable for our services, and
• Give clients basic information about conflicts of interest.
Carson Advisory Group benefits financially from the rollover of client assets from a retirement
account to an account that we manage because the assets increase our assets under
management, and, in turn, our advisory fees. As a fiduciary, Carson Advisory Group only
recommends a rollover when we believe it is in the client’s best interest.
Financial Planning Service
A financial plan can be designed, as part of any of our advisory services described above, to
help clients with aspects of financial planning.
The average client does not utilize a detailed financial plan, but our mutual understanding
typically includes at least some elements of the following: a net worth statement; a cash flow
statement; a review of investment accounts, including reviewing asset allocation and providing
repositioning recommendations; strategic tax planning; a review of retirement accounts and
plans including recommendations; a review of insurance policies and recommendations for
changes, if necessary; one or more retirement scenarios including retirement cash flow
analysis; estate planning review and recommendations; and education planning with funding
recommendations.
Please note that our IARs, in consultation with the client, may decide to utilize a single strategy
described above, multiple strategies noted above, individual securities in combination with one
of the strategies noted above, or none of the strategies noted above. In any scenario, IARs will
tailor their recommendations and investments based on the client’s investment objective and
risk tolerance, and the client will have the opportunity to place reasonable restrictions or
constraints on the way their account is managed.