Overview
Csenge Advisory Group, LLC (“CAG”, Csenge, we, us, our, ours) is a limited liability company
organized under Florida state law. John L. Csenge founded the Clearwater-based investment
advisory firm in 2000. John Csenge is the principal owner. The firm is a registered investment
adviser with the SEC.
Csenge Advisory Group offers investment advisory services through a network of
independent advisory representatives who are authorized to conduct business under their
own business names or under the CAG name.
We offer the following advisory services:
• Asset Management Programs;
• Asset Allocation Services;
• Analysis, Recommendation and Monitoring of Third-Party Managed Programs;
• Financial Planning and hourly Consulting; and
• Corporate Investment and Retirement Plan Consulting Services
Asset Management Program
Our advisory representatives directly manage client portfolios. Assets are allocated within a
mix of securities that may include equities, bonds, options, mutual funds and exchange traded
funds.
We also maintain 14 asset allocation models consisting primarily of equities, mutual funds
and exchange traded funds (“ETFs”):
•CAG Cash Cow
•CAG Commodore
•CAG Core & Explore
•CAG Fixed
•CAG Growth & Income
•CAG Hard Asset
•CAG International
•CAG Opportunistic
•CAG Sector Select
•CAG Tactical Fusion
•CAG Techno Quant
•CAG Total Market
•Radian Preferred
However, your portfolio may be managed independently of these models. We work with you
to identify your investment goals, objectives, restrictions, and risk tolerance to determine
what is most suitable for you. From there, we customize your portfolio to create an initial
allocation designed to complement your financial situation and personal circumstances.
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Subadviser Services
We may also act as a subadviser to an unaffiliated third-party advisor to
our firm. These third-party advisers outsource portfolio management services to our firm.
This relationship will be memorialized in each contract between us and the third-party
advisor.
Betterment may act as a subadviser on behalf of our clients. Betterment is an unaffiliated
advisor to our firm.
IRA Rollover Considerations and Recommendations
As part of our investment advisory services to you, we may recommend that you withdraw the
assets from your employer's retirement plan and roll the assets over to an individual retirement
account (“IRA”) that we will manage on your behalf. If you elect to roll the assets to
an IRA that
is subject to our management, we will charge you an asset-based fee as set forth in the
agreement you executed with our firm. This practice presents a conflict of interest because
persons providing investment advice on our behalf have an incentive to recommend a rollover
to you for the purpose of generating fee-based compensation rather than solely based on your
needs. You are under no obligation, contractually or otherwise, to complete the rollover.
Moreover, if you do complete the rollover, you are under no obligation to have the assets in an
IRA managed by our firm.
We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption 2020-02
(“PTE 2020-02”) where applicable. Our firm is providing the following additional
acknowledgment:
When the Adviser provides investment advice to individuals regarding a retirement plan
account or individual retirement account, the firm is deemed a fiduciary 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 the Adviser makes money
creates potential conflicts with a client’s interest. Therefore, the Adviser, operates under a
special rule which requires the firm to act in a client’s best interest and not put the Adviser’s
interest ahead of the client. Under this special rule’s provisions, the Adviser must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put the Adviser’s financial interests ahead of a client when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure advice given is in the client’s best
interest;
• Charge no more than is reasonable for services; and
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• Provide basic information about conflicts of interest.
The Adviser benefits financially from the rollover of a client’s assets from a retirement account
to an account managed by the firm. This is a primary conflict of interest because when the
Adviser provides investment advice, the assets increase the firm assets under management
and, in turn, advisory fees. To meet the fiduciary responsibility the Adviser only recommends a
rollover when it is deemed in the client’s best interest.
Management of Wrap Accounts
Our advisory services are generally offered on a wrap fee basis. The fee you pay to us covers
our advisory fee and most brokerage commissions and other trading costs as described under