CEETO CAPITAL GROUP, LLC

Ceeto Capital Group, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Ceeto Capital Group, LLC. If you have any questions about the contents of this brochure, please contact us at 786-477- 6445 or by email at: ccanida@ceetocapitalgroup.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ceeto Capital Group, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Ceeto Capital Group, LLC CRD number is: 286538. 114 Alhambra Cir., Suite 202 Coral Gables, FL 33134 786-477- 6445 ccanida@ceetocapitalgroup.com Registration does not imply a certain level of skill or training. Version Date: 03/25/2025 i  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment of Ceeto Capital Group, LLC on 03/27/2024. Material changes relate to Ceeto Capital Group, LLC’s policies, practices or conflicts of interests. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .........................................................................................................................................................................................................ii Item 3: Table of Contents ....................................................................................................................................................................................................... iii Item 4: Advisory Business ....................................................................................................................................................................................................... 2 A. Description of the Advisory Firm ................................................................................................................................................................................ 2 B. Types of Advisory Services ........................................................................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ........................................................................................................................................ 3 D. Wrap Fee Programs ....................................................................................................................................................................................................... 3 E. Assets Under Management ........................................................................................................................................................................................... 3 Item 5: Fees and Compensation .............................................................................................................................................................................................. 4 A. Fee Schedule ................................................................................................................................................................................................................... 4 B. Payment of Fees .............................................................................................................................................................................................................. 4 C. Client Responsibility For Third Party Fees ................................................................................................................................................................. 4 D. Prepayment of Fees ....................................................................................................................................................................................................... 4 E. Outside Compensation For the Sale of Securities to Clients ..................................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................................................................................... 5 Item 7: Types of Clients ........................................................................................................................................................................................................... 5 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................................................................. 5 A. Methods of Analysis and Investment Strategies ............................................................................................................................................... 5 B. Material Risks Involved ....................................................................................................................................................................................... 6 C. Risks of Specific Securities Utilized .................................................................................................................................................................... 8 Item 9: Disciplinary Information .......................................................................................................................................................................................... 10 A. Criminal or Civil Actions ................................................................................................................................................................................... 10 B. Administrative Proceedings .............................................................................................................................................................................. 10 C. Self-regulatory Organization (SRO) Proceedings ........................................................................................................................................... 10 Item 10: Other Financial Industry Activities and Affiliations ........................................................................................................................................... 10 A. Registration as a Broker/Dealer or Broker/Dealer Representative ............................................................................................................. 10 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .............................. 10 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ......................................................... 10 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................................. 11 A. Code of Ethics ..................................................................................................................................................................................................... 11 B. Recommendations Involving Material Financial Interests ............................................................................................................................ 12 C. Investing Personal Money in the Same Securities as Clients......................................................................................................................... 12 D. Trading Securities At/Around the Same Time as Clients’ Securities .......................................................................................................... 12 Item 12: Brokerage Practices ................................................................................................................................................................................................. 12 iii  A. Factors Used to Select Custodians and/or Broker/Dealers .......................................................................................................................... 12 1. Research and Other Soft-Dollar Benefits .................................................................................................................................................... 13 2. Brokerage for Client Referrals ...................................................................................................................................................................... 13 3. Clients Directing Which Broker/Dealer/Custodian to Use ..................................................................................................................... 13 B. Aggregating (Block) Trading for Multiple Client Accounts .......................................................................................................................... 13 Item 13: Review of Accounts ................................................................................................................................................................................................. 13 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................................................................ 13 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ........................................................................................................ 14 C. Content and Frequency of Regular Reports Provided to Clients.................................................................................................................. 14 Item 14: Client Referrals and Other Compensation ........................................................................................................................................................... 14 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .................... 14 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................................................................................ 14 Item 15: Custody .................................................................................................................................................................................................................... 14 Item 16: Investment Discretion ............................................................................................................................................................................................. 14 Item 17: Voting Client Securities (Proxy Voting)................................................................................................................................................................ 15 Item 18: Financial Information .............................................................................................................................................................................................. 15 A. Balance Sheet ....................................................................................................................................................................................................... 15 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ............................................ 15 C. Bankruptcy Petitions in Previous Ten Years ................................................................................................................................................... 15 iv  Item 4: Advisory Business A. Description of the Advisory Firm Ceeto Capital Group, LLC (hereinafter “CCG”) is a Limited Liability Company organized in the State of Florida. The firm was formed in November 2016, and the principal owner is Brian William Canida. B. Types of Advisory Services Portfolio Management Services CCG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCG creates an Investment Policy Statement for each client, which outlines the client’s current situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring CCG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CCG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CCG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCG’s economic, investment or other financial interests. To meet its fiduciary obligations, CCG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CCG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CCG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Alternative Fund Managers CCG may recommend alternative fund managers. Before selecting alternative fund managers for clients, CCG will verify that all recommended fund managers are properly licensed, notice filed, or exempt in the states where CCG is recommending the alternative fund managers to clients. 2  Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury CCG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs (including ETFs inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. CCG may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions CCG offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCG from properly servicing the client account, or if the restrictions would require CCG to deviate from its standard suite of services, CCG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. CCG does not participate in any wrap fee programs. E. Assets Under Management CCG has the following regulatory assets under management.: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 381,533,402 $ 57,876,947 December 2024 CCG has $200,000,000.00 in assets under advisement. 3  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All Assets 1.00% CCG uses the balance in the client’s account on the last day of the billing period to determine the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of CCG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 10 days' written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, ETF fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CCG. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees CCG collects its fees in arrears. It does not collect fees in advance. 4  E. Outside Compensation For the Sale of Securities to Clients Neither CCG nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management CCG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients CCG generally provides advisory services to High-Net-Worth Individuals, trusts, foundations, endowments, and pension funds. CCG generally requires an account minimum of $10,000,000 for its services, but at its discretion may accept a smaller account. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CCG’s methods of analysis may include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. CCG uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. 5  Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies CCG uses long term trading, short term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. 6  Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies CCG's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: To the extent outside advisors are used, CCG's selection process cannot ensure that money managers will perform as desired and CCG will have no control over the day-to-day operations of any of its selected money managers, if any. CCG would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 7  C. Risks of Specific Securities Utilized CCG's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or 8  changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; may involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. 9  Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CCG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CCG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Brian William Canida is also manager of Canida Ventures, LLC (d/b/a Ceeto Ventures) (“Ceeto Ventures”) and other affiliated investment vehicles that his family and other non- client families have used to make private investments. Ceeto Ventures will not be a client of Ceeto Capital, LLC; however, Mr. Canida may come across investment opportunities that he may or may not share with clients of CCG, depending on each client’s communicated desire to invest in such opportunities. CCG always acts in the best interest 10  of the client and clients are in no way required to the services of any representative of CCG in connection with Mr. Canida’s activities outside of CCG. Brian William Canida is a lawyer. Ceeto Capital Group, LLC always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of Ceeto Capital Group, LLC in their capacity as a lawyer. Maria Teresa ("Tere") Canida currently sits on the board of Kemper Corporation (NYSE: KMPR). She has been a member of the board since 2018 and receives compensation in the form of both cash and KMPR securities. Maria Teresa ("Tere") Canida also serves as a member of the Investment Advisory Council of the Florida State Board of Administration. Carolina Elizabeth Canida is a lawyer. Ceeto Capital Group, LLC always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of Ceeto Capital Group, LLC in their capacity as a lawyer. Carolina Elizabeth Canida is also a principal at Canida Ventures, LLC (d/b/a/ Ceeto Ventures) ("Ceeto Ventures") and other affiliated investment vehicles that her family and other non-client families have used to make private investments. Ceeto Ventures will not be a client of Ceeto Capital Group, LLC; however, Mrs. Canida may come across investment opportunities that she may or may not share with clients of CCG, depending on each client's communicated desire to invest in such opportunities. CCG always acts in the best interest of the client and clients are in no way required to the services of any representative of CCG in connection with Mrs. Canada's activities outside of CCG. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CCG does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CCG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual 11  Review, and Sanctions. CCG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests CCG does not recommend that clients buy or sell any security in which a related person to CCG or CCG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of CCG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CCG to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. CCG will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of CCG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CCG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, CCG will never engage in trading that operates to the client’s disadvantage if representatives of CCG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on CCG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and CCG may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in CCG's research efforts. CCG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. 12  1. Research and Other Soft-Dollar Benefits CCG does not employ any soft dollar arrangements. 2. Brokerage for Client Referrals CCG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use CCG may permit clients to direct it to execute transactions through a specified broker- dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to CCG to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the client may be unable to participate in block trades (unless CCG is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If CCG buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, CCG would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. CCG would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for CCG's advisory services provided on an ongoing basis are reviewed at least monthly by Brian William Canida, President, Maria Teresa (“Tere”) Canida, and Portfolio Manager, Wiliam James Canida, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at CCG are assigned to this review process. 13  B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of CCG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client's account, including assets held, asset value, and calculation of fees. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) CCG does not receive any economic benefit, directly or indirectly from any third party for advice rendered to CCG's clients. B. Compensation to Non – Advisory Personnel for Client Referrals CCG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, CCG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion CCG provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, CCG generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. 14  Item 17: Voting Client Securities (Proxy Voting) CCG in its discretion may ask for and/or accept voting authority for client securities. Clients may also receive proxies directly from the issuer of the security or the custodian. CCG acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it, or for which it is deemed to have, proxy voting authority. CCG will vote proxies on behalf of a client solely in the best interest of the relevant client. CCG has established general guidelines for voting proxies. CCG may also abstain from voting if, based on factors such as expense or difficulty of exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, CCG may vote in a manner that is contrary to the general guidelines if it believes that it would be in a client’s best interest to do so. If a proxy proposal presents a conflict of interest between CCG and a client, then CCG will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client’s wishes. Clients may obtain a complete copy of the proxy voting policies and procedures by contacting CCG in writing and requesting such information. Each client may also request, by contacting CCG in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the relevant client during the prior annual period. Clients can send written requests to the Chief Compliance Officer at: ccanida@ceetocapitalgroup.com Item 18: Financial Information A. Balance Sheet CCG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither CCG nor its management has any financial condition that is likely to reasonably impair CCG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years CCG has not been the subject of a bankruptcy petition in the last ten years. 15