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Firm Brochure
(Parts 2A and 2B of Form ADV)
Carson Advisory Group
470 Hill Street
Athens, GA 30601
706-543-6578
www.carsonadv.com
This brochure provides information about the qualifications and business
practices of Carson Advisory, Inc. doing business as Carson Advisory
Group. Please contact us at: 706-543-6578, or by email at:
lindsey.seagraves@raymondjames.com with any questions regarding the
contents of this brochure. The information in this brochure has not been
approved or verified by the United States Securities and Exchange
Commission (“SEC”), or by any state securities authority.
Additional information about Carson Advisory Group is available on our
website at http://www.carsonadv.com/ or on the SEC’s website at
www.adviserinfo.sec.gov.
03/24/2025
Carson Advisory Group
ITEM 2- MATERIAL CHANGES
Annual Update
The Material Changes section of this brochure will be updated annually when material changes
occur since the previous release of the Firm Brochure.
Material Changes since the Last Annual Update of 03/26/24
1. Item 5: We updated the “Accounts Managed by Other Asset Managers” section to
clarify that most of these types of accounts have a separate manager fee that is
in addition to our advisory fee but combined into a single charge.
2. Item 11: We clarified our personal securities trading policies.
3. Item 14: We added disclosures relating to referral arrangements.
Additionally, we have made other changes throughout this Disclosure Brochure which
may clarify or enhance existing disclosures, but we do not consider these changes to be
material.
Full Brochure Available
A complete copy of our Firm Brochure is available at our office or on our website:
http://www.carsonadv.com/
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ITEM 3-TABLE OF CONTENTS
ITEM 2- MATERIAL CHANGES ...................................................................................... i
Annual Update ............................................................................................................ i
Material Changes since the Last Annual Update of 03/26/24 ..................................... i
ITEM 4- ADVISORY BUSINESS .................................................................................... 1
Firm Description ......................................................................................................... 1
Principal Owners ........................................................................................................ 1
Types of Advisory Services ........................................................................................ 1
Tailored Relationships ............................................................................................... 2
Types of Services ...................................................................................................... 2
Advisory Services ...................................................................................................... 2
Asset Management .................................................................................................... 3
Retirement Plan Services .......................................................................................... 4
Financial Planning Services ....................................................................................... 5
ITEM 5- FEES AND COMPENSATION .......................................................................... 6
Description ................................................................................................................. 6
Advisory Services ...................................................................................................... 6
Fee Billing .................................................................................................................. 6
Past Due Accounts and Termination of Agreement ................................................. 10
Other Fees or Expenses .......................................................................................... 11
ITEM 6- PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ........ 12
Sharing of Capital Gains .......................................................................................... 12
ITEM 7- TYPES OF CLIENTS ...................................................................................... 13
Description ............................................................................................................... 13
Account Minimums ................................................................................................... 13
ITEM 8- METHODS OF ANALYSIS, INVESTMENT STRATEGIES, & RISK OF LOSS
...................................................................................................................................... 13
Methods of Analysis ................................................................................................. 13
Investment Strategies .............................................................................................. 13
Risk of Loss ............................................................................................................. 14
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Carson Advisory Group
ITEM 9- DISCIPLINARY INFORMATION ..................................................................... 16
Legal and Disciplinary .............................................................................................. 16
ITEM 10- OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ................. 16
Financial Industry Activities ...................................................................................... 16
Affiliations ................................................................................................................ 17
ITEM 11- CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS & PERSONAL TRADING ................................................................ 17
Code of Ethics.......................................................................................................... 17
Participation or Interest in Client Transactions ......................................................... 18
Personal Trading...................................................................................................... 18
ITEM 12- BROKERAGE PRACTICES .......................................................................... 19
Selecting Brokerage Firms and Best Execution ....................................................... 19
Soft Dollars .............................................................................................................. 20
Order Aggregation ................................................................................................... 21
ITEM 13- REVIEW OF ACCOUNTS ............................................................................. 21
Periodic Reviews ..................................................................................................... 21
Review Triggers ....................................................................................................... 21
Regular Reports ....................................................................................................... 21
ITEM 14- CLIENT REFERRALS AND OTHER COMPENSATION .............................. 21
Incoming Referrals and Solicitor Arrangements ....................................................... 21
Referrals Out ........................................................................................................... 22
Reimbursement for Client Events or Training .......................................................... 22
Margin Interest and Securities Based Lending Programs ........................................ 22
ITEM 15- CUSTODY ..................................................................................................... 23
ITEM 16- INVESTMENT DISCRETION ........................................................................ 23
Discretionary Authority for Trading ........................................................................... 23
ITEM 17- VOTING CLIENT SECURITIES .................................................................... 23
Proxy Votes ............................................................................................................. 23
ITEM 18- FINANCIAL INFORMATION ......................................................................... 24
Financial Condition .................................................................................................. 24
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CARSON ADVISORY GROUP’S BUSINESS CONTINUITY PLAN DISCLOSURE .... 25
PRIVACY NOTICE ................................................................................................... 26
PART 2B OF FORM ADV: BROCHURE SUPPLEMENT ........................................ 28
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Carson Advisory Group
ITEM 4- ADVISORY BUSINESS
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” or “RJA”) 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. Clients should consult a professional tax advisor to determine their individual tax
situation.
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Carson Advisory Group
As of December 31, 2024, Carson Advisory Group had the following in assets under
management:
Discretionary Assets ......................................................$681,232,856
Non-Discretionary Assets...............................................$90,474,199
Assets Under Advisement2.............................................$65,447,450
Total Assets Managed is $837,154,505
Carson Advisory Group owners, employees, and related personnel have a brokerage
relationship with Raymond James Financial Services, Inc., member FINRA/SIPC, (“RJFS”),
Assets serviced in that capacity, when acting as registered representatives of RJFS, totaled
approximately $133,886,987 on 12-31-24. The total assets serviced for both our fee based
and brokerage relationships was approximately $971,041,492 on 12-31-24.
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,
the client 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 Services
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.
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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 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 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
3 Accounts managed by other asset managers are included in our assets under advisement.
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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 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.
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Carson Advisory Group
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 Services
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
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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.
ITEM 5- FEES AND COMPENSATION
Description
Carson Advisory Group bases its advisory fees on a percentage of assets under management.
Advisory fees are negotiable, and the decision to accept a negotiated fee is at the discretion of
the IAR. Therefore, clients similarly situated may pay significantly higher or lower fees than other
clients. Factors involved in this negotiation include, but are not limited to, the nature and size of
the overall relationship with the IAR and the level and type of advisory or other financial services
that are expected to be provided. Unless a lower rate has been negotiated, Carson Advisory
Group will charge fees based upon the applicable standard fee schedule detailed below. In
some instances, Carson Advisory Group charges hourly rates and fixed fees for consulting
services.
Advisory Services
The annual Advisory Service Agreement maximum fee is based on a percentage of the
investable assets according to the following schedule:
Advisory Fee Annualized Fee
Up to $1 million 1.50%
$1 million up to $2 million 1.25%
$2 million up to $5 million 1.00%
$5 million up to $10 million 0.75%
$10 million and up 0.50%
*The previous fee schedule will remain in effect for Ambassador contracts signed prior to July 1,
2021.
*We generally require a minimum account size of $25,000 for the Ambassador wrap-fee
program. However, each IAR has the discretion to require a minimum account size less than
$25,000.
*The above fee schedule represents Carson Advisory Group’s portion of the advisory fee, which
is the total for Ambassador accounts. Accounts managed by other asset managers typically
charge a manager fee that is in addition to the advisory fee we charge. Please see “Accounts
Managed by Other Asset Managers” on page 12 for additional details.
*Each IAR has the ability to reduce fees based on total family or corporate relationship.
Commonly, fees are discounted for nonprofit clients and 401(k)/Profit Sharing Plans.
Fee Billing
Advisory Accounts Custodied at Raymond James
The annual Advisory Fee is typically payable quarterly in advance. When the Account is
incepted, the Advisory Fee is billed for the remainder of the current billing period and is based
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on the initial contribution to the account. The initial payment will become due in full on the date
of inception. Subsequent quarterly Advisory Fees will be calculated based on the Account
Value, excluding any non-billable assets, as of the last business day of the previous calendar
quarter and will become due the following business day. For fee billing purposes, the term
“Account Value” shall mean the absolute market values of each of the non-cash assets in the
account, long or short, including all cash credit balances, but excluding cash debit balances and
non-billable assets. For purposes of calculating Account Value, the market value of any fee-
based annuity held in an advisory account is based on the market value of the annuity as
disclosed on the client’s Raymond James quarterly statement as provided to Raymond James
by the insurance company. If cash or securities, or a combination thereof, amounting to at least
$100,000 are deposited to or withdrawn from a client’s account on an individual business day in
the first two months of the quarter, Raymond James will:
(i)
assess the Fee based on the Account Value on the date of deposit for the pro rata
number of days remaining in the quarter, or
(ii)
refund the prepaid Fee based on the Account Value on the date of withdrawal for the pro
rata number of days remaining in the quarter.
During the last month of the quarter, no additional Fees or adjustments to previously assessed
Fees will be made in connection with deposits or withdrawals that occur during the last month
of the quarter unless at the client’s request, subject to approval by AMS.
In spite of the above $100,000 adjustment threshold, Raymond James reserves the right, to
process or not process Fee adjustments when the source and destination of deposits and
withdrawals involve the client’s other fee-based advisory accounts.
Unless the client elects to receive a separate billing invoice, the client authorizes and directs
Raymond James, when acting as custodian, or sub-custodian, to deduct Advisory Fees from
their account(s). Clients will be provided statements, at least quarterly, showing all amounts
disbursed from their account(s), including the amount of the Advisory Fee and the Account
Value on which the fee was based and details of the manner in which the fee was calculated.
The Advisory Fee includes execution charges except: (1) certain dealer-markups and odd lot
differentials, taxes, exchange fees and any other charges imposed by law with regard to any
transactions in the Account; and (2) offering concessions, and any other fees and expenses for
purchases of public offerings of securities and certificates of deposit as more fully disclosed in
the prospectus and offering documents. Client may also incur charges for other services
provided by RJFS, through RJA, not directly related to the execution and clearing of
transactions including, but not limited to, IRA custodial fees, safekeeping fees, interest charges
on margin loans or short positions, and fees for legal or courtesy transfers of securities.
While there are reasonable controls in place to monitor for the accuracy of advisory fees, it is
the responsibility of the client to verify accuracy of fees, including the advisory fee rate applied
to the account(s).
Other Compensation Considerations:
Non-Billable Assets
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Certain securities may be held in an Ambassador account and designated non-billable assets.
There are two primary categories of non-billable assets: Client-designated and Raymond
James-designated. Client-designated non-billable assets may be designated by IARs that do not
wish to collect an advisory fee on certain assets, while Raymond James-designated non-billable
assets are designated as such by Raymond James in conformance with internal policy. For
example, an IAR may make an arrangement with a client that holds a security that the IAR did
not recommend or the client wishes to hold for an extended period of time and does not wish for
their IAR to sell for the foreseeable future. In such cases, the IAR may elect to waive the
advisory fee on this security but allow it to be held in the client’s advisory account – such
designations fall into the Client-designated category. Alternatively, Raymond James may
determine that certain securities may be held in an advisory account but are temporarily not
eligible for the advisory fee (mutual funds, market-linked notes, market-linked certificates of
deposit, and unit investment trusts (“UITs”) purchased with a front-end sales charge through us
within the last two years, dependent on the investment, and certain primary market offerings
with embedded commissions). Certain mutual funds converted to advisory fee eligible share
classes may become eligible if held at least one year, subject to certain conditions. Certain
primary market offerings with embedded commissions become eligible for fee billing, if held for
at least one year from the trade date where commissions were incurred. Assets designated by
Raymond James as temporarily exempt from the advisory fee fall into the Raymond James-
designated category. In this category, an advisory fee will not be assessed during the period the
asset is not fee eligible. Alternative investments that pay upfront and/or ongoing commissions
or administrative/servicing fees are designated as non-billable assets for as long as the position
is held in the advisory account. Uninvested cash can be coded as a non-billable asset.
The following chart illustrates which Advisory Accounts permit the use of Client-Designated and
Raymond James-Designated non-billable assets:
Account Type Client-Designated Raymond James-Designated
Non-retirement Permitted Permitted
Retirement Not Permitted (except cash) Permitted
Non-billable assets will not be included in the Account Value when calculating applicable asset-
based advisory fee rates. For clients with multiple fee-based accounts, the Relationship Value
(that is, the total aggregate Account Values of all related accounts) will be used to determine the
applicable fee rate that will be assessed. However, clients should understand that any assets
held as non-billable assets will not be included in the Relationship Value.
Asset –Based Fee Aggregation- Fee Based Accounts
Fee-based accounts are aggregated for billing purposes based primarily on information provided
by IARs and clients; however, it is the client’s obligation to notify us if there are accounts that the
client believes should be included as “related” and we (through Raymond James) reserve the
right to determine whether accounts are “related” in our sole discretion. Clients may request that
we aggregate their fee-based accounts for billing purposes so that each account will pay a fee
under the applicable program fee schedule that is calculated on the basis of the Relationship
Value. In general, related accounts are typically combined based on how the client instructs
their IAR to link their accounts for the delivery of statements, trade confirmations and other
forms of client communications. For example, the combination of accounts contained in an
account statement delivery packet delivered to a unique address will typically form the basis of
fee-based account combinations. However, additional accounts may be considered by the IAR
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even when statements are being delivered to different addresses. While we will attempt to
identify an individual client’s related fee-based accounts based on their unique social security
number or tax identification number, clients should understand that combining related accounts
effectively acts as a discount to the standard program fee schedule by allowing the client to
achieve a lower breakpoint rate as their Relationship Value increases. As a result, it is important
for clients to consult with their IAR, as factors other than the social security number or tax
identification number may be considered by the IAR when combining accounts for fee billing
purposes. For example, a spouse or domestic partner, their children or other relatives’ accounts
may be combined based on their collective relationship with their IAR. Please note that we may
be limited in our ability to combine a client’s retirement accounts where a prohibited transaction
under the Employee Retirement Income Security Act of 1974 or the Internal Revenue Code of
1986, as amended, may result.
Billing on Cash-Balances Held in Ambassador Accounts
If the cash sweep and foreign currency balances (“cash”) (not non-sweep money market funds)
exceeds 20% of the Account Value as of the last business day of the quarter (“the valuation
date”) for three (3) consecutive quarterly valuation dates, the amount in excess of 20% is
excluded from billing (the “Cash Rule”). For example, an Ambassador account that held 30% of
the Account Value for three (3) consecutive billing valuation dates (March 31st, June 30th, and
September 30th) would have the amount in excess of 20% excluded from the Account Value
upon which Fees are applied. For simplicity of illustration, assuming an account was valued at
$100,000 for all three (3) quarterly billing periods, with $30,000 held in cash, the September
30th valuation date would exclude $10,000 of the cash from the Account Value when assessing
the Fee.
The exclusion of excess cash from the Fee is intended to benefit clients holding substantial cash
balances (as a percentage of the total individual Account Value) for an extended period of time.
The portion of the account held in cash experiences negative performance when the applicable
Fee charged is higher than the return received on the cash sweep balance.
Within the Ambassador account, the Cash Rule applies on an individual account basis. The
Cash Rule may pose a financial disincentive to an IAR as the portion of cash sweep balances in
excess of 20% is excluded from the Fee charged to the account. This may cause an IAR to
recommend a reallocation of the account from cash to advisory fee eligible investments,
including money market funds, or to recommend against raising cash, to avoid the application of
the Cash Rule and therefore receive a Fee on the full account value. Clients may direct their
IAR to raise cash by selling investments or hold a predetermined percentage of their account in
cash at any time. The Cash Rule is applicable only to cash sweep and foreign currency
balances and, therefore, non-sweep money market funds would not result in excess “cash”
balances being excluded from the asset based advisory fee calculation.
Cash balances in the AMS Managed Program accounts are generally expected to be a small
percentage of the overall account value, as determined by the Managers and are therefore not
subject to the Cash Rule.
Investment of Cash Reserves
Raymond James offers a cash sweep program that allows clients to earn interest on cash
awaiting investment (“Cash Sweep Program”). There is a deposit sweep called the Raymond
James Bank Deposit Program (“RJBDP”), which includes several variations. In addition
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Raymond James offers a cash feature called the Client Interest Program (“CIP”) in which eligible
accounts earn interest on cash awaiting investment. The Cash Sweep Program is offered at no
additional charge or cost to the client.
For important information on what sweep programs are available for each account type and how
each sweep program operates, please refer to the “Important Client Information” Brochure,
which can be obtained from the Raymond James public website:
https://www.raymondjames.com/legal-disclosures, or from IAR. For current interest rates for CIP
and RJBDP, refer to Deposit Rates - Client Resources | Raymond James. For information on the
rate being paid on particular account(s), please contact IAR or review periodic account
statements.
Past Due Accounts and Termination of Agreement
The client or the investment manager may terminate any of the aforementioned services at any
time by notice to the other party. At termination, the prorated portion of the unearned fee for the
quarter of termination will be refunded. All fees due under the agreement at termination will be
deducted from the client’s account before assets are delivered from the account.
Carson Advisory Group reserves the right to stop work on any account that is more than 30
days overdue, or if normally required or updated paperwork is not returned in a timely fashion.
Conflicts and Fees Associated with Managers Offered on the RJFS Platform
As described throughout this Brochure, Carson Advisory Group has a relationship with
Raymond James. This relationship includes access to mutual fund wrap fee programs offered
through the Raymond James Platform by third party money managers and the Asset
Management Services (AMS) division of Raymond James. IARs that are also registered
representatives of RJFS are limited to selecting programs that are approved by Raymond
James and which may contain share classes of mutual funds that are not the lowest fee share
class offered by the fund family, thus resulting in a higher cost to own the fund compared to
lower fee share classes. However, those are rare instances and with few exceptions, those
lowest expensed funds are mostly available.
In addition, when selecting what managers will be highlighted on Raymond James’ platform,
Raymond James has a financial incentive to favor investments (or managers that trade in
certain investments) that pay them education and marketing support fees (“E&M support fees”),
networking and/or omnibus and other administrative and/or service-related fees over
investments that do not. They also have an incentive to select those investments that pay higher
amounts of compensation for E&M support fees, networking and/or omnibus and other
administrative and service-related fees over those investments that pay lower amounts of
compensation. They also receive non-E&M support fees. These arrangements impact the
number of investment options our IARs can utilize to manage the client’s account, and the
expenses associated with those options. It is important to understand that less expensive
alternatives are available elsewhere.
Raymond James addresses the conflicts of interests associated with the payment of
compensation in the following ways. They disclose compensation they receive from product
sponsors and other service providers which are further detailed on their public website found
here: Packaged Product Disclosures - Legal Disclosures | Raymond James. They have
adopted various policies and procedures reasonably designed to prevent the receipt of
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compensation from third-parties from affecting the nature of the advice they provide. Regarding
the Freedom and Freedom UMA Programs managed by Raymond James, the AMS Investment
Committee makes investment decisions based on objective, investment related due diligence
and are agnostic to the compensation arrangements with the various investment companies.
Additionally, they and their affiliates select investments that are available on the investment
advisory platform and offered through their advisory Program based on qualitative and
quantitative evaluation of such factors as performance, risk management policies and
procedures and consistency of the execution of their strategy.
However, similar to seeking best execution, the determining factor we used in choosing to
partner with Raymond James is not always the lowest possible cost, but whether the
relationship represents the best platform through which to provide the majority of our advisory
services. To make this determination, we take into consideration the full range of Raymond
James’ services, including among others, the ability of our IARs to offer brokerage services as
registered representatives, their fees (both to us and to our clients), their financial wherewithal,
their custodial services, and their responsiveness. Accordingly, although Carson Advisory Group
seeks to offer the most cost effective solutions for our clients, Raymond James may not
necessarily offer the lowest cost mutual fund share classes in all instances. Raymond James
may select certain mutual fund product offerings and share classes because they pay Raymond
James compensation for the administrative and recordkeeping services Raymond James
provides to the mutual fund, and which we believe is passed along to us in the execution of their
services to us. The client should understand that another custodian may offer the same, or
similar, mutual fund products at a lower overall cost.
Carson Advisory Group’s IARs and supervisors review client accounts to ensure they are
consistent with the client’s stated needs, objectives, and financial situation. While we believe
Raymond James allows us to provide quality services to our clients, which is important and
helpful to our management of client assets and to clients' overall success, the client needs to
understand the potential added cost to his or her portfolio. Every client should review the fees
charged by the funds and our fees to fully understand the total amount of fees he or she is
paying, and in doing so will have the ability to adequately evaluate the advisory services being
provided. We are happy to explain these products and any associated conflicts in detail.
Other Fees or Expenses
Fees and expenses such as but not limited to electronic fund and wire transfer fees, custodial
fees, taxes, and borrowing costs are not included in the advisory fees described above and are
the responsibility of the client. See Brokerage Practices section for a discussion of our practices.
Open-end funds, closed-end funds, ETFs and fee-based annuities generally charge a
management fee and operating expense for services as investment managers. Distribution fees
charged by mutual fund companies (also known as trails or 12b-1 fees) pursuant to Rule 12b-1
under the Investment Company Act of 1940 are included in the calculation of the mutual fund
company’s annual operating expenses. If such fees are received by Raymond James from
funds acquired in a client’s account, the client will receive a credit to the account in the amount
equal to such fees received from the funds. 12b-1 fees are credited bi-monthly to accounts, as
applicable. In addition, certain mutual funds may impose short-term trading charges for
redemptions (which they impose to deter market timing).
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For specific information on each mutual fund or ETF’s expenses, please refer to its prospectus.
For annuities, depending on the product, and as more fully described in the annuity contract,
clients may pay an early withdrawal fee if canceled during the surrender charge period. Costs
and fees vary between insurance products. Please refer to the annuity contract for a detailed
description of charges.
All of the aforementioned fees are in addition to the fees paid by the client to Carson Advisory
Group.
IARs of Carson Advisory Group are registered representatives of RJFS and some are also
licensed insurance agents who receive other forms of compensation (e.g., commissions) for
securities products they offer and sell through RJFS. These products are not offered through
Carson Advisory Group and the client is not charged investment advisory fees on such products
sold through RJFS. However, these activities create real or potential conflicts for the IAR, as
they are incentivized to recommend such products. Carson Advisory Group has policies and
procedures in place to recognize and appropriately monitor such conflicts that arise between the
IAR’s multiple capacities. These activities are discussed in Item 10 - Other Financial Industry
Activities and Affiliations.
Accounts Managed by Other Asset Managers3
As noted in Item 4 above, Carson Advisory Group offers several wrap fee programs sponsored
by Raymond James. These programs are detailed in the RJA Wrap Fee Program Brochure.
Most programs include a separate manager fee ranging from 0.12% to 0.50%, which is in
addition to our advisory fee but combined into a single charge. The specific manager fee is
disclosed in the applicable RJA Wrap Fee Program Brochure and should be added to our fee
schedule on Page 6 to determine the total advisory fee. For more details, clients should consult
their IAR and refer to the brochure for information on fees, charges, investment minimums, and
other key considerations.
*For more information, including investment minimums, please refer to the RJA Wrap Fee Program Brochure:
https://www.raymondjames.com/-/media/rj/dotcom/files/legal-disclosures/rja-wrap-fee-program.pdf.
Employer Sponsored Retirement Accounts Maintained at Recordkeeper
As described in Item 4, Carson Advisory Group Acts as an ERISA 3(21) fiduciary for some
employer sponsored retirement plans. Advisory fees for these plans, which are custodied at
recordkeepers other than Raymond James, are billed and remitted directly through the
recordkeeper. The billing frequency and method depends upon the recordkeeper’s policy over
which we have no control. The annual advisory fee is agreed upon at the start of the relationship
and can vary based upon the scope of work involved and the plan size, but will not exceed
1.00%
ITEM 6- PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Sharing of Capital Gains
Carson Advisory Group is not compensated through performance-based fees. Performance-
based fees are fees that can be charged based upon a share of capital gains on or capital
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appreciation of the assets of a client. As stated above, our fees are based on the market value
of client accounts and are not dependent upon whether or not accounts gain value.
ITEM 7- TYPES OF CLIENTS
Description
Carson Advisory Group generally provides investment advice to individuals, pension and profit-
sharing plans, trusts, estates, charitable organizations, foundations, and corporations or small
business entities.
Client relationships vary in scope and length of service.
Account Minimums
We generally require a minimum account size of $25,000 for the Ambassador wrap-fee
program. However, each IAR has the discretion to require a minimum account size less than
$25,000.
ITEM 8- METHODS OF ANALYSIS, INVESTMENT STRATEGIES, & RISK OF LOSS
Methods of Analysis
Security analysis methods may include charting, fundamental analysis, technical analysis, and
cyclical analysis.
The main sources of information include financial newspapers and magazines, inspections of
corporate activities, research materials prepared by others, corporate rating services, timing
services, annual reports, prospectuses, filings with the Securities and Exchange Commission,
and company press releases.
Other sources of information that Carson Advisory Group may use include Morningstar, FactSet,
and the World Wide Web.
Investment Strategies
The primary investment strategy used on client accounts is strategic asset allocation, using
actively managed funds, passively-managed indices and ETFs as the core investments.
Portfolios are globally diversified, to a degree, in an effort to spread geo-political risk as well as
add growth prospects where appropriate.
A minority of our accounts are composed primarily of individual securities.
The investment strategy for a specific client is based upon the objectives stated by the client
during consultations. The client may change these objectives at any time. The client is
encouraged to either specifically execute an Investment Policy Statement that documents his or
her objectives and desired investment strategy or construct one in consultation with each
advisor.
Some accounts can employ margin transactions, and the use of options writing (including writing
covered options, uncovered options or spreading strategies), though there are separate
arrangements, involving further qualifications and they are client need-driven.
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Risk of Loss
There are inherent risks involved for each investment strategy or method of analysis we use and
the particular type of security we recommend. Investing in securities involves risk of loss, which
the client should be prepared to bear. Specific risks of our significant investment strategies
include, but are not limited to:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. An example, with longer dated fixed investments, would be that when interest
rates rise, yields on existing bonds become less attractive, causing their market values
to decline. Interest rate volatility, in general, lends itself to higher equity volatility.
(Volatility itself does not equate to risk over longer periods of time).
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk can be caused by
external factors independent of a security’s particular fundamental circumstances. For
example, political, economic, and social conditions may trigger general market events,
or more specific, sector volatility.
•
Inflation Risk: This type of risk is the chance that future cash from an investment will
not be worth as much due to inflation. Inflation is the increase in the price of goods and
services, which causes purchasing power to erode.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities and is commonly a concern with maturing or called
debt issues.
• Business or Economic Cycle Risk: These risks are associated with a particular industry,
government, or central bank. Political decisions can change, leading to macro-economic
concerns or even to more specific individual industry sector concerns.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product, a product or market with low expenses to trade and large market size, with
many market participants. For example, Treasury Bills are highly liquid, while real estate
properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or could demonstrate concern via a declining market
value.
• Default Risk: Both for-profit (corporate) and non-profit (federal, state, and municipal)
borrowers are subject to the timely repayment of principal and interest. In times of
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dramatic financial stress, short-term debt obligations can be quickly re-priced should
that repayment ability be questioned or challenged threatening the financial viability of
the subject entity, particularly if a refinancing need is untimely.
• Valuation Risk: This is the risk that an asset is improperly valued in relation to what
would be received upon its being sold or redeemed at maturity.
• Tax Risk: This is the risk that tax laws may change and impact the underlying
investment premise or profitability of an investment.
• Cybersecurity Risk: Intentional cybersecurity breaches include unauthorized access to
systems, networks, or devices (such as through "hacking" activity); infection from
computer viruses or other malicious software code; and attacks that shut down, disable,
slow, or otherwise disrupt operations, business processes, or website access or
functionality. In addition, unintentional incidents can occur, such as the inadvertent
release of confidential information (possibly resulting in the violation of applicable
privacy laws). A cybersecurity breach could result in the loss or theft of customer data or
funds, the inability to access electronic systems ("denial of services"), loss or theft of
proprietary information or corporate data, physical damage to a computer or network
system, or costs associated with system repairs. Such incidents could cause an
investment fund, the advisor, a manager, or other service providers to incur regulatory
penalties, reputational damage, additional compliance costs, or financial loss.
• Technology Risk: Raymond James must rely in part on digital and network technologies
to conduct its business and to maintain substantial computerized data relating to client
account activities. These technologies include those owned or managed by Raymond
James as well as those owned or managed by others, such as financial intermediaries,
pricing vendors, transfer agents, and other parties used by Raymond James to provide
services and maintain its business operations. These technology systems may fail to
operate properly or become disabled as a result of events or circumstances wholly or
partly beyond Raymond James’ or its service providers’ control. Technology failures,
whether deliberate or not, including those arising from use of third-party service
providers or client usage of systems to access accounts, could have a material adverse
effect on our business or our clients and could result in, among other things, financial
loss, reputational damage, regulatory penalties or the inability to conduct business.
• ETF and Mutual Funds Risk: ETFs and mutual funds are subject to internal
management and other expenses, which will be indirectly paid by clients. As a result,
the cost of our investment strategies will be higher than the cost of investing directly in
ETFs or mutual funds, as there are two levels of fees. ETFs and mutual funds are
subject to specific risks, depending on the nature of the fund.
ETFs are professionally managed pooled vehicles that invest in stocks, bonds, short-
term money market instruments, other mutual funds, other securities, or any
combination thereof. ETF managers trade fund investments in accordance with fund
investment objectives. ETF risk can be significantly increased for funds concentrated in
a particular sector of the market, or that primarily invest in small cap or speculative
companies, use leverage (i.e., borrow money) to a significant degree, or concentrate in
a particular type of security (i.e., equities), rather than balancing the fund with different
types of securities.
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ETFs can be bought and sold throughout the day like stocks, and their price can
fluctuate throughout the day. During times of extreme market volatility, ETF pricing may
lag versus the actual underlying asset values. This lag usually resolves itself in a short
period of time (usually less than one day); however, there is no guarantee this
relationship will always occur.
• Pandemic Risks: Disease outbreaks that affect local economies or the global economy
may materially and adversely impact our investment portfolios and/or our business. For
example, uncertainties regarding disease outbreaks have resulted in serious economic
disruptions across the globe. These types of outbreaks can be expected to cause
severe decrease in core business activities such as manufacturing, purchasing, tourism,
business conferences and workplace participation, among others. These disruptions
lead to instability in the marketplace, including stock market loses and overall volatility.
In the face of such instability, governments may take extreme and unpredictable
measures to combat the spread of disease and mitigate the resulting market disruptions
and losses. We have in place business continuity plans reasonably designed to ensure
that we maintain normal business operations, and that our investment portfolios and
client assets are protected, and we periodically test those plans. In the event of a
pandemic or an outbreak, there can be no assurance that we or our service providers
will be able to maintain normal business operations for an extended period of time or
will not lose the services of key personnel on a temporary or long-term basis due to
illness or other reasons. The full impact of a pandemic or disease outbreaks are
unknown, resulting in a high degree of uncertainty for potentially extended periods of
time.
The above list of risk factors is not intended to be a complete list or explanation of the risks
involved in each of our investment strategies. The client is encouraged to consult his or her
financial advisor, legal counsel and tax professional on an initial and continuous basis in
connection with selecting and engaging in the services provided by us. In addition, due to the
dynamic nature of investments and markets, strategies may be subject to additional and
different risk factors not discussed above.
ITEM 9- DISCIPLINARY INFORMATION
Legal and Disciplinary
Carson Advisory Group and its employees have not been involved in legal or disciplinary
events related to past or present investment clients.
ITEM 10- OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
Financial Industry Activities
Carson Advisory Group is not registered as a securities broker-dealer, or a futures commission
merchant, commodity pool operator or commodity trading advisor and does not in any capacity
serve as a securities dealer.
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Affiliations
Securities Brokerage
Registered Representatives, through their affiliation with RJFS, receive commissions
generated through the buying and selling of securities. In addition, the IAR may recommend a
third-party asset manager who has a direct affiliation with RJFS or a contractual relationship
with Raymond James. RJFS will pay the broker, who is the IAR, fees or commissions as stated
in the contract the client signs with that third-party manager. This additional compensation
provides an incentive to Carson Advisory Group or the IAR, in exercising discretion or making
recommendations for the client’s account, to choose or recommend investments that result in
higher compensation to our Firm or the IAR. In these circumstances, it is our duty to determine
that an investment made in the client’s account or recommended to the client that results in
such additional compensation is in the client’s best interest based up on the information that
has been provided to us. Carson Advisory Group has implemented a Compliance Program to
monitor its compensation arrangements and IARs to help ensure that client assets are
invested in, what we believe, are the best available mutual funds for the strategies we are
implementing and monitoring. As always, please see a fund’s prospectus for more information
about fees. Commission charges may vary depending upon any number of factors, including
type of security, purchase or sale, secondary market price, volume of trading, market float, and
traded or listed exchange. Carson Advisory Group believes that commissions charged by
RJFS are competitive with other full-service broker-dealers and that they are fair and
reasonable. Commissions charged by RJFS, while generally competitive, are not necessarily
the lowest in the industry. Brokerage transactions are placed only through RJFS. There is an
inherent potential conflict of interest in this arrangement in that Carson Advisory Group,
through its IARs or related persons who are Registered Representatives of RJFS, share in a
percentage of the brokerage commissions.
All Carson Advisory Group employees have a Raymond James email address.
As a result, all email sent by Carson Advisory Group employees to our clients and all email
received by Carson Advisory Group from our clients, are hosted on and transmitted by the
Raymond James email platform. This means that all information (including attachments),
included in email messages between Carson Advisory Group and the sender/recipient, is
stored on Raymond James servers. We do not control the Raymond James email platform.
This email platform is subject to compliance reviews and audits by Raymond James personnel.
Insurance Services
Carson Advisory Group and its IARs or related persons may have insurance company
affiliations from which they receive commissions. Clients are under no obligation to execute
recommendations relating to insurance and/or annuity products through Carson Advisory
Group.
ITEM 11- CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS &
PERSONAL TRADING
Code of Ethics
The Investment Advisers Act of 1940 imposes a fiduciary duty on investment advisers. As a
fiduciary, Carson Advisory Group has a duty of utmost good faith to act solely in the best
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interest of each of our clients. Our clients entrust us with their funds, which in turn places a
high standard on our conduct and integrity. Our fiduciary duty compels all employees to act
with the utmost integrity in all of our dealings. Employees will not take inappropriate advantage
of their position with the firm and all employees are expected to comply with federal securities
laws.
This fiduciary duty is the core principle underlying this Code of Ethics and Personal Trading
Policy and represents the expected basis of all of our dealings with our clients.
Participation or Interest in Client Transactions
Carson Advisory Group and its employees may buy or sell securities that are also held by
clients. Employees comply with the provisions of the Carson Advisory Group Compliance
Manual, which in almost all points is reflective of the high standards required in our legal,
mutual relationship with RJFS.
Personal Trading
Employees are expected to conduct their personal securities transactions in accordance with
the Personal Trading Policy and will avoid all conflicts of interest with the client. The Chief
Compliance Officer (“CCO”) of Carson Advisory Group is Lindsey Seagraves. She reviews the
trades of employees. Employees with questions regarding the appearance of a conflict with a
client should consult with the CCO before taking action that may result in an actual conflict.
The personal trading reviews ensure that the personal trading of employees does not affect the
markets, and that clients of the firm receive preferential treatment.
Carson Advisory Group has created a Code of Ethics which establishes standards and
procedures for the detection and prevention of certain conflicts of interest including activities by
which persons having knowledge of the investments and investment intentions of Carson
Advisory Group might take advantage of that knowledge for their own benefit. Carson Advisory
Group has in place Ethics Rules (the “Rules”), which are comprised of the Code of Ethics and
Insider Trading policies and procedures. The Rules are designed to ensure that our personnel
(i) observe applicable legal (including compliance with applicable state and federal securities
laws) and ethical standards in the performance of their duties; (ii) at all times place client
interests first; (iii) disclose all actual or potential conflicts; (iv) adhere to the highest standards
of loyalty, candor and care in all matters relating to our clients; (v) conduct all personal trading
consistent with the Rules and in such a manner as to avoid any actual or potential conflict of
interest or any abuse of their position of trust and responsibility; and (vi) not use any material
non-public information in securities trading. The Rules also establish policies regarding other
matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio
holdings information.
Under the general prohibitions of the Rules, our personnel may not: 1) effect securities
transactions while in the possession of material, non-public information; 2) disclose such
information to others; 3) participate in fraudulent conduct involving securities held or to be
acquired by any client; and 4) engage in frequent trading activities that create or may create a
conflict of interest, limit their ability to perform their job duties, or violate any provision of the
Rules.
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Carson Advisory Group requires personnel to conduct personal investments without
compromising client interests. Securities transactions are permitted only under the conditions
outlined in our Code of Ethics, which mandates reporting of non-exempt personal transactions
for compliance review. A copy of the Code of Ethics is available upon request. Firm personnel,
including officers and employees, may invest in securities also held by clients or transact in
securities they personally own on behalf of clients, at or about the same time they invest for
clients, provided they adhere to our Personal Trading Policy. Client transactions always take
priority. We maintain records of all securities transactions, and our Compliance Department
reviews all trading activity
Carson Advisory Group clients or prospective clients may request a copy of the firm's Code of
Ethics by contacting Lindsey Seagraves at (706) 543-6578.
As part of its fiduciary duties to clients, Carson Advisory Group endeavors at all times to put
the interests of its advisory clients first. Clients should be aware, however, that the receipt of
economic benefits by Carson Advisory Group in and of itself creates a potential conflict of
interest.
Donations to Charities
From time to time, Carson Advisory Group donates to charitable organizations or participates
in charity fundraisers that may be affiliated with clients. On occasion, such donations are
made in response to requests from clients, or their personnel. Because our contributions could
result in the recommendation of Carson Advisory Group or its products, such contributions can
raise a potential conflict of interest. No contribution will be made if the contribution implies that
continued or future business with Carson Advisory Group depends on making such
contribution.
ITEM 12- BROKERAGE PRACTICES
Selecting Brokerage Firms and Best Execution
Carson Advisory Group currently uses Raymond James & Associates, Inc. (RJA) and
Raymond James Trust Company of New Hampshire (RJTCNH), both wholly -owned
subsidiaries of Raymond James Financial, Inc. as its custodians. RJTCNH provides custodial
services for all individual retirement accounts (IRAs) held at Raymond James & Associates
and RJA is sub-custodian.
Additionally, IARs are registered representatives of RJFS and will recommend RJFS to
advisory clients for plan implementation and brokerage services. These individuals are subject
to FINRA Conduct Rule 3280 that restricts them from conducting securities transactions away
from RJFS. Therefore, clients are advised that such IARs are limited to conducting securities
transactions through RJFS. It may be the case that RJFS charges a higher fee than another
broker charges for a particular type of service, such as transaction fees. Clients may utilize the
broker dealer of their choice and have no obligation to purchase or sell securities through
RJFS. However, if the client does not use RJFS, the IAR will reserve the right not to accept the
account.
As a registered FINRA broker dealer, RJFS routes order flow through its affiliated broker
dealer, Raymond James. Raymond James is obligated to seek best execution pursuant to
FINRA Rule 5310 for all trades executed; however, better executions may be available via
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another broker dealer based on a number of factors including volume, order flow and market
making activity.
If a client acts upon IAR’s advice and chooses to use one of Raymond James' affiliates, IAR,
acting in the capacity of a registered representative, may receive compensation in the form of
commissions from the affiliate. If a client chooses to use an IAR in his individual capacity as an
insurance agent, the individual IAR could receive a commission. Additionally, if a client
purchases a mutual fund containing a 12b-1 fee, the adviser and representative may receive
such fee, but only as that IAR is acting as a registered representative with RJFS and not as an
advisor with Carson Advisory Group.
The custodian may have its own fee and cost schedules, as it is entitled to as a custodian of
the account. These fees and costs are completely independent of Carson Advisory Group, and
Carson Advisory Group does not receive any portion of these collected costs. Please see Item
5 Fees and Compensation for some of these costs.
Carson Advisory Group continuously reviews the accuracy, timeliness and execution of trades
processed through RJFS. Carson Advisory Group selected RJFS for client account custody
and trade processing due to accessibility, electronic trading, efficient and professional service,
technical support, and timely reporting to clients. In addition, client funds are covered through
the excess SIPC coverage maintained by RJFS. RJFS prohibits Carson Advisory Group from
utilizing any other broker-dealer for client custody or securities trading.
Our IARs and related persons may receive research information through its broker-dealer
affiliation on securities, market, and economic conditions. Raymond James does not impose
surcharges on clients for research. However, Raymond James does seek to do investment
banking and other business with some companies covered by its research. Raymond James
complies with all securities laws and regulations to manage these potential conflicts of interest.
Additionally, Raymond James does not require that IARs or related persons recommend any
securities to clients.
It is Carson Advisory Group’s policy that the firm will not affect any principal or agency cross
securities transactions for client accounts. Carson Advisory Group will also not cross trades
between client accounts. Principal transactions are generally defined as transactions where an
adviser, acting as principal for its own account or the account of an affiliated broker-dealer,
buys from or sells any security to any advisory client. A principal transaction may also be
deemed to have occurred if a security is crossed between an affiliated hedge fund and another
client account. An agency cross transaction is defined as a transaction where a person acts as
an investment adviser in relation to a transaction in which the investment adviser, or any
person controlled by or under common control with the investment adviser, acts as broker for
both the advisory client and for another person on the other side of the transaction. Agency
cross transactions may arise where an adviser is dually registered as a broker-dealer or has
an affiliated broker-dealer.
Soft Dollars
Carson Advisory Group has no formal soft dollar arrangements.
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Order Aggregation
In discretionary accounts where the IAR has determined that the purchase or sale of a
particular equity or ETF is appropriate for more than one client, the IAR may aggregate sale
and purchase orders of securities held by the client with similar orders being made
simultaneously for other clients into one “block” order for execution purposes. If a block
transaction is effected by IAR, the client will receive the average price of all transactions
effected to fill the order. As a result, the average price received by the client may be higher or
lower than the price that an individual client may have received had the transaction been
effected independently from the block transaction. Carson Advisory Group will not receive any
additional compensation or remuneration whether or not client orders are aggregated.
ITEM 13- REVIEW OF ACCOUNTS
Periodic Reviews
Account reviews are performed, in essence, on a constant basis by advisors, but particularly
when market conditions or sector volatility increases. Formal Client reviews are encouraged at
least annually but are at the discretion of the client.
Review Triggers
Other conditions that may trigger a review are changes in the tax laws, new investment
information, and changes in a client's own situation.
Regular Reports
Account reviewers are members of the firm's IARs’ team. They are instructed to consider the
client's current security positions and the likelihood that the performance of each security will
contribute to the investment objectives of the client.
Clients receive a confirmation of each transaction and periodic statements from their broker-
dealer.
Clients are also able to view their accounts online, and in some circumstances, clients are
permitted to execute trades online.
Tax related information is included in each account’s 1099 sent annually, including interest and
dividend income, and realized short-term and long-term gains and losses, and our asset
management fees.
ITEM 14- CLIENT REFERRALS AND OTHER COMPENSATION
Incoming Referrals and Solicitor Arrangements
Carson Advisory Group receives client referrals as a key driver of our growth. These referrals
come from various sources, including current clients, estate planning attorneys, accountants,
employees, personal acquaintances of employees, and other professional connections. The
firm does not compensate referring parties for these types of referrals.
R.J. Chester of Carson Advisory has established referral and solicitor arrangements with
SmartAsset, BlueStar Connections, and The 401K Advisor Line. These agreements vary but
generally involve paying a fee—typically a flat fee—for lead generation, appointments, or
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potential client referrals. While these arrangements do not affect fees the client pays for our
advisory services, they create actual or potential conflicts of interest, as the referring entities
have a financial incentive to recommend our firm.
Despite these potential conflicts, Carson Advisory Group maintains its commitment to
providing objective advice. Our Investment Adviser Representatives (IARs) and supervisors
regularly review client accounts to ensure that our recommendations align with each client’s
stated needs, objectives, and financial situation.
Referrals Out
Carson Advisory Group does not accept referral fees or any form of remuneration from other
professionals when a prospect or client is referred to them.
Reimbursement for Client Events or Training
From time to time, insurance companies, mutual fund companies or the managers of mutual
funds sponsor or pay for client luncheons, or other events that Carson Advisory Group hosts.
This may include third-party speakers that Carson Advisory Group does not have to
compensate (although Carson Advisory Group may also pay consultants to attend these
events or other client meetings to offer their expertise). These arrangements may give rise to
conflicts of interest, or perceived conflicts of interest in that Carson Advisory Group has an
incentive to invest client assets in investment products managed or sold by companies that
provide such benefits to Carson Advisory Group. Carson Advisory Group’s commitment to its
clients and the policies and procedures it has adopted that require the review of such
arrangements by the CCO are designed to limit any interference with Carson Advisory Group’s
independent decision making when choosing the best investment products for our clients.
Margin Interest and Securities Based Lending Programs
Carson Advisory Group is part of a margin debit participation program with Raymond James.
We receive a portion of the margin interest charged to a client’s margin debit balance, currently
15bps (or $.15 for every $100). In addition, the Firm is part of a similar program for security-
based lending through Raymond James Bank. Carson Advisory Group receives a portion of
the loan interest charged to a client that qualifies for this program, currently 25bps (or $.25 for
every $100). These arrangements give rise to conflicts of interest, or perceived conflicts of
interest, as Carson Advisory Group has an incentive to steer client assets to Raymond James
that generate such revenue, rather than to products or custodians that do not generate such
revenue.
Notwithstanding these conflicts, Carson Advisory Group believes that these arrangements do
not interfere with its provision of advice to clients because of its practices and controls. Carson
Advisory Group periodically reviews the fees it has negotiated with Raymond James against
the services it receives. Also, Carson Advisory Group’s IARs and supervisors review client
accounts to ensure they are consistent with their stated needs, objectives, and financial
situation.
22
Carson Advisory Group
ITEM 15- CUSTODY
We do not have custody of client funds or securities. Client assets are held at a qualified
custodian. However, we are deemed to have limited custody of some of our clients’ funds
when they have standing letters of authorization (“SLOAs”) with their custodian to move money
from a client’s account to a third-party, and under that SLOA, it authorizes us to designate the
amount or timing of transfers with the custodian. The SEC has set forth a set of standards
intended to protect client assets in such situations, which we follow. The qualified custodian
will send the client, at least quarterly, a copy of their account statements. The account
statements will reveal the funds and securities held with the qualified custodian, any
transactions that occurred in the account, and the deduction of our fee. Clients should carefully
review the account statements received from the qualified custodian. Clients should contact
us at the address or phone number on the cover of this brochure with any questions about
their statements. Clients should notify us if they do not receive the account statements, at least
quarterly, from the qualified custodian.
ITEM 16- INVESTMENT DISCRETION
Discretionary Authority for Trading
Carson Advisory Group has discretionary authority for most clients’ accounts to trade
securities without the clients’ prior notification or consent. We will only have discretion in an
account with permission from the client. If a client wants to grant discretion in his/her account,
the client will either give discretion in writing by signing an investment advisory agreement, or,
in cases where a Master Advisory Agreement has been signed, provide oral instructions. In
this case, upon approval, the request will be confirmed in writing via an Advisory Feature
Summary that includes the account’s fee rate, features, and details. Carson Advisory Group
usually receives discretionary authority from the client at the outset of an advisory relationship.
Discretionary authority provides IARs with the ability to select the identity and amount of
securities to be bought or sold. In all cases, however, such discretion is to be exercised in a
manner consistent with the stated investment objectives for the particular client account. When
selecting securities and determining amounts, Carson Advisory Group observes the
investment policies, limitations, and restrictions of the clients for which it advises. Investment
guidelines and restrictions must be provided to us in writing.
ITEM 17- VOTING CLIENT SECURITIES
Proxy Votes
Carson Advisory Group does not vote proxies on securities. Clients are expected to vote their
own proxies.
When assistance on voting proxies is requested, Carson Advisory Group will provide
recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client.
On occasion, Carson Advisory Group will assist in the completion of paperwork to accept legal
settlements related to past stock, bond, or mutual fund ownership.
23
Carson Advisory Group
ITEM 18- FINANCIAL INFORMATION
Financial Condition
Carson Advisory Group has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.
24
Carson Advisory Group
CARSON ADVISORY GROUP’S BUSINESS CONTINUITY PLAN DISCLOSURE
Carson Advisory Group has developed a Business Continuity Plan on how we will respond to events
that significantly disrupt our business. Since the timing and impact of disasters and disruptions is
unpredictable, we will have to be flexible in responding to actual events as they occur. With that in
mind, please find information on our business continuity plan outlined below.
Contacting Us – If after a significant business disruption, we are unable to be reached by normal
contact methods at (706) 543-6578 / lindsey.seagraves@raymondjames.com, please visit our
website at www.carsonadv.com. If unable to access us through either of those means, please contact
our custodian, Raymond James, by calling their Client Services line at 800-647-7378, their main line
at 800-248-8863, or visiting their website www.raymondjames.com for instructions on how it may
provide prompt access to client funds and securities, enter orders and process other trade-related,
cash and security transfer transactions.
Our Business Continuity Plan – We plan to quickly recover and resume business operations after a
significant business disruption and respond by safeguarding our employees and property, making a
financial and operational assessment, protecting the firm’s books and records, and allowing our
clients to transact business. In short, our business continuity plan is designed to permit our firm to
resume operations as quickly as possible, given the scope and severity of the significant business
disruption.
Our business continuity plan addresses: data backup and recovery; all mission critical systems;
financial and operational assessments; alternative communications with clients, employees, and
regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-
party impact; regulatory reporting; and assuring our clients’ prompt access to their funds and
securities if we are unable to continue our business.
Our custodian backs up our important records in a geographically separate area. While every
emergency situation poses unique problems based on external factors, such as time of day and the
severity of the disruption, we have been advised by our custodian that its objective is to restore its
own operations and be able to complete existing transactions and accept new transactions and
payments within a timely manner. Client orders and requests for funds and securities could be
delayed during this period.
Varying Disruptions – Significant business disruptions can vary in their scope and impact. Such
disruptions could affect only our firm, the business district where our firm is located, the city where we
are located, or the whole region. Within each of these areas, the severity of the disruption can also
vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will
transfer our operations to a local site when needed and recover and resume business as soon as
possible. In a disruption affecting our business district, city, or region, we will transfer our operations
to a site outside of the affected area and recover and resume business as soon as possible. In either
situation, we plan to continue in business, transfer operations to our custodian if necessary, and notify
our clients through our website. If the significant business disruption is so severe that it prevents us
from remaining in business, we will assure our customers’ prompt access to their funds and
securities.
For more information – If there are questions about our business continuity plan, please contact us
at (706) 543-6578.
25
Carson Advisory Group
PRIVACY NOTICE
Rev.
April 2020
WHAT DOES CARSON ADVISORY GROUP
DO WITH YOUR PERSONAL INFORMATION?
FACTS
Why?
Financial companies choose how they share your personal information. Federal law gives
consumers the right to limit some but not all sharing. Federal law also requires us to tell you how
we collect, share, and protect your personal information. Please read this notice carefully to
understand what we do.
What?
The types of personal information we collect, and share depend on the product or service you
have with us. This information can include:
Investment Experience
and Assets
● Social Security Number and Income
●
● Employment Information and Risk Tolerance
When you are no longer our customer, we continue to share your information as described in this
notice.
How?
Carson Advisory Group
All financial companies need to share customers’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their customers’
chooses to share; and whether
personal information; the reasons
you can limit this sharing.
Can you limit this sharing?
Reasons we can share your personal
information
Does Carson Advisory
Group share?
YES
NO
For our everyday business purposes –
such as to process your transactions, maintain
your account(s), respond to court orders and legal
investigations, report to credit bureaus
NO
We don’t share
For our marketing purposes –
to offer our products and services to you
NO
We don’t share
For joint marketing with other financial
companies
NO
We don’t share
For our affiliates’ everyday business purposes
–
information about your transactions and
experiences
NO
We don’t share
For our affiliates’ everyday business purposes
–
information about your creditworthiness
For non-affiliates to market to you
NO
We don’t share
http://www.carsonadv.com/
Questions? Call 706-543-6578 or go to
26
Carson Advisory Group
Page 2
Who we are
Who is providing this notice?
Carson Advisory Group
What we do
How does Carson Advisory Group
protect my personal information?
To protect your personal information from unauthorized access and
use, we use security measures that comply with federal law. These
measures include computer safeguards and secured files and
buildings.
information of our customers,
We maintain safeguards that comply with federal standards to protect
including
nonpublic personal
procedures to assure appropriate access to, and use of, information
about our customers.
We collect your personal information, for example, when you
How does Carson Advisory Group
collect my personal information?
or Enter into an investment
● Seek advice about
your investments
● Show your driver’s
advisory contract
or Give us your contact
license
information
● Tell us about your investment or retirement portfolio
We also collect your personal information from others, such as credit
bureaus, affiliates, or other companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only
● sharing for affiliates’ everyday business purposes-information
about your creditworthiness
● affiliates from using your information to market to you
● sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights
to limit sharing.
Definitions
Affiliates
Companies related by common ownership or control. They can be
financial and nonfinancial companies.
● Carson Advisory Group has no affiliates.
Non-affiliates
Companies not related by common ownership or control. They can
be financial and nonfinancial companies.
●
Carson Advisory Group does not share with non-affiliates
so they can market to you.
Joint Marketing
A formal agreement between nonaffiliated financial companies that
together market financial products or services to you.
● Carson Advisory Group does not jointly market.
Other important information
Who we share your information with:
• With Raymond James Financial Services having regulatory requirements to supervise Carson Advisory
Group’s broker-dealer activities.
27
Carson Advisory Group
PART 2B OF FORM ADV: BROCHURE SUPPLEMENT
Item 1. Cover Page
Carson Advisory Group
470 Hill St.
Athens, GA 30601
706-543-6578
www.carsonadv.com
Brochure Supplement for:
Robert H. Carson, Jr., Richard J. Chester, Jr., Kevin Wilson,
Edward Ariail, Daniel Mosseri, Lindsey Seagraves, William
Isaac Brown, and Cesar Ortiz Garcia
March 24, 2025
This Brochure Supplement provides information about Carson Advisory Group’s Investment
Adviser Representatives and supplements the Carson Advisory Group Brochure. You should
have received a copy of that brochure. Please contact us at 706-543-6578 if you did not receive
Carson Advisory Group’s Brochure or if you have any questions about the contents of this
Brochure Supplement.
Additional information about Carson Advisory Group’s Investment Adviser Representatives is
available on the SEC’s website at www.adviserinfo.sec.gov.
28
Carson Advisory Group
Robert Howard Carson, Jr., CRD no. 1013355, FINRA Series 7, 8, and SIE and
NASAA Series 63
Item 2. Educational Background and Business Experience
Year of birth: 1954
Educational Background:
Vanderbilt University: BA in History (1977)
Business Background:
Carson Advisory Group, President & Investment Adviser Representative, 1999-Present
Carson and Associates, Investment Adviser Representative, 1981-1999
Raymond James Financial Services, Inc., Registered Representative, 1981-Present
Ralston Purina, Resort Management, 1977-1981
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Robert Carson, Jr. has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Inc., Registered Representative
Item 5. Additional Compensation
While acting as a Registered Representative of Raymond James Financial Services, he
may be paid fees and or commissions on securities transactions. All commissions are
disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
Robert H. Carson, Jr. is supervised by Lindsey Seagraves, CCO. She reviews Robert’s
work through frequent office interactions as well as remote interactions. She also
reviews Robert’s activities through our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
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Carson Advisory Group
Richard John Chester, Jr., Accredited Investment Fiduciary®, Chartered
Retirement Plans Specialist (CRPS®), CRD no. 2664105, FINRA Series 7, 9, and
SIE and NASAA Series 63 and 65
Item 2. Educational Background and Business Experience
Year of birth: 1970
Educational Background:
University of Georgia: BBA in Economics (1997)
College of Financial Planning: Chartered Retirement Plans Specialist Designation
(2001)
Business Experience:
Carson Advisory Group, Investment Adviser Representative, 1999-Present
Carson and Associates, Investment Adviser Representative, 1995-1999
Raymond James Financial Services, Inc., Registered Representative, 1995-Present
Berean Capital, Inc., Trading Support Specialist, 1991-1993
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Richard J. Chester, Jr. has no
reportable disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
While acting as a Registered Representative of Raymond James Financial Services, he
may be paid fees and or commissions on securities transactions. All commissions are
disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
Richard J. Chester, Jr. is supervised by Lindsey Seagraves, CCO. She reviews
Richard’s work through frequent office interactions as well as remote interactions. She
also reviews Richard’s activities through our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
30
Carson Advisory Group
Kevin Patrick Wilson, CFP®, CRD no. 5744810, FINRA Series 7, 9, 10, and SIE and
NASAA Series 66
Item 2. Educational Background and Business Experience
Year of birth: 1979
Educational Background:
Piedmont College: BBA in Business (2008)
Business Experience:
Carson Advisory Group, Investment Adviser Representative, 2012-Present
Raymond James Financial Services, Inc., Registered Representative, 2011- Present
Morgan Stanley Smith Barney, Financial Advisor Associate, 2010-2011
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Kevin Wilson has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
While acting as a Registered Representative of Raymond James Financial Services, he
may be paid fees and or commissions on securities transactions. All commissions are
disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
Kevin Wilson is supervised by Lindsey Seagraves, CCO. She reviews Kevin’s work
through frequent office interactions as well as remote interactions. She also reviews
Kevin’s activities through our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
Certified Financial Planner Board of Standards, Inc. (CFP Board) owns the certification
marks CFP®, CERTIFIED FINANCIAL PLANNER™, and CFP® (with plaque design) in the U.S., which it authorizes
use of by individuals who successfully complete CFP Board's initial and ongoing certification requirements.
31
Carson Advisory Group
Edward Denton Ariail, CRD no. 5755612, FINRA Series 7 and SIE and NASAA
Series 66
Item 2. Educational Background and Business Experience
Year of birth: 1958
Educational Background:
University of Georgia: MBA (1982)
Piedmont College: BA in History (1980)
Business Experience:
Carson Advisory Group, Investment Adviser Representative, 2012-Present
Raymond James Financial Services, Inc., Registered Representative, 2012-Present
Morgan Stanley Smith Barney, Financial Advisor Associate, 2010-2012
Habersham Bank, President, 1996-2009
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Edward Ariail has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
While acting as a Registered Representative of Raymond James Financial Services, he
may be paid fees and or commissions on securities transactions. All commissions are
disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
Edward Ariail is supervised by Lindsey Seagraves, CCO. She reviews Edward’s work
through frequent office interactions as well as remote interactions. She also reviews
Eddy’s activities through our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
32
Carson Advisory Group
Daniel Francis Mosseri, CFP®, CRD no. 5997001, FINRA Series 7 and SIE and
NASAA Series 66
Item 2. Educational Background and Business Experience
Year of birth: 1988
Educational Background:
University of Georgia: BS in Financial Planning (2010)
Business Experience:
Carson Advisory Group, Investment Adviser Representative, 2020-Present
Raymond James Financial Services, Inc., Registered Representative, 2020-Present
Wells Fargo Advisors, LLC, Financial Advisor, 2017- 2020
Wells Fargo Advisors, LLC Registered Client Associate, 2014-2017
Wells Fargo Advisors, LLC, Client Associate, 2012-2014
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Daniel Mosseri has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
Additional Compensation: While acting as a Registered Representative of Raymond
James Financial Services, he may be paid fees and or commissions on securities
transactions. All commissions are disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
Daniel is supervised by Lindsey Seagraves, CCO. She reviews Daniel’s work through
frequent office interactions as well as remote interactions. She also reviews Daniel’s
activities through our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
Certified Financial Planner Board of Standards, Inc. (CFP Board) owns the certification
marks CFP®, CERTIFIED FINANCIAL PLANNER™, and CFP® (with plaque design) in the U.S., which it authorizes
use of by individuals who successfully complete CFP Board's initial and ongoing certification requirements.
33
Carson Advisory Group
Lindsey Adams Seagraves, CRD no. 5666863, FINRA Series 7 and SIE and NASAA
Series 66
Item 2. Educational Background and Business Experience
Year of birth: 1982
Educational Background:
University of Georgia: BA in Political Science (2008)
Business Experience:
Carson Advisory Group, CCO, 2020-Present
Carson Advisory Group, Investment Adviser Representative, 2015-Present
Carson Advisory Group, Client Services Associate, 2009-Present
Raymond James Financial Services, Inc., Registered Representative, 2014-Present
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Lindsey Seagraves has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
Additional Compensation: While acting as a Registered Representative of Raymond
James Financial Services, she may be paid fees and/ or commissions on securities
transactions. All commissions are disclosed to clients.
Item 6. Supervision
Lindsey is supervised by Robert Carson, Jr. He reviews Lindsey’s work through
frequent office interactions as well as remote interactions. He also reviews Lindsey’s
activities through our client relationship management system.
Robert Carson, Jr.’s contact information:
706-543-6578 or Bob.Carson@Raymondjames.com
34
Carson Advisory Group
William Isaac Brown, CRD no. 7406518, Chartered Retirement Plans Specialist
(CRPS®), FINRA Series 6, 7 and SIE and NASAA Series 63 and 65
Item 2. Educational Background and Business Experience
Year of birth: 1998
Educational Background:
Marshall University: BA in Applied Mathematics & Secondary Math Education (2021)
Business Experience:
Carson Advisory Group, Client Services Associate, 2023-Present
Raymond James Financial Services, Inc., Registered Representative, 2023-Present
Nationwide Investment Services Corp., Territory Consultant/Sales Coordinator, 2021-
2023
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. William Isaac Brown has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Item 5. Additional Compensation
Additional Compensation: While acting as a Registered Representative of Raymond
James Financial Services, he may be paid fees and/ or commissions on securities
transactions. All commissions are disclosed to clients.
We have insurance company affiliations through Raymond James Insurance Group,
Inc., an affiliate of Raymond James from which he may receive commissions. Clients
are under no obligation to execute recommendations relating to insurance and/or
annuity products through Raymond James Insurance Group, Inc. If a client chooses to
use us in our individual capacity as an insurance agent, we will receive a commission.
Item 6. Supervision
William is supervised by Lindsey Seagraves. She reviews his work through frequent
office interactions as well as remote interactions. She also reviews his activities through
our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
35
Carson Advisory Group
Cesar Ortiz Garcia, CFA®, FRM, CRD no.7820790, FINRA Series 7, 9, 10 and SIE
and NASAA Series 66
Item 2. Educational Background and Business Experience
Year of birth: 1981
Educational Background:
Madre y Maestra Pontifical Catholic University: BA in Economics (2003)
Pompeu Fabra University: Master’s Degree in Economics (2007)
Santo Domingo Institute of Technology: Graduate Certificate in Mathematics (2012)
Business Experience:
Carson Advisory Group, Financial Analyst, 2023-Present
Raymond James Financial Services, Inc., Registered Representative, 2024-Present
Banking Supervision Agency of the Dominican Republic, Deputy Director of Risk
Monitoring & Research, 2012-2021
Item 3. Disciplinary Information
Investment Adviser Representatives are required to disclose all material facts regarding
any legal or disciplinary events that would be material to a client’s evaluation of each
supervised person providing investment advice. Cesar Ortiz Garcia has no reportable
disciplinary history.
Item 4. Other Business Activities
Raymond James Financial Services, Registered Representative
Mishu Music, LLC, Finance Manager & Data Analyst
Item 5. Additional Compensation
Additional Compensation: While acting as a Registered Representative of Raymond
James Financial Services, he may be paid fees and/ or commissions on securities
transactions. All commissions are disclosed to clients.
In addition, Cesar receives compensation from Mishu Music, LLC.
Item 6. Supervision
Cesar is supervised by Lindsey Seagraves. She reviews his work through frequent
office interactions as well as remote interactions. She also reviews his activities through
our client relationship management system.
Lindsey Seagraves’ contact information:
706-543-6578 or Lindsey.Seagraves@Raymondjames.com
CFA® and Chartered Financial Analyst® are registered trademarks owned by CFA Institute.
36
Carson Advisory Group
Client Services Associates
Patricia Crawford
Tiffin University: MBA
Mount Olive College: BS in Management and Organizational Development
Carson Advisory Group (2010 to Present)
Patty.Crawford@Raymondjames.com
Jennifer Bielli
University of Georgia: BA in English Literature
Carson Advisory Group (July 2020- Present)
Jennifer.Bielli@Raymondjames.com
Jodi Hatcher
University of South Carolina Upstate: BS in Criminal Justice
Carson Advisory Group (February 2023-Present)
Jodi.Hatcher@Raymondjames.com
Richard “John” Chester, III
University of Georgia: BBA in Finance
Carson Advisory Group (May 2024- Present)
John.Chester@RaymondJames.com
37
Carson Advisory Group