Overview

Assets Under Management: $367 million
Headquarters: PITTSFORD, NY
High-Net-Worth Clients: 170
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART 2 2024)

MinMaxMarginal Fee Rate
$0 $500,000 0.85%
$500,001 and above 0.60%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $7,250 0.72%
$5 million $31,250 0.62%
$10 million $61,250 0.61%
$50 million $301,250 0.60%
$100 million $601,250 0.60%

Clients

Number of High-Net-Worth Clients: 170
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 75.46
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 926
Discretionary Accounts: 919
Non-Discretionary Accounts: 7

Regulatory Filings

CRD Number: 165984
Last Filing Date: 2024-05-17 00:00:00
Website: HTTP://WWW.CANDACESHIRA.COM

Form ADV Documents

Primary Brochure: ADV PART 2 2024 (2025-03-18)

View Document Text
1 Cross Staff Investments, Inc. 115 Sully’s Trail, Suite 8 Pittsford, NY 14534 Phone: (585) 249-1550 Fax: (585) 249-1554 www.candaceshira.com January 1, 2025 Form ADV Part 2A Brochure Cross Staff Investments, Inc., doing business as Candace Shira Associates, LLC, is a registered investment advisor with the United States Securities and Exchange Commission (“SEC”). A “registered investment advisor” means any entity which, for compensation, engages in the business of advising others as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or which, for compensation and as a part of regular business, produces planning documents concerning individuals, or companies, overall financial health. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Cross Staff Investments, Inc. If you have any questions about the contents of this brochure, please contact us at (585) 249-1550 or through our website at www.candaceshira.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration does not imply a certain level of skill or training. Additional information about Cross Staff Investments, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. January 2025 2 Material Changes – Item 2 The purpose of this page is to inform you of any material changes since the previous version of this Brochure, which was dated January 1, 2024. Item 4 was updated to reflect the current assets under management of the Firm as of December 31, 2024. Item 15 was updated to include custody information related to standing letters of authorization. January 2025 3 Table of Contents – Item 3 Contents Advisory Business – Item 4………………………………………………………………….. 4 Fees and Compensation – Item 5…………………………………………………………….. 5 Performance-Based Fees and Side by Side Management – Item 6.…………………………...8 Types of Clients – Item 7…………………………………………..………………………… 8 Methods of Analysis, Investment Strategies and Risk of Loss – Item 8.……………………. 8 Disciplinary Information – Item 9…………………………………………………………… 9 Other Financial Industry Activities or Affiliations – Item 10……………………………….. 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading – Item 11……………………………………………………………….…. 10 Brokerage Practices – Item 12……………………………………………………………..... 11 Review of Accounts – Item 13……………………………………………………….………11 Client Referrals and Other Compensation – Item 14…………………………………….…. 12 Custody – Item 15……………………………………………………………………….….. 12 Investment Discretion – Item 16……………………………………………………….…… 12 Voting Client Securities – Item 17………………………………………………………….. 12 Financial Information – Item 18…………………………………………………………….. 12 January 2025 4 Advisory Business – Item 4 A. Cross Staff Investments, Inc., doing business as Candace Shira Associates, LLC (“the Firm” or “CSI”) is a registered investment advisor based in Pittsford, NY. The Firm is incorporated under the laws of the State of New York. The Firm has been incorporated since December 2012. Before Cross Staff Investments, Inc., the advisors were Investment Advisor Representatives providing advisory services under other registered investment advisors. The Firm is considered fiduciaries due to the type of services we provide. The principal owner of the Firm is Candace Shira, sole owner and President. B. The Firm offers the following services personalized to each individual Client: a. Financial Planning b. Investment Management c. Use of Third Party-Money Management Our Financial Planning service involves general recommendations as to asset allocation or security selection of either a selected account, or across a Client’s entire financial portfolio. The Client determines what accounts and/or assets we will review and provide advice on. Some of the areas that we may focus on are cash flow, retirement goals, asset allocation, estate goals, or education analysis, as well as budgeting reviews. The Firm may provide periodic investment review for accounts held outside of the Firm’s affiliation (i.e., 401K, 403B, etc.) if requested by the Client. For these types of reviews, the Clients will be expected to provide a copy of their most recent statements, as well as the investment choices for the account, if applicable. The Client will then be responsible for acting on any changes they see fit. The Client may choose to give the Firm authority to discuss their financial matters with attorneys, tax preparers, their bank, health care professionals, etc. to allow the Firm to better assist the Client in their financial planning. Such authority will be given in writing and/or documented in the Client’s file maintained with the Firm. The Firm may also be given discretionary authority for only those accounts held at the custodians the Firm works with by agreement. This allows the Firm to conduct trades deciding on security, amount, and whether to buy or sell, if necessary. Investment Management securities are limited to publicly traded stocks, mutual funds and exchange traded funds as well as bonds and certificates of deposit and other cash equivalent holdings. Clients may hold all or only a portion of the securities listed here. The Firm may also utilize Third-Party Money Managers to provide investment management services, which may include other investments than those listed here. The advisor and/or Client will determine which type of securities will be utilized for management. The Firm and Client may decide to utilize a Third-Party Money Manager to assist in making trading decisions in a Client’s account. Currently the Firm utilizes Advisor’s Asset Management and SEI. The Firm also has access to Schwab’s Managed Platform which has additional Third-Party Money Managers the Clients can choose from. The Firm will conduct due diligence on all Third-Party Money Managers prior to introducing January 2025 5 them to a Client. All Third-Party Money Managers will provide their individual ADV Part 2a (and 2b if necessary) which will provide more in-depth information regarding the Third-Party Manager and their investment style, fees, risks of investing, etc. C. The Firm tailors our advisory services to the individual needs of the Clients. The Client may at times impose investment restrictions on certain securities or types of securities. Those investment restrictions will be monitored by the Advisor as well as by the Firm. If investment restrictions are in place, it may affect the overall performance of the Clients’ accounts. D. Cross Staff Investments does not participate in a wrap fee program. E. Cross Staff Investments manages $401,493,805 of assets on a discretionary basis and $8,093,263 of assets on a non-discretionary basis as of December 31, 2024. Fees and Compensation – Item 5 Cross Staff Investments, Inc. charges fees based on the type of service that is agreed upon by the Client and Advisor. Fees for all services may be negotiated by the Firm with the Client and fees may vary based on a pre-existing relationship, levels of service the Client wants performed, complexity of the Client’s overall financial situation or based on other unique Client circumstances. A Client will also be responsible to assume trading charges, such as ticket charges, maintenance or other account fees as charged by the custodian or Third-Party Money Manager. Internal mutual fund fees are also an expense that the Client will bear. For accounts managed by CSI, investment management fees are based on the below schedule and charged quarterly in arrears. All Clients’ accounts may not be assessed a fee, thus will not be included in the overall fee calculation. Fees are determined through a discussion between the Advisor and Client. The Firm will send invoices to Clients on a quarterly basis. Item 12 discusses additional information regarding assets held in brokerage accounts. Again, this schedule may be reduced or increased based on a specific situation of a Client, however all fees are based on this tier and discounted or increased as the Client, Advisor and/or Firm see fit. The Client in all cases will sign off on the initial fee agreement and will acknowledge a fee change either by signing a new agreement or receiving a negative consent notice from the Firm of a fee change. This policy is stated within the Firm’s agreement. However, if the Advisor wishes to charge above 1% the Firm’s Chief Compliance Officer must approve the fee prior to the signing of the agreement. The Advisory Fee will be charged on a quarterly basis for services performed in the previous quarter and shall be calculated based on the quarter ending value of the account multiplied by the percentage stated with the Advisory, then divided by 4. Using this calculation, over the course of 4 quarters the Client will have paid the Advisory Fee in an amount equal to the percentage listed within the Advisory Agreement. Client authorizes and instructs Advisor and Custodian to deduct the Advisory Fee from the Client’s account as agreed upon in the Firm’s Advisory Agreement. The Client will be notified of the fee via an invoice that will be sent to the Client for accounts under management of the Advisor prior to such a fee being deducted from the accounts. The invoice will include the calculation of such fee. Fees calculated by Third-Party Money Managers will be shown on the quarterly statement provided by the Third-Party Money Manager. CSI does not send an invoice for these accounts. January 2025 6 The Custodian will perform all valuations of assets in the account and Advisor will rely on these valuations. In computing the market value of any security or other investment in the Account, each security listed on a national securities exchange shall be valued as of the valuation date, generally the last business day of each calendar quarter, at the closing price on the principal exchange on which it is traded. Any other security or investment in the Account shall be valued in a manner determined in good faith by the Custodian or, in the absence of the Custodian’s valuation by a valuation assigned by Advisor to reflect fair market value. Any valuation shall not be deemed to be a guarantee of any kind by Advisor regarding the value of the assets in Client’s account. Clients will receive monthly and/or quarterly statements from the Custodian valuing the investment positions in the account. All assets held in Client’s account will be subject to the Advisory Fee, including assets, such as cash, that are temporarily awaiting investment. Client acknowledges that it is Client’s responsibility to verify the accuracy of the Advisor’s calculation of the Advisory Fee. If there is not enough liquid cash or equivalents in the account to pay the Advisory Fee when due, the Advisor may instruct the Custodian to liquidate the necessary positions in the account to cover the amount due to Advisor. Certain assets, including cash, may be excluded from the fee calculation if determined by the Advisor and agreed upon with the client. Such exclusion will be noted on the invoice. Client will pay transaction fees for execution of trades in the accounts. In addition to the Advisory Fee, Client will be responsible for all other account fees charged, if any, to the account including but not limited to costs of trading, safekeeping, custody fees, closeout fees, margin costs (if applicable. The Firm currently does not utilize margin with client accounts.), and internal mutual fund fees. Client understands that services like those provided by Advisor may be available from other sources at lower costs and under different cost structures that may be beneficial to Client, such as a brokerage account. All brokerage commissions, custodial fees, stock transfer fees, transaction fees, charges imposed directly by mutual, index or exchange-traded funds, fees imposed by variable annuity providers, certain deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other account fees and similar charges incurred in connection with transactions for Client’s account imposed by unaffiliated third parties will be paid out of the assets in the account and are in addition to the Advisory Fee paid by Client to Advisor. Managed Account Fee Schedule Tier 1 $0-$500,000 $500,000+ 0.85% 0.60% Tier 2 $0-+ 0.85% Tier 3 – Fixed Income/Transitional/Distribution Accounts .30%-.60% $0 - + January 2025 7 Tier 4 – American Fund only Accounts $0 - + .50% For Financial Planning and ongoing investment monitoring, these services will be charged either a one time or ongoing fee, which will be assessed hourly, quarterly, or semi-annually in arrears. The hourly base fee is currently $350/hour. The initial ongoing charge is $1,500/annually. The annual fee will be divided into either four (4) quarterly payments or two (2) semi-annual payments and charged in arrears. These fees may be negotiated based on the services the Clients wish to engage in with the Firm, so they may be more or less than what is stated herein. Again, this schedule may be reduced or increased based on a specific situation of a client, however all fees are based on this tier and discounted or increased as the Advisor and/or Client see fit. For Clients who wish to pay an hourly fee, an invoice is mailed to the Client or presented to the Client at the time of completion of the service or at the end of the quarter or semi-annual period. The Client typically pays these fees directly to the Firm. For Clients who pay an ongoing financial planning fee directly from their Schwab account a quarterly invoice will be sent to the client. If they wish to have the fee deducted through their Schwab account, the Client must complete Schwab paperwork to that effect. If the Client chooses to pay the Firm directly the Client will receive an invoice on a quarterly or semi-annual basis and will remit payment directly to the Firm via check. The Firm will decide when specifically requested by the Client for other alternative payment arrangements. In any case all payments will be made in arrears. The Client in all cases will sign off on the initial investment management, continuation of services or hourly agreement and will acknowledge a fee change either by signing a new agreement or receiving a negative consent notice from the Firm of a fee change. This policy is stated within the Firm’s agreement. Investment advice may also include a discussion of traditional insurance products, which may be offered by the appropriately licensed advisors of the Firm. The advisors will receive a commission to sell the product, however the Firm does not charge a fee for investment advice regarding the product. Should the Firm’s advisors utilize mutual funds within the advisory portfolio, the fund company may pay a marketing fee under Section 12b-1 of the Investment Company regulations depending upon the share class of the Fund. If the Advisor does receive such a fee, the total fee received, including the 12b-1 fee, will not exceed the stated maximum fee allowed by the Firm, which is 1%. Currently, the Firm does not receive any Section 12b-1 fees for accounts that are held at the Firm’s custodians. The Firm strives to utilize investor share classes that do not assess a Section 12b-1 marketing fee when available. The Advisor and Client may choose to utilize a Third-Party Money Manager to invest the Client’s account. The Advisor will have entered into a selling agreement or similar relationship with the Third-Party Money Manager, if required. This relationship is agreed upon and acknowledged by the Client, the Third-Party Money Manager, and the Advisor. The fees for such a relationship will be based on the Third-Party Money Manager’s fee schedule and minimum investment requirement, if any. The Client will be given the ADV Part 2A for the Firm and the Third-Party Money Manager, as well as any applicable Part 2Bs for the Firm and Third-Party Money January 2025 8 Manager. The Third-Party Money Manager fee is not included within the fee charged by the Firm. Performance Based Fees and Side by Side Management – Item 6 Cross Staff Investments, Inc. does not accept performance-based fees. Types of Clients – Item 7 We offer investment advisory services as stated above to individuals, trusts, businesses, and estates. The Firm currently does not require a minimum account size. Methods of Analysis, Investment Strategies and Risk of Loss – Item 8 The Advisors of Cross Staff Investments, Inc. will utilize various methods to manage Client assets. These methods are based on Client’s individual objectives, risk tolerances as well as their overall financial condition. The Firm uses traditional methods of researching specific investments. Use of traditional methods of research does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments may result in significant price fluctuations that can lead to investor losses or gains which can affect a client’s tax base. The Firm may utilize mutual funds, individual publicly traded securities, exchange traded funds, Certificates of Deposits and bonds, as well as other cash equivalent holdings in certain situations. The Firm utilizes software, fund managers and industry specific periodicals when researching securities for investing. The Advisors may use a Third-Party Money Manager to assist in the management of the Client’s investments. Clients always approve of the use of Third-Party Money Managers for use in their overall financial portfolio. Third-Party Money Management has its own unique risks in investing, such as additional fees. Also, while the Advisor and Clients can change their portfolios in the account; neither can buy or sell individual securities held in the portfolio(s) used. This can be a risk to Clients if they do not wish to be invested in a particular security or group of securities. A more detailed list of specific risks of each Third-Party Money Manager can be found in their Form ADV Part 2A that is given to Clients for their review. All investments come with the risk of losing money. Investing in individual securities may carry significantly more risk than a diversified mutual fund or exchange traded fund. Investing involves substantial risks, including complete loss of principal plus other losses and may not be suitable for all individuals. Investments are not insured by the government to protect against market losses. Clients should be able to assume these types of risks. Different securities carry different types and degrees of risk and Clients should familiarize themselves with the risks involved in the securities they intend to invest in. It is important to note that for all investments past performance is not indicative of future results as many factors weigh on the performance of any particular investment. Mutual Funds and Exchange Trade Funds (ETFs) have specific risks aside from those stated above in that a manager who has been successful may not be able to continue that success in the future. In addition, the Firm does not control the underlying investments, managers of different January 2025 9 funds held by the client may purchase the same or similar securities, increasing the risk to the client if that security or sector of securities were to fall in value. There is also risk that the manager may deviate from the stated investment objective of the fund or ETF, which could make the fund or ETF less suitable for the Client’s portfolio. Money market mutual funds are not insured or guaranteed by FDIC or any other governmental agency and may lose money. With other security types we use there are specific risks to each of them aside from what was stated above. Equity investments can be volatile and are subject to stock market risk with the chance that stock prices may decline in value. Stock markets move based on many factors, least of which is a feeling based on politics, news items, interest rates, etc. The market in its history has moved in cycles with periods of rising and lowering prices. If you are invested in stocks of smaller companies, they have a higher probability of failure since they are not as established as larger capitalized companies. They also may not pay out dividends or capital gains to their stockholders, as other more established companies may. Bond and interest rates have an inverse relationship. So, if the price to purchase a bond rises; interest rates are falling. The opposite of this is also true. Disciplinary Information – Item 9 Registered Investment Advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to an individual’s evaluation of the Firm or the integrity of its management. There is no history of legal or disciplinary events by the Firm, the management, or advisors. Other Financial Industry Activities and Affiliations – Item 10 Cross Staff Investments, Inc. has a custodial relationship with Charles Schwab, SEI, American Funds (Capital Bank & Trust), and Security Benefit. These relationships do not present a conflict of interest as we do not receive economic benefit from these entities, nor are we affiliated with them. Ms. Shira and Ms. Kay are also licensed insurance agents and can affect transactions in various insurance products such as, life, health, disability, long-term care, and fixed annuities. Ms. Shira earns commissions for these activities. The Firm’s advisory Clients may also be insurance clients. Clients are instructed that the fees paid to the Firm for advisory services are separate and distinct from the commissions earned by Ms. Shira for placing the Client in a traditional insurance product. Clients are not obligated to utilize Ms. Shira for their insurance services; they may use any insurance brokerage firm and agent of their choice. Ms. Kay currently does not solicit insurance products to Clients. Her role is solely administrative in nature. The receipt of insurance commissions represents a potential conflict of interest due to the receipt of both advisory and commission compensation. Cross Staff Investments, Inc. has policies and procedures in place to monitor Client transactions. Should Cross Staff Investments, Inc. find that an Advisor has not acted in the best interest of the Client, Cross Staff Investments, Inc. may cancel the transaction. This is on an individual basis and is discussed and agreed upon by the Client and the Advisor. It is important to note that the Firm does not receive any commissions on advisory accounts. Commissions are received solely for the sale of traditional insurance products as stated above. In any event, all Client transaction costs will be disclosed to the Client. Ms. Shira spends less than 5% of her time in her capacity as an insurance agent. The Firm charges some Clients based on an agreement of a percentage of assets under management. This is a potential conflict of interest as the Firm will make more in fees if the Client has more assets under management. The Firm addresses this conflict by reviewing Client January 2025 10 fees regularly and may not charge on all assets under management. Also, the Firm does not make it mandatory for its Clients to have all their investment assets under the Firm’s management. It is the sole discretion of the Client what assets the Firm manages. Cross Staff Investments, Inc. may recommend that Clients use a Third-Party Money Manager, with whom the Firm has established a selling agreement, if applicable, as a part of our asset allocation and investment strategy. Cross Staff Investments, Inc. will receive compensation on Third-Party money managed accounts for overseeing the Client’s account with the manager. This means that the Advisor can make allocation changes and/or the ability to terminate the relationship with the money manager. The use of and fees associated with a Third-Party Money Manager is agreed upon by the Client. By signing the Firm’s agreement, the Client understands and accepts the Firm’s potential Conflicts of Interest and management of same. Code of Ethics – Item 11 The Firm maintains Code of Ethics procedures which were created to supervise potential conflicts of interest between trades placed on behalf of a Client account and Advisors of CSI’s personal trading. The Code describes its high standard of business conduct and fiduciary duty to its Clients. The Code includes CSI’s policies and procedures developed to protect Client’s interests in relation to the following topics: the duty to place the interest of the Client first, requirement that personal securities transactions be conducted to be consistent with the Code, responsibility to avoid any actual or potential conflict of interest or misuse of an Advisor’s position of trust, and the confidentiality of the Client’s information concerning the identity of the Client’s security holdings and financial circumstances. When a trade is placed for multiple Clients in the same stock at the same time with Schwab (i.e. block trades), Schwab will use an average price when allocating the trades to the individual Client accounts. This allows for Clients to receive the same price for the stock trade. Employees of the Firm may also be included within the block trade to ensure that the employees of the Firm do not benefit from Client’s transactions. In addition, the Code requires pre-clearance of Initial Public Offerings (IPO), Special Purpose Acquisition Company (SPAC), and private placements. The Code also discusses review of Advisors personal trading so that the Advisor does not benefit from known Client trades. Trading conducted in an Advisor’s accounts is monitored under the Code to reasonably prevent conflicts of interest between CSI, the Advisor, and its Clients. Certain employees of the Firm and their family members may have access to purchase IPOs or SPACs at various times, however, CSI does not place IPO or SPACs transactions for its Clients until the IPO or SPAC securities are trading on an exchange. The Firm will review its IPO and SPAC transactions to ensure that such a transaction will not harm the Client. The Code is reviewed on an annual basis by the Firm’s CCO, and annual training is conducted for all Advisors of the Firm. Clients and prospective Clients may request a copy of the Firm’s Code of Ethics by contacting the Firm’s Chief Compliance Officer at 585-249-1553. January 2025 11 Brokerage Practices – Item 12 Suggestion of a Broker Cross Staff Investments, Inc. has a custodial relationship with Charles Schwab & Company, Inc (“Schwab”), a FINRA-registered broker dealer. Advisors of Cross Staff Investments, Inc. will suggest Schwab for brokerage and custodial assets. Clients, however, can enter a continuous financial planning relationship with the Firm and utilize a custodian of their choice. SEI’s affiliated custodian, SEI Private Trust Company (SPTC) is utilized for assets held with SEI. SPTC may charge the Client a fee for their services. SPTC may also provide trust, custody and/ or record-keeping services to SEI Clients. For additional information on SEI or SPTC please review SEI’s Form ADV Part 2A. American Funds clears through Capital Bank & Trust. Only Clients that hold American Funds can be placed here. The Firm uses American Funds in an advisory capacity. If a Client wishes to have their assets held directly at American Funds, they may be limited to share class availability. Prime Brokerage Relationship In 2022 the Firm established a Prime Brokerage relationship with Charles Schwab. This allows the Firm to place Initial Public Offering transactions through accounts held at Schwab. The Firm executed one transaction with EF Hutton/RBC and one with Kingwood/RBC for employees of the Firm along with certain immediate family members’ accounts. The Firm is not offering such a service to our Advisory clients. The Firm also did not receive any personal or business benefit for executing this relationship. Research and Other Soft Dollar Benefits The Firm does not engage in research or other soft dollar benefits. Brokerage for Client Referrals Cross Staff Investments, Inc. does not receive Client referrals from any custodial relationship, nor does the Firm receive any other benefits from any custodian in exchange for Client referrals. Use of an Outside Custodian Cross Staff Investments, Inc. has a custodial agreement with Charles Schwab. For Clients who wish to custody their assets at another broker dealer the Firm will provide financial planning services to the Client. The Client will be responsible for executing their own trades in their account based on the suggestions of the Firm. Review of Accounts – Item 13 Cross Staff Investments, Inc. will monitor Client’s accounts on a periodic basis. The Firm will monitor the Third-Party Money Managers to ensure their performance and investment style remains aligned with Client’s investment goals and objectives. The Advisor of the account will conduct ongoing reviews of the Client’s portfolio holdings. Ms. Kay, the Firm’s Chief Compliance Officer, will conduct random account reviews monthly to oversee the accounts. Ms. Kay will conduct other supervisory reviews as needed. Clients will receive statements directly from the custodian(s) on at least a quarterly basis. Clients are reminded annually to contact the Firm and/or custodian if they are not receiving their statements. January 2025 12 Client Referrals and Other Compensation – Item 14 The Firm does not currently receive Client referrals or other compensation other than commissions from insurance sales as previously disclosed herein. Custody – Item 15 Cross Staff Investments, Inc. does not have physical custody of Client’s funds or securities. Clients will receive account statements at least quarterly from the custodian. Clients should review their statements for accuracy and contact their Advisor with any questions. The custodial statement is the official record of the Client’s account for tax purposes. Cross Staff Investments, Inc., however, is deemed to have custody based on SEC regulation related to the Firm providing on-request distributions to third parties for our Clients. For example, charitable donations. Cross Staff Investments Inc. custodians, as well as the Firm’s Chief Compliance Officer, monitor these transitions to ensure the third-party distribution is sent in accordance with the Client’s wishes. The Client monitors these transactions through custodian confirmations and statements. Investment Discretion – Item 16 For investment management and financial planning accounts held with Schwab, the Firm is given discretion over the purchase and sale of securities held. The Firm will decide the type of security, the amount and whether to buy or sell. This privilege is given to the Firm by the Client through the execution of the Advisory Agreement, Continuation of Services Agreement and/or paperwork from the custodian and/or the Third-Party Money Managers. Clients who wish to place an investment restriction on the account must notify their Advisor. For accounts held at Third-Party Money Managers, the manager will have discretion over the account regarding the individual securities held. The Firm may have discretion over the type of portfolio that is managed by the Third-Party Money Manager. Again, this privilege is given by the Client to the money manager and the Advisor through the Third-Party Manager’s agreement. If the Client wishes to place an investment restriction on the account, the Client must notify the Advisor. The Advisor will notify the Third-Party Money Manager. Should a Client wish to place an investment restriction on any account it may affect the performance or diversification of the account. Voting Client Securities – Item 17 Cross Staff Investments, Inc. does not vote proxies for Client securities. If a proxy is received at the office, it will be forwarded to the Client for their review and voting. Financial Information - Item 18 We are required in this Item to provide you with certain financial information or disclosures about Cross Staff Investments, Inc.’s financial condition. The Firm does not require the prepayment of fees. Additionally, the Firm has no financial liability that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. January 2025 13 Form ADV Part 2B Brochure Supplement For: Candace Shira Cross Staff Investments, Inc. DBA Candace Shira Associates, LLC 115 Sully’s Trail Suite 8 Pittsford, NY 14534 585-249-1550 This brochure supplement provides information about Candace Shira that supplements the Cross Staff Investments, Inc. brochure. You should have received a copy of that brochure. Please contact the Firm at 585-249-1550 if you did not receive Cross Staff Investment’s brochure or if you have any questions about the contents of this supplement. Additional information about Candace Shira is available on the SEC’s website at www.adviserinfo.sec.gov January 2025 Item I. Education Background and Business Experience Candace Shira was born in 1954. In 1976 Candace graduated from West Liberty State University with a Bachelor of Science degree. From January 2013 to present Candace has worked as an Investment Advisor Representative with Cross Staff Investments, Inc., doing business as Candace Shira Associates, LLC. Candace was previously registered as a Broker-Dealer Representative with Wall Street Financial Group, Inc. (WSFG) from January 2013 through September 2016. From April 2007 to December 2012 Candace worked as a Registered Representative and Investment Advisor Representative with WSFG. Candace is also a Certified Financial Planner (CFP®) with the Certified Financial Planner Board of Standards, Inc. Individuals who wish to obtain the CFP® designation must have a bachelor’s degree (or higher) from an accredited college or university, and three years of full-time personal financial planning experience. CFP® candidates must complete a CFP-board registered program or hold one of the following designations: CPA, Chartered Financial Consultant, Chartered Life Underwriter, Chartered Financial Analyst, Ph D in business or economics, Doctor of Business Administration or an Attorney’s license. Individuals are awarded the CFP® designation once they complete the certification examination and are required to complete thirty hours of continuing education every two years. Item II. Disciplinary History Currently, there are no disciplinary actions to report. Item III. Other Business Activities Candace maintains an insurance license in various states to sell and service insurance products such as fixed annuities, life insurance, long term care insurance, etc. This activity may generate a commission as well. Item IV. Additional Compensation Candace Shira does not receive additional compensation or economic benefit from any other individuals or companies. Item V. Supervision A member of Cross Staff Investments, Inc. randomly reviews client accounts for its Investment Advisor Representatives. A client advisory review may include but is not limited to an examination of the client’s objectives, risk tolerance and time horizon versus the client’s current holdings and transactions executed in the account. Advertising with the public is reviewed and/or approved by the Firm prior to use. Nancy Kay, the Firm’s Chief Compliance Officer, is responsible for overseeing Candace’s advisory activities. Ms. Kay may be reached at 585-249-1553. January 2025 Form ADV Part 2B Brochure Supplement For: Anthony Joseph Filberto Cross Staff Investments, Inc. DBA Candace Shira Associates, LLC 115 Sully’s Trail Suite 8 Pittsford, NY 14534 585-249-1550 This brochure supplement provides information about Anthony Joseph Filberto that supplements the Cross Staff Investments, Inc. brochure. You should have received a copy of that brochure. Please contact the Firm at 585-249-1550 if you did not receive Cross Staff Investment’s brochure or if you have any questions about the contents of this supplement. Additional information about Anthony Joseph Filberto is available on the SEC’s website at www.adviserinfo.sec.gov. January 2025 Item I. Education Background and Business Experience Anthony Joseph Filberto (Joseph) was born in 1979. In 2002 Joseph graduated from Washington and Jefferson College with a Bachelor of Science degree. In March 2014, Joseph received from Boston University a certificate in Financial Planning. From August 2014 to present Joseph has worked as an Investment Advisor Representative and Chief Investment Officer with Cross Staff Investments, Inc., doing business as Candace Shira Associates, LLC. From March 2013 through September 2016, Joseph had been registered as a Broker-Dealer Representative with Wall Street Financial Group, Inc. (WSFG). From June 2012 until present, Joseph has worked for Candace Shira Associates, LLC in a back-office capacity. From October 2008 to May 2012, Joseph had non-financial business-related experience. Joseph had been previously registered with other investment firms from June 2002 through September 2008. Joseph is also a Retirement Income Certified Professional (RICP®) with the American College of Financial Services. Individuals who wish to obtain the RCIP® designation must complete three course requirements in Retirement Income Process, Strategies & Solutions, Sources of Retirement Income and managing the Retirement Income Process. They must also meet the experience requirement, which is three years of professional experience within a five- year period of obtaining the certification. Once the certification is obtained the individual must complete 15 hours of continuing education every two years. Item II. Disciplinary History Currently, there are no disciplinary actions to report. Item III. Other Business Activities Joseph currently does not have any other business activities. Item IV. Additional Compensation Joseph receives a salary from Cross Staff Investments, Inc. for his duties performed for the Firm. Item V. Supervision A member of Cross Staff Investments, Inc. randomly reviews client accounts for its Investment Advisor Representatives. A client advisory review may include but is not limited to an examination of the client’s objectives, risk tolerance and time horizon versus the client’s current holdings and transactions executed in the account. Advertising with the public is reviewed and/or approved by the Firm prior to use. Nancy Kay, the Firm’s Chief Compliance Officer, is responsible for overseeing Joseph’s advisory activities. Ms. Kay may be reached at 585-249-1553. January 2025