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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
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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.
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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
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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
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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.
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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 - +
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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
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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
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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
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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.
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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.
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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.
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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