Crown Capital Securities, L.P. (“Crown”), which is a SEC-registered investment adviser, is also a registered broker-dealer with the Financial Industry Regulatory Authority ("FINRA"). Crown began conducting business in 1999 with its principal place of business located in Orange California. Listed below are the firm’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company):
• Mr. Darol K. Paulsen, CEO
• Delta Broker Holding, LLC, Shareholder Delta Broker Holding, LLC is a Limited Partner of Delta Capital Holdings, LLC. The general partner, Delta Capital Holdings, LLC is controlled by RET, LP and the Paulsen Trust, collectively referred to as the "members". Crown provides investment advisory services to a variety of clients. Our investment advice is delivered through our investment advisor representatives (“Advisory Associates”) whom are also registered as securities representatives of our broker-dealer. Crown sponsors the following Wrap Fee Programs:
• The Crown Heritage Adviser Model Management Wrap Program
• The Crown Heritage Wrap Strategists
• The Crown Heritage Separate Accounts Wrap

The Crown Heritage Adviser Model Management Wrap Fee Program
The Crown Heritage Adviser Model Management Program (“Model Management Program”) is a versatile portfolio management platform sponsored and offered by Crown. The Model Management Program is designed to offer clients a diversified, long-term approach to their personal investment goals and objectives through asset allocation, portfolio monitoring, consolidated reporting, and, most importantly, individualized portfolio management. It allows clients to invest in no-load or load-waived mutual funds, variable products, stocks, bonds, commercial paper, money market shares, CDs and exchange traded funds, according to the investor’s needs, goals, objectives and preferences. Clients considering participation in Model Management Program will receive an initial consultation with a Crown Advisory Associate to determine the client’s financial situation including investment history, goals and objectives, and special interests or concerns. Based on this consultation and client account documents, the client and the Crown Advisory Associate will design a portfolio using appropriate investments intended to meet the client’s long-term goals. Accounts will be rebalanced to ensure they stay within the client's established allocation. The Crown Advisory Associate will review the strategy periodically, and may make changes in the asset allocation among securities as needed. It is imperative, therefore, for the client to contact the Crown Advisory Associate if the client’s financial situation or objectives change.
The Crown Heritage Wrap Strategists
With the Heritage Wrap Strategist program clients can select from a list of Third Party Asset Managers (“Strategists”) that offer actively managed portfolios comprised of either mutual funds or exchange-traded funds. Crown will provide the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS").

Once we determine the most suitable Strategists for the client, we provide the selected Strategists with the client's PIPS. The Strategists then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS.

We monitor the performance of the selected Strategists. If we determine that a particular selected Strategists is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different Strategists. Under this scenario, our firm assists the client in selecting a new Strategist. However, any move to a new Strategist is solely at the discretion of the client. Clients retain individual ownership of all securities.

Client must have a minimum investment of $25,000 for this program.
Crown Heritage Separate Accounts Wrap
The Heritage Separate Accounts Wrap program provides clients with direct access to global investment managers (“Separate Account Manger”), many of whom were once available exclusively to large institutional investors.

Crown will provide the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS").

Once we determine the most suitable Separate Account Manger for the client, we provide the selected Separate Account Manger with the client's PIPS. The Strategists then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS. Crown will monitor the performance of the selected Strategists. If we determine that a particular selected Strategists is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different Strategists. Under this scenario, our firm assists the client in selecting a new Separate Account Manger. However, any move to a new Separate Account Manger is solely at the discretion of the client. Clients retain individual ownership of all securities. Client must have a minimum investment of $100,000 for this program.
Services
Affiliated and unaffiliated service providers may develop asset allocation models. The Crown Advisory Associate may also develop asset allocation models or use others from outside independent sources. Each Advisory Associate develops his or her own methods of analysis, sources of information, and investment strategies. As such, recommendations by Advisory Associate and individual investment portfolios will differ.

The Advisory Associate will manage accounts on an ongoing basis and will review accounts at least annually with the client or upon the client’s request. The purpose of the review is to determine whether there have been any changes in the client’s financial situation and investment goals and to determine whether any changes in the client’s investment portfolio are appropriate. The Advisory Associate also reviews the client’s asset mix and makes recommendations regarding changes to the portfolio.

Clients will receive monthly brokerage statements, except for months in which no account activity has occurred, and quarterly statements and performance reports. Clients may call at any time during normal business hours to speak directly with their Advisory Associate or the Crown home office about their account, financial situation, or investment needs.

Crown Heritage Wrap Fees

The Crown Heritage program is an All-Inclusive account in which clients pay an asset-based advisory fee and, occasionally, fees such as a stock reorganization fees passed on by the clearing firm. The following are the maximum advisory fees applied to this program. These fees may be negotiable at the sole discretion of management.

Crown Heritage Program Wrap Fee Schedule

Value of Account Assets Annual Fee First $500,000 2.00% Next $500,000 1.50% Next $1,000,000 1.00% Over $1,999,999 Negotiable
Billing
Clients will be charged advisory fees based on an annualized percentage of the value of the assets in the Crown Heritage account. The fee will be assessed and billed quarterly in advance. The fee for any given calendar quarter is debited by the custodian from the client’s account at the beginning of the calendar quarter, based on the total portfolio value as of the last business day of the preceding calendar quarter. The first fee will be billed upon execution of the Agreement and will be based upon the opening value of the account. If the Agreement is executed at any time other than the first day of a calendar quarter, the payment will be prorated. Alternatively, clients may elect to pay all advisory fees described above from a National Financial Services (“NFS”) or Pershing, LLC (“Pershing”) brokerage account(s) other than their Crown Heritage account. Direct payments will be calculated in the same manner and billed on the same time frame.
Additional Expenses
Clients who purchase mutual fund shares and variable insurance contracts within their Crown Heritage account or move existing funds or contracts into their Crown Heritage account should also understand that they will pay annual fees assessed by mutual fund and insurance companies that are not included in the Crown Heritage wrap fee. Furthermore, Class B, C, and similar mutual fund shares, and variable products held in accounts may incur sales charges when sold or redeemed. For more specific information about fees and charges, including Contingent Deferred Sales Charges (CDSC), surrender charges and annual 12b-1 fees, clients should refer to the fund or variable product prospectus.
Crown Advisory Associates Compensation
The Advisory Associates managing the Crown Heritage account will receive a portion of the advisory fee as a result of their services and the client’s participation in the program. The Advisory Associates portion of this fee ranges from .50% to 2.00% per year. The amount of this compensation may be more or less than the amount the Crown Advisory Associate would receive if the client participated in other company programs or paid separately for investment advice, brokerage, and other services.

Furthermore, clients should understand that some mutual funds and insurance companies may pay 12b-1 fees to Crown for mutual fund shares and variable contracts held in the Crown Heritage. To that extent, the Crown Advisory Associate may be compensated through both the Crown Heritage program and through any such fees paid by mutual fund companies and insurance companies. Crown and its Advisory Associates consider costs, fees and the client’s interests when recommending investments; however, clients should consult mutual fund and variable product prospectus to determine all fees and compensation when considering the purchase of such products. Mutual funds and variable insurance contracts that were not purchased at their Net Asset Value ("NAV”) may only be deposited into a Crown Heritage program account if they were purchased through Crown at least two years prior to opening the account, or if they were purchased at any time through another broker dealer, unless there is an economic or practical reason for doing so.
Potential Conflict of Interest
Mutual Fund 12b-1 fees paid by mutual fund or insurance companies to Crown may be passed, in whole or in part, to Advisory Associates. Therefore there is an inherent conflict of interest for an Advisory Associates to favor certain mutual funds, contrary to the interest of the client. Crown may receive a portion of fees earned on money market balances in the accounts custodied with NFS and Pershing. Crown my pass this fee on to the Advisory Associates in whole or in part. These fees are nominal; however, this could amount to an incentive to retain assets in money market accounts.

Advisory Associates are responsible for disclosing all conflicts of interest that arise through the management of clients accounts in connection with the Crown Heritage program and are responsible to disclose such conflicts to the Crown Investment Committee. The Investment Committee will determine the materiality of such conflicts. All material conflicts will be disclosed to the clients involved. Such clients will be offered an opportunity waive such conflicts, to work with another Advisory Associate, or to move their assets to another investment advisory firm.

Crown looks for potential conflicts of interest during account review. Any individual knowingly placing their own interest above that of clients may be subject to termination.

Account Termination
Client may terminate the Crown Heritage account without penalty within five (5) business days of Client’s signature.

This Agreement may be terminated by either party effective upon receipt of written notice to the other party (“Termination Date”) provided that such termination does not cause the client to forfeit any prepaid fees or such otherwise forfeitable fees are reimbursed to client. Crown will advise the account custodian to deliver securities and funds held in the account as instructed by Client unless Client requests that the account be liquidated. If an account is liquidated as a result of a termination notice, proceeds will be payable to Client upon settlement of all transaction in the account. The Client will be entitled to a prorated refund of any pre-paid quarterly advisory fee based upon the number of days remaining in the quarter after the termination date. The Transaction Charges set forth in Exhibit A will remain in effect for 30 days from the Termination Date. Thereafter, the Crown Heritage account assets will be transferred to a standard brokerage account unless the Client otherwise directs in writing. If an account is closed within the first six months by Client or as a result of withdrawals which bring the account value below the required minimum, Crown reserves the right to cancel and rebill all transactions in the account at normal and customary brokerage commission rates, in order to cover the administrative cost of establishing the Crown Heritage account. Termination of the Agreement will not affect the liabilities or obligations of the parties arising from transactions initiated prior to termination. The Client shall be responsible for any transactions initiated prior to Account, and may also have tax consequences. In addition, early redemption fees or similar fees for mutual funds and other products may be applicable as described in product’s prospectus or other offering documents. Certain assets that may be transferred or held in the Account may not be accepted by another broker dealer. Crown will use reasonable efforts to follow Client instructions regarding the disposition of Account termination. Such redemption or liquidation may affect the asset allocation and/or market value of the assets to the extent permitted by law and policies of the receiving firm.
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Crown provides investment advice in the Crown Heritage program, where appropriate, to individuals, trusts, estates, charitable organizations, corporations, and other business entities.

Minimum Account Size
As previously disclosed in Item 4 above the minimum account size for each program is as follows:

Program Name Minimum Account Size
• The Crown Heritage Model Management Program $25,000
• The Crown Heritage Wrap Strategists $25,000
• The Crown Heritage Separate Accounts Wrap $100,000 These minimum account values may include the value of previously purchased securities that are transferred into the client’s Crown Heritage account and the aggregate of multiple Crown Heritage accounts. The minimum requirement may be waived for certain accounts at the sole discretion of Crown.

Custody
Crown Heritage clients must direct Crown as to the broker dealer/custodian to be used in managing their account. Crown requires that clients direct it to custody the client’s assets with and to place trades through National Financial Services, LLC (“NFS”). NFS is a FINRA-member broker dealer and one of the clearing firms Crown uses for its brokerage accounts. Crown has evaluated NFS and believes that it will provide Crown’s clients with a blend of execution services, commission costs, and professionalism that will assist CROWN in meeting its fiduciary obligations to clients. Clients always retain all indicia of ownership of the cash and securities in the account, the right to vote proxies for the securities and the right to pledge and hypothecate such securities. Crown has negotiated an arrangement with NFS to provide custodial and brokerage services as part of the Crown Heritage Program. As such, Crown reserves the right to decline acceptance of any client account for which the client directs the use of a broker dealer/custodian other than NFS. In evaluating such an arrangement, the client should recognize that brokerage commissions for the execution of transactions in the client's account are not negotiated by Crown on a trade-by-trade basis, and best execution may not be achieved. In addition, as noted above in Item 4, transactions in the client’s account are effected “net” (i.e., without separate commission charge to the client) and a portion of the wrap fee is generally considered as being in lieu of commissions. Not all advisers require clients to direct it to use a particular broker dealer, though the sponsors of wrap fee programs typically do.

As custodian, NFS and Pershing will credit their respective accounts with dividends and interest paid on securities held in the client account and with principal paid on called or matured securities. please register to get more info

At this time, Crown Advisor Associates are the sole portfolio managers in the Crown Heritage Program. Crown’s Advisory Associate must possess, minimally, a college degree and/or appropriate business experience and all required licenses.

As noted above in Item 5, Crown has partnered with NFS to provide brokerage, custodial and other services for the Crown Heritage Program. Crown relies upon NFS to calculate portfolio manager performance. Pershing uses the Bank Administration Institute (“BAI”) method when computing performance. The BAI method is compliant with Global Investment Performance Standards (“GIPS,” formerly known as the AIMR Performance Presentation Standards). The BAI is a non-profit organization that focuses on improving banking standards (in the operations and auditing areas). GIPS is a set of standardized, industry-wide ethical principles that provide investment firms with guidance on how to calculate and report their investment results to prospective clients.

Please see the disclosure in Item 4 for the services provided by these Advisory Associate and the fees charged within the Crown Heritage Program. We do not charge performance-based fees (i.e., fees based on a share of capital gains on or capital appreciation of the assets of a client).
Methods of Analysis, Investment Strategies and Risk of Loss
We may use the following methods of analysis in formulating the investment advice we provide to clients in the Crown Heritage Program.
Fundamental Analysis:
We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indication it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis 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.
Technical Analysis:
We also analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement.

Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement.
Cyclical Analysis:
In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security.

Cyclical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement.
Asset Allocation:
Rather than focusing primarily on securities selection, Crown also attempts to identify an appropriate ratio of equities, fixed income, and cash or cash equivalents suitable to the client’s investment goals and risk tolerance.

A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of equities, fixed income, and cash or cash equivalents will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals.
Mutual Fund Analysis:
Mutual funds in client portfolios will be recommended on the basis of any or all of the following criteria: the fund's performance history; the asset class and industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. A risk of mutual fund analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund, which could make the fund less suitable of the client’s portfolio.
Third-Party Manager Analysis:
We examine the experience, expertise, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks.

A risk of investing with a third-party manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, it is possible for us to miss the absence of internal controls necessary to prevent business, regulatory or reputational deficiencies.

Risks for All Forms of Analysis:
Our securities analysis method relies on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. There is always a risk that our analysis may be compromised by inaccurate or misleading information.

We may use the following investment strategies, as appropriate, when managing client assets:
Long-term Purchases:
Where appropriate, our firm employs a long-term investment strategy when formulating the investment advice given to clients. This entails the purchase of securities with the idea of holding them in the client’s account for a year or longer. We may do this because we believe the securities to be currently undervalued. We may do this because we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that, by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell.
Short-term Purchases:
Where appropriate, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A risk in a short-term purchase strategy is that, should the anticipated price swing not materialize, we are left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and may result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short- term capital gains.
Short Sales:
In addition, we may borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. We then sell the shares we have borrowed. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If the stock has gone down since we purchased the shares from the original owner, the client keeps the difference.

One risk in selling short is that losses are theoretically unlimited; we are obligated to repurchase the stock no matter how much the price has climbed. In addition, even if we are correct in determining that the price of a stock will decline, we run the risk of incorrectly determining when the decline will take place. Short selling may not be appropriate in times of inflation, as prices may adjust upwards regardless of the value of the stock.

Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal.
Voting Client Securities
Crown does not vote client proxies. Our clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other types of events pertaining to the client’s investment assets. Therefore, Crown and/or the client shall, as required in each case, instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. Crown also does not typically provide advice to clients regarding the clients’ voting of proxies. please register to get more info

As noted above, Crown’s Advisory Associates are the sole portfolio managers in the Crown Heritage Program. They are in direct contact with Crown Heritage clients. Crown does not typically communicate updated information to these Advisory Associates regarding their clients. please register to get more info

Crown does not place any restrictions on a client’s ability to contact and consult with their portfolio managers. All clients have direct access to the Crown Advisory Associate(s) managing their account(s). please register to get more info

Legal & Disciplinary Info
We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Crown Capital has three disciplinary events relating to our firm that occurred within the last ten years:

The first was an allegation by the State of Nevada that Crown failed to properly license two investment advisor representatives in Nevada. Crown agreed to comply with Nevada revised statutes and consent to a $15,000 penalty.

The second is an allegation by FINRA that the firm failed to transmit its reportable order events to the order audit trail system during a specific period, and did not provide documentary evidence that it performed the supervisory reviews set forth in its written supervisory procedures concerning OATS. On 6/20/2013, without admitting or denying the allegations, Crown agreed to settle the issue by paying a $15,000 penalty.

The third is an allegation that the firm failed to properly disclose Alaska orders against a representative from 1984 and the representative's website failed to properly disclose that his firm was licensed to sell insurance in products in Oregon, Utah and Washington. This order was entered against Crown Capital Securities and two other non-affiliated entities. The entities agreed to settle the matter for $12,500 with $6,250 suspended for a period of five years.

The forth is a 6/20/2019 FINRA finding that the firm failed to establish and maintain a supervisory system, including written supervisory procedures, for reviewing and monitoring mutual fund switches reasonably designed to achieve compliance with FINRA suitability requirements. The findings stated that the firm failed to reasonably supervise short-term switches of Class A mutual fund shares conducted by two firm registered representatives. The firm’s supervisory system was not reasonably designed to supervise mutual fund switches because it relied solely upon the registered representative to alert the firm of a mutual fund switch. The firm had no supervisory mechanism in place to initiate a review of mutual fund switches in the event a representative failed to complete the mutual fund switch form. As a result, mutual fund switch transactions by the two registered representatives in this matter escaped supervisory scrutiny by the firm. The firm voluntarily paid approximately $395,000 in restitution to affected customers and without admitting or denying the allegations agreed to a censure and fine of $75,000. A list of all legal and disciplinary events for Crown and our advisory affiliates are disclosed as required in response to Item 11 of Form ADV, Part 1A, which can be accessed by following the directions provided on the Cover Page of this Firm Brochure.
Other Financial Industry Activities and Affiliations
Crown Capital Securities, L.P. ("Crown"), which is a Registered Investment Advisor, is also a securities broker dealer and provides contract services to licensed securities representatives. As a broker-dealer, Crown provides due diligence and clears selected products which are sold by registered representatives who may also be associated with Crown's registered investment advisory service ("Advisory Associates"). The client of an Advisory Associate may pay both a fee and commission during the development and implementation of a financial plan, if the client chooses to implement the Advisory Associate’s recommendations through Crown and the Advisory Associate.

The principal business of Crown and its executive officers is that of a Securities Broker-Dealer registered with FINRA. In that capacity, Crown, its officers, branch managers and registered representatives, who may also be Advisory Associates, buy and sell securities on behalf of clients. It is estimated that over 80% of the time of Crown's officers and Advisory Associates is devoted to their business as a securities broker dealer.

Crown is under common ownership and control with the following other financial institutions (referred collectively with Crown as the “Related Companies”):

Consolidated Brokerage Services, Inc. CCIA Insurance Agency of Nevada, Inc. Jewel Insurance Agency, Inc. CCIA Insurance Agency of Alabama, LLC Crown Capital Insurance Agency, LLC CCIA Insurance Agency of Washington, LLC

Where appropriate, Crown, its employees and Advisory Associates will recommend the various investment-related and non-investment services of the Related Companies to its advisory clients. The Related Companies and their employees may also recommend the investment advisory services of Crown to their customers. The services provided by the Related Companies are separate and distinct from the advisory services of Crown, and are provided for separate and additional compensation. There may also be arrangements between Crown and these Related Companies where Crown and/or the Related Companies and their employees receive payment in exchange for client leads and referrals. In addition, many Advisory Associates who are properly licensed also sell insurance, real estate, prepare income tax returns, and provide accounting services. Some of Crown's Advisory Associates may also be licensed as lawyers, and as lawyers, may provide legal advice. No Crown client is obligated to use the services of any of the Related Companies or Advisory Associates in their separate capacities.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Our firm or individuals associated with our firm may buy or sell securities identical to those recommended to clients for their personal accounts. In addition, any of our firm’s related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. This presents a conflict of interest in that an employee of our firm may purchase a security for himself/herself prior to that transaction being implemented in a client’s account, thus, receiving a more favorable price, commission, or allocation. Crown has adopted a Code of Ethics (“Code”) that, among other things, addresses this conflict of interest by setting forth restrictions regarding an employee’s purchase or sale of a security prior to a transaction(s) in the same security in a client account. Our Code also includes the following terms to ensure Crown meets its fiduciary responsibilities as a registered investment adviser:

- No employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry; - No person employed by Crown shall prefer his/her own interests to those of its advisory clients; - We maintain a list of all securities holdings for our firm and anyone associated with this advisory practice with access to advisory recommendations; these holdings will be reviewed on a regular basis by the Chief Compliance Officer of Crown, and/or his designee, to supervise compliance with the firm's Code of Ethics; - We emphasize the unrestricted right of the client to decline to implement any advice rendered; - Our owner and employees must act in accordance with all applicable state and federal regulations governing registered investment advisory practices; and - Any individual not in observance of the above may be subject to sanctions including termination.

Clients and prospective clients may obtain a copy of the firm's Code of Ethics by contacting the firm's Chief Compliance Officer at the firm’s principal place of business.
Review of Accounts

Account Reviews: Generally the supervision of activity on behalf of Crown is by the Branch Manager of each branch where advisory services are conducted. Client reviews are conducted by the Advisory Associate managing the client(s) account(s). Although Crown does not dictate a specific number of client accounts that any Advisory Associate may supervise or be involved in, the Branch Manager and Home Office monitor the size, number and type of advisory clients assigned to each Advisory Associate to maintain the quality of service to clients. The number of accounts overseen by an Advisory Associate will vary individual to individual. Statements: Account statements for all Crown Heritage program accounts are prepared by the independent advisor who is managing the account with duplicate copies sent to the Advisory Associate for review. Statements are prepared at least quarterly on all managed accounts with most accounts producing a monthly statement any time there is activity in the account. Statements are produced by the custodian or clearing firm that holds the account. Neither Crown nor its Advisory Associates produce regular account statements.
Client Referrals and Other Compensation
We may pay a one-time, nominal flat fee to certain employees of the Related Companies for the referral of a prospective client. The payment of this fee is not contingent upon the prospective client actually becoming an advisory client of Crown. It is paid if one of Crown Advisory Associates has a meaningful conversation about investments with the prospective client.
Financial
Crown has not been the subject of a bankruptcy petition at any time in its existence. Under no circumstances will we earn fees in excess of $1,200 more than six months in advance of services rendered. please register to get more info