CoBiz Wealth (“CoBiz”) is a registered investment adviser and a Colorado Corporation, with
offices in both Colorado and Arizona which offers investment management services, investment
supervisory services, and financial planning services. The firm combines intellectual rigor and a
disciplined process to create customized diversified investment portfolios for its clients. We
build portfolios based on specific client needs and objectives, using a hybrid open architecture
approach that provides broad opportunity. We combine the expertise of our in-house investment
team, responsible for managing our proprietary equity and fixed income portfolios, with the
capabilities of external managers with complementary styles and methodologies, to implement
investment solutions that are global in nature and thoroughly researched.
CoBiz Wealth was founded in 1975 and in 2018 was acquired by BOK Financial Corporation, a
financial holding company based in Tulsa, Oklahoma.
CoBiz Wealth primarily engages in providing investment advisory services to individuals, trusts,
estates, charitable organizations, corporations or other business entities. CoBiz Wealth also
offers financial planning services.
CoBiz Wealth tailors advisory services to the individual needs of clients by personalizing its
portfolio management services so that each client has a customized investment plan. As part of
this investment plan, clients may impose some restrictions on investing in certain securities or
types of securities. Security level restrictions may not be applied for purchased or held mutual
funds, exchange traded funds, separately managed accounts or other third party investment
products. Investment strategies are guided by a deep knowledge of our clients’ current situation
and future plans. Our strategies are able to adapt to our clients’ changing needs and are
periodically reassessed throughout the year.
CoBiz Wealth participates in wrap fee programs by providing portfolio management services.
There are no material differences in how wrap fee accounts are managed. CoBiz Wealth
receives a portion of the wrap fee for the services provided.
CoBiz Wealth manages client assets on both a discretionary and non-discretionary basis. As of
12/31/2018, CoBiz Wealth managed $959,289,616 in discretionary assets and $8,876,493 in non-
discretionary assets for an approximate total of $968,166,109 in regulatory assets under
management.
A copy of CoBiz Wealth’s privacy policy notice and a written disclosure statement that meet the
requirements of Rule 204-3 of the Investment Advisers Act of 1940, as amended (“Advisers
Act”), shall be provided to each client prior to or in conjunction with the execution of an
Investment Management Agreement (“IM Agreement”) or a Financial Planning Agreement (“FP
Agreement”). Any client who has not received a copy of CoBiz Wealth’s written disclosure
statement at least forty-eight (48) hours prior to executing an agreement with CoBiz Wealth shall
have five (5) business days subsequent to executing an agreement to terminate CoBiz Wealth’s
services without penalty.
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CoBiz Wealth offers investment advisory services for a fee based upon a percentage of assets
under management. CoBiz Wealth charges a management fee for each calendar quarter during
any part of which an IM Agreement is in effect. The management fee is paid quarterly, normally
in arrears, based upon a percentage of the market value of the assets being managed by CoBiz
Wealth, which is determined on the last day of the preceding quarter. (Some Wrap Program fees
are charged in advance according to the Wrap Program Sponsors’ agreements with their clients.)
Fees are generally computed based upon the aggregate of family or related assets under
management and then charged proportionately.
Annual Fee Schedule - Investment Account
For All Assets: Suggested Minimum $1,000,000
First $2,000,000 @ 1.00%
Next $3,000,000 @ 0.80%
Next $5,000,000 @ 0.70%
Next $10,000,000 @ 0.30%
Next $10,000,000 @ 0.25%
$30,000,000 or more - Negotiable
Annual Fee Schedule - Fixed Income-Only Account
For All Assets: Suggested Minimum $1,000,000
First $2,500,000 @ 0.50%
Next $2,500,000 @ 0.35%
Next $5,000,000 @ 0.25%
$10,000,000 or more @ 0.20%
Management fees are negotiable depending upon the market value of the assets under
management and the type of investment management services to be rendered. CoBiz Wealth, in
its sole discretion, may negotiate to charge a lesser management fee based upon certain criteria
(i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, pre-existing client relationship,
account retention, pro bono activities, etc.). Employees of CoBiz Financial, its affiliates (see
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For advisory services offered for fees based upon a percentage of assets under management, the
IM Agreement authorizes CoBiz Wealth, through Financial Institution(s), to deduct fees from the
client’s assets for the amount of CoBiz Wealth’s fee and to directly remit that management fee to
CoBiz Wealth in accordance with applicable custody rules. Financial Institution(s) shall include,
but are not limited to, any custodian or broker-dealer recommended by CoBiz Wealth, custodian
or broker-dealer directed by the client, trust companies, separate account managers, banks, etc.
The Financial Institution(s) recommended by CoBiz Wealth have agreed to send a statement to
the client, at least quarterly, indicating all amounts disbursed from the account including the
amount of management fees paid directly to CoBiz Wealth. Clients also have the option to
directly pay CoBiz Wealth the management fee by check.
The management fee is exclusive of, and in addition to, brokerage commissions, transaction fees,
custodian fees, mutual fund expenses, separately managed account fees and other related costs,
which shall be incurred by the client. CoBiz Wealth shall not receive any portion of these
commissions, fees, and costs. Please see Item 12 for more information on brokerage practices.
CoBiz Wealth may refer the client to an outside investment advisor (sub-advisor) to perform
investment management services over a portion of the client’s portfolio. Specific services and
fees related to separately managed accounts will be available in the outside investment advisor’s
current disclosure document and on CoBiz Wealth‘s Separate Account Management
Authorization Agreement. CoBiz Wealth may choose to use one or more sub-advisors in a
client’s portfolio with the goal of providing more specialized investment diversification and
expanded product offerings.
For the initial quarter that investment management services are rendered, the management fee
shall be calculated on a pro-rata basis. The IM Agreement between CoBiz Wealth and the client
will continue in effect until terminated by either party pursuant to the terms of the IM
Agreement. CoBiz Wealth’s fee shall be prorated through the date of termination based on the
number of days in the calendar quarter during which the IM Agreement was in effect.
The client may make additions to and withdrawals from the account at any time, subject to
CoBiz Wealth’s right to terminate an account. However, CoBiz Wealth generally designs its
portfolios as long-term investments and asset withdrawals may impair the achievement of a
client’s investment objectives.
Financial planning services are available to clients with an existing investment advisory account
generally at no additional charge as part of CoBiz Wealth’s suite of services. For prospective
clients seeking only financial planning services, CoBiz Wealth will execute an FP Agreement
based on a fixed fee schedule and services rendered. Fees for financial planning services will be
billed to the client and collected at the initiation of the plan services. If the FP Agreement is
terminated prior to the completion of the financial plan, a pro rata refund of unearned fees based
on the time and effort expended by the firm and the planner will be considered. In the event the
client establishes an investment advisory account prior to completion of the financial plan, the
fee for the financial plan could be offset against the initial fees for investment advisory services.
Fixed Fee Schedule – Financial Planning Services
Tier 1 - $3,000
Tier 2 - $5,000
Tier 1 Services include:
Current Net-Worth Statement
Cash Flow and Retirement Planning
Risk Management Review
Investment Review
Education Planning (if applicable)
Tier 2 Services include:
Current Net-Worth Statement Cash Flow and Retirement Planning
Risk Management Review
Investment Review
Education Planning (if applicable)
Estate Snapshot
Estate and Wealth Transfer Planning
Advanced Retirement Planning – options, deferred compensation, etc.
Philanthropic Planning (if applicable)
Business Transition Planning (if applicable)
No employee of CoBiz Wealth accepts compensation for the sale of securities or other
investment products or services.
Item 6. Performance-Based Fees and Side-By-Side Management
CoBiz Wealth does not charge performance-based fees or fees based on a share of capital gains
on or capital appreciation of client assets. In addition, CoBiz Wealth does not engage in side-by-
side management (such as charging performance-based fees and another type of hourly fee or
asset-based fee).
Item 7. Types of Clients
CoBiz Wealth provides investment management services primarily to individuals, trusts, estates,
charitable organizations, corporations and business entities.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
CoBiz Wealth uses fundamental, technical, and cyclical analysis and charting when formulating
investment advice. The main sources of information CoBiz Wealth uses include: research
materials prepared by others, annual reports, prospectuses, filings with the SEC and company
press releases, financial newspapers and magazines, inspections of corporate activities, corporate
rating services, and timing services. The investment strategies used to implement any
investment advice given to clients include primarily long-term purchases (securities held at least
a year), but may also include: short-term purchases (securities sold within a year), separately
managed accounts, option writing, including covered options, uncovered options or spreading
strategies. Investing in securities involves risk of loss that clients should be prepared to bear.
In recommending an investment strategy, circumstances of the client(s) are considered.
Appropriate recommendations are made based on the risk tolerance of the client. CoBiz Wealth
may recommend that clients who are "accredited investors" as defined under Rule 501 of the
Securities Act of 1933, as amended, invest in private placement securities, which may include
debt, equity, and/or pooled investment vehicles when consistent with the client’s investment
objectives. When CoBiz Wealth recommends that the client invest in private placement
securities, CoBiz Wealth shall receive no additional compensation but shall continue to receive
applicable investment advisory fees on the clients’ assets under management. CoBiz Wealth may
also provide advice about any type of investment held in a client’s portfolio throughout the
advisory relationship.
Item 9. Disciplinary Information
CoBiz and its employees have not been involved in any investment-related legal or disciplinary
events in the past 10 years that would be material to a client’s evaluation of CoBiz or its personnel.
Certain CoBiz management persons are also employees, management persons, executive
officers, directors, or registered representatives of BOKF, NA, Cavanal Hill Investment
Management, Inc., BOK Financial Asset Management, Inc., The Milestone Group, Inc., or BOK
Financial Securities, Inc. Neither CoBiz nor any of its employees are registered, or have an
application pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading advisor, or are an associated person of the foregoing entities. CoBiz has
established policies and procedures to address conflicts of interest and address the SEC’s
requirements on principal and affiliated trading. The Firm has also established restrictions
within its Code of Ethics that reflect its fiduciary responsibilities.
The following is a description of relationships or arrangements that are important to CoBiz’s
advisory business or to our clients that we or our personnel have with any affiliate mentioned
below.
Related Relationships
Banking or Thrift Institution
BOKF, NA is a national banking association and is a wholly-owned subsidiary of BOK Financial
Corporation. BOKF, NA does business as Bank of Oklahoma, Bank of Texas, Bank of
Albuquerque, Bank of Arizona, Colorado State Bank and Trust, Missouri Bank and Trust
Company and Bank of Arkansas.
Investment Advisor or Financial Planner
BOK Financial Securities, Inc. is a dual registered broker/dealer and investment advisor (dba:
BOK Financial Advisors- “BOK FA”) and an affiliate of CoBiz. BOKF, NA is a national
banking association affiliate that may also provide advisory and financial planning services to its
clients. BOK Financial Asset Management, Inc., Cavanal Hill Investment Management, Inc. and
StepStone LP are registered investment advisor affiliates of CoBiz, and wholly-owned
subsidiaries of BOKF, NA. Cavanal Hill includes a diverse and experienced team of full-time
professional portfolio managers, offering CoBiz clients access to fixed income and equity
security inventories often available to institutional-level investors. CoBiz may utilize Cavanal
Hill as a sub-advisor when CoBiz believes it is in the best interest of such clients.
Investment Company or Other Pooled Investment Vehicle
The Cavanal Hill Funds, an affiliate of CoBiz, is an investment company registered under the
Investment Company Act of 1940. The Cavanal Hill Funds are managed by Cavanal Hill and are
compensated for the provision of services to the funds (e.g., distribution, custodial, and
administrative services). CoBiz may engage Cavanal Hill to provide their mutual funds and
alternative investments to certain CoBiz clients.
Broker-Dealer, Municipal Securities Dealer, or Government Securities Dealer
BOK Financial Securities, Inc. is a registered broker-dealer, municipal securities dealer, and
member FINRA/SIPC. CoBiz does not effect client transactions through BOK Financial
Securities, Inc.
Insurance Company or Agency
BOSC Agency, Inc. is a subsidiary of BOK Financial Corporation and an affiliate of CoBiz.
As required, any affiliated investment advisers and broker-dealers are specifically disclosed in
Section 7.A on Schedule D of Form ADV, Part 1, which can be accessed by following the
directions provided on the cover page of this Brochure.
The CoBiz family is made up of the following financial services companies in addition to CoBiz
Wealth:
CoBiz Bank (includes Colorado Business Bank, Arizona Business Bank, CoBiz Private
Bank and CoBiz Retirement Advisory Services). CoBiz Bank offers a broad range of
sophisticated banking services, including credit, treasury management, and deposit
products, and through a networking agreement, retirement services for businesses and
their employees.
CoBiz Insurance, Inc. CoBiz Insurance offers a full range of commercial insurance,
consulting and risk management services.
All clients of CoBiz Wealth that use the services of any of the other CoBiz affiliate companies
are advised of the relationship between CoBiz Wealth and those companies. A written agreement
setting forth the terms and conditions of the affiliated referral arrangements has been executed
with each participating CoBiz company as a party to the agreement.
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CoBiz Wealth has adopted a Code of Ethics that sets forth the standards of conduct expected of
its access persons and requires compliance with applicable securities laws. In accordance with
Section 204A of the Advisers Act, CoBiz Wealth’s Code of Ethics contains written policies
reasonably designed to prevent the unlawful use of material non-public information by CoBiz
Wealth or any of its access persons. The Code of Ethics also requires that all access persons
report their personal securities holdings and transactions and obtain pre-approval of certain
investments such as initial public offerings and limited offerings. Clients or prospective clients
may contact CoBiz Wealth to request a copy of its Code of Ethics.
CoBiz Wealth and its access persons are permitted to buy or sell securities that it also
recommends to clients consistent with CoBiz Wealth‘s policies and procedures. None of CoBiz
Wealth’s access persons may effect for themselves, or for their immediate family, any
transactions in a security which is being actively purchased or sold on behalf of any of CoBiz
Wealth’s clients. When CoBiz Wealth is purchasing or considering for purchase any security on
behalf of a client, no access person may effect a transaction in that security prior to the
completion of the purchase or until a decision has been made not to purchase such security
without pre-approval of the purchase by the firm’s Chief Compliance Officer (“CCO”) or his
designee. Similarly, when CoBiz Wealth is selling or considering the sale of any security on
behalf of a client, no access person may effect a transaction in that security prior to the
completion of the sale or until a decision has been made not to sell such security without pre-
approval of the sale by the firm’s CCO or his designee. These requirements are not applicable to:
(i) direct obligations of the Government of the United States; (ii) money market instruments,
bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and
other high quality short-term debt instruments; (iii) shares issued by mutual funds or money
market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one
or more mutual funds.
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CoBiz Wealth shall generally recommend the brokerage, clearing and/or custodial services of
numerous broker-dealers and/or banks for investment management accounts. CoBiz Wealth may
only implement its investment management recommendations after the client has arranged for
and furnished CoBiz Wealth with all information and authorization regarding accounts with
appropriate Financial Institution(s).
Clients may incur certain charges imposed by the Financial Institution(s) and other third parties
such as custodial fees, separate account manager fees, charges imposed directly by a mutual fund
or exchange traded fund in the account, which shall be disclosed in the fund’s prospectus (e.g.,
fund management fees and other fund expenses), deferred sales charges, odd lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Additionally, for assets outside of any wrap fee programs,
clients may incur brokerage commissions and transaction fees. Such charges, fees and
commissions are exclusive of and in addition to CoBiz Wealth’s management fee.
Factors which CoBiz Wealth considers in recommending particular Financial Institution(s), or
any other broker-dealer, to clients include their respective financial strength, reputation,
execution, pricing, research and service. The commissions, separate account management fees,
custodial fees and/or transaction fees charged by Financial Institution(s) may be higher or lower
than those charged by other broker-dealers. The commissions paid by CoBiz Wealth’s clients
shall comply with CoBiz Wealth’s duty to obtain "best execution." However, a client may pay a
commission that is higher than what another qualified broker-dealer might charge to effect the
same transaction where CoBiz Wealth determines, in good faith, that the commission is
reasonable in relation to the value of the brokerage and research services received. In seeking
best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including among others, the value of research provided, execution
capability, commission rates and responsiveness. Consistent with the foregoing, while CoBiz
Wealth will seek competitive rates, it may not necessarily obtain the lowest possible commission
rates for client transactions.
If the client requests CoBiz Wealth to arrange for the execution of securities brokerage
transactions for the client’s account, CoBiz Wealth shall direct such transactions through broker-
dealers that CoBiz Wealth reasonably believes will provide best execution. Transactions may be
cleared through other broker-dealers with whom CoBiz Wealth and the Financial Institution(s)
have entered into agreements for prime brokerage clearing services. CoBiz Wealth shall
periodically and systematically review its policies and procedures regarding recommending
broker-dealers to its clients in light of its duty to obtain best execution.
Research:
In addition to trade execution, CoBiz Wealth receives research from some broker-dealers in
connection with client securities transactions. This provides a benefit to CoBiz Wealth because
CoBiz Wealth would otherwise have to pay for or produce this research. CoBiz Wealth may have
an incentive to select a broker-dealer based on receiving research rather than the client’s interest
in receiving the most favorable execution. Research received may be used for the benefit of all
client accounts.
Directed Brokerage:
A client may direct CoBiz Wealth in writing to use a particular broker-dealer to execute some or
all transactions. In that case, the client will negotiate terms and agreements for the account with
that broker-dealer, and CoBiz Wealth will not seek better execution services or prices from other
broker-dealers or be able to "batch" client transactions for execution through other broker-dealers
with orders for other accounts managed by CoBiz Wealth (as described below). As a result, the
client may pay higher commissions or other transaction costs or greater spreads, or receive less
favorable net prices on transactions for the account than would otherwise be the case.
In instances where CoBiz Wealth trades securities with the directed broker-dealer for the client’s
account or otherwise trades with the broker-dealer or receives business from the broker-dealer,
conflicts may arise. Subject to its duty of best execution, CoBiz Wealth may decline a client’s
request to direct brokerage if, in CoBiz Wealth’s sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
Grouping of Trades:
Transactions for each client generally will be effected independently, unless CoBiz Wealth
decides to purchase or sell the same securities for several clients at approximately the same time.
CoBiz Wealth may (but is not obligated to) combine or "batch" such orders to obtain best
execution, to negotiate more favorable commission rates, or to allocate equitably among CoBiz
Wealth’s clients differences in prices and commissions or other transaction costs that might have
been obtained had such orders been placed independently. Under this procedure, transactions
will generally be averaged as to price and allocated among CoBiz Wealth’s clients pro-rata to the
purchase and sale orders placed for each client on any given day. To the extent that CoBiz
Wealth determines to aggregate client orders for the purchase or sale of securities,
CoBiz Wealth shall do so in accordance with applicable rules promulgated under the Advisers
Act and no-action guidance provided by the staff of the U.S. Securities and Exchange
Commission. CoBiz Wealth shall not receive any additional compensation or remuneration as a
result of the aggregation.
In the event that CoBiz Wealth determines that a prorated allocation is not appropriate under the
particular circumstances, the allocation will be made based upon other relevant factors, which
may include: (i) when only a small percentage of the order is executed, shares may be allocated
to the account with the smallest order or the smallest position or to an account that is out-of-line
with respect to security or sector weightings relative to other portfolios, with similar mandates;
(ii) allocation may be given to one account when one account has limitations in its investment
guidelines which prohibit it from purchasing other securities which are expected to produce
similar investment results and can be purchased by other accounts; (iii) if an account reaches an
investment guideline limit and cannot participate in an allocation, shares may be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an order is
placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash;
(v) in cases when a prorated allocation of a potential execution would result in a
de minimis
allocation in one or more accounts, CoBiz Wealth may exclude the account(s) from the
allocation; the transactions may be executed on a pro-rata basis among the remaining accounts;
or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be
allocated at random.
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CoBiz Wealth monitors client portfolios as part of an ongoing process. Regular account reviews
are conducted by the client’s portfolio manager and approved by the CCO. All investment
advisory clients are encouraged to discuss their needs, goals and objectives with CoBiz Wealth
and to keep CoBiz Wealth informed of any changes thereto. CoBiz Wealth shall contact
investment advisory clients at least annually to review previous services and/or recommendations
and to discuss the impact resulting from any changes in the client’s financial situation and/or
investment objectives.
Unless otherwise agreed upon, clients are provided with regular summary account statements
directly from their Financial Institution(s) for the client accounts. Those clients to whom CoBiz
Wealth provides investment advisory services will receive reports from CoBiz Wealth during
one-on-one meetings. Also, upon request, the client can arrange to receive reports each quarter,
electronically or by mail. If reports are delivered electronically at the client’s request, it will be
necessary to have an executed Electronic Document Delivery Authorization form on file at
CoBiz Wealth.
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CoBiz Wealth participates in the CoBiz Financial referral program as described in Item 10
(above). Additionally, if a client is introduced to CoBiz Wealth by either an unaffiliated or an
affiliated solicitor, CoBiz Wealth may pay that solicitor a referral fee in accordance with Rule
206(4)-3 of the Advisers Act and any corresponding state securities law requirements. Any such
referral fee shall be paid solely from CoBiz Wealth’s investment management fee, and shall not
result in any additional charge to the client. If the client is introduced to CoBiz Wealth by an
unaffiliated solicitor, the client will be provided with a copy of CoBiz Wealth’s written
disclosure statement which meets the requirements of Rule 204-3 of the Advisers Act, and a
copy of the solicitor’s disclosure statement containing the terms and conditions of the solicitation
arrangement including compensation. Any affiliated solicitor of CoBiz Wealth shall disclose the
nature of his/her relationship to prospective clients at the time of the solicitation.
Unaffiliated solicitors are provided an allocation of a referred client’s management fee based
upon an agreed percentage. CoBiz Wealth does not currently compensate any unaffiliated
solicitors for client referrals.
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Clients of CoBiz Wealth will receive monthly or quarterly account statements directly from their
Financial Institution(s). Clients should carefully review the Financial Institution statements and
are urged to compare them to any reports provided by CoBiz Wealth.
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CoBiz Wealth accepts discretionary and non-discretionary authority to manage securities
accounts on behalf of its clients. Prior to CoBiz Wealth assuming this authority, a fully executed
IM Agreement that includes the execution of a limited power of attorney allowing CoBiz Wealth
to assume the specified authority must be executed. Clients that have provided CoBiz Wealth
with discretionary authority may restrict investment in certain securities or types of securities,
upon request, so long as the restrictions are not so extensive that they prohibit effective
implementation of the client’s investment strategy.
Neither CoBiz Wealth nor the client may assign the IM Agreement within the meaning of the
Advisers Act, without the consent of the other party.
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CoBiz Wealth will vote proxies on behalf of all clients who execute a Proxy Voting Addendum
to the IM Agreement. In the absence of a completed Proxy Voting Addendum, the obligation to
vote proxies for securities held within the account shall at all times rest with the client. All
proxies will be voted consistent with guidelines established and described in CoBiz Wealth’s
Proxy Voting Policies and Procedures, as amended from time-to-time.
CoBiz Wealth has engaged the services of a third party to provide and implement its proxy
voting guidelines and to vote client proxies. The third party shall do extensive research on all
proxy questions and vote client proxies according to CoBiz Wealth’s proxy voting guidelines.
The relationship with the third party will help CoBiz Wealth ensure proxy voting decisions are
made in the best interest of clients and avoid any conflicts of interest that could otherwise exist
due to business or personal relationships that CoBiz Wealth maintains with persons who may
have an interest in the outcome of certain votes.
At any time, clients may contact CoBiz Wealth to request information about how proxies for that
client’s securities were voted or to get a copy of CoBiz Wealth’s Proxy Voting Policies and
Procedures. Clients generally are not able to direct CoBiz Wealth’s vote in a particular
solicitation.
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CoBiz Wealth does not require or solicit prepayment of fees that would require a statement of
financial information.
CoBiz Wealth’s Chief Compliance Officer, Mark Marrone, remains available to address any
questions regarding this Part 2A of Form ADV brochure.
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