Black Swift Group is a investment adviser based in Boulder, CO, that holds a 84.4/100 Fidelon TransparencyScore (42nd percentile among SEC-registered advisers), with 9 registered advisors. Score based on public SEC and FINRA filings.
Black Swift Group
Black Swift Group, LLC · CRD #286084
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Black Swift Group, LLC is an SEC-registered investment adviser in Boulder, CO. It used to be called Cbt Capital, LLC. Its 9 registered advisors typically serve high-net-worth individuals. It manages $694.1 million across 406 client accounts. It charges one yearly percentage of your account, and it does not report earning commissions. Its services include financial planning, portfolio management, educational seminars and private fund management. It reports that it can hold or access client money, which the SEC requires firms to disclose. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
6,250th of 10,815
SEC-registered advisers
Bottom 42%
175th of 289
SEC-registered advisers in CO
Bottom 39%
16th of 21
SEC-registered advisers in Boulder, CO
Bottom 24%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the All accounts band, charged at 1.00% on the full amount.
This fee is negotiable
“We may negotiate the amount of management fees depending upon the circumstances of each client, including, but not limited to, account composition, account complexity, and other client, employee, or family relationships, which may result in different fees being charged for accounts that are similar in composition and objectives.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Brokerage commissions, mutual fund fees, organizational and offering expenses, legal expenses, custodial fees, and other expenses as borne by the Funds
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| All accounts | 1.00% |
Billed quarterly in advance
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Who They Typically Serve
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- Its brochure says it receives research or services from brokers, but it does not say those perks can shape which broker it picks for you or the firm benefits by not paying for those things. Ask how the firm chooses the broker for your trades and whether perks play any part.Item 12.A.1
- Its brochure names an affiliated adviser or private fund as a conflict, but it does not explain what this arrangement tempts the firm to do, say what the firm is paid for it, or say what it can cost you. Ask whether any fund or adviser recommended to you is owned by or tied to the firm, and what fees that adds.Items 10, 11, 12.B and 14
Conflict Audit
Our analysis identified 1 potential conflict of interest in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“Our firm’s fees increase as client accounts grow, so we have an incentive to encourage our clients to increase the amount of assets in the accounts that are under our management.”
Source: the firm’s own Form CRS, filed 2026-03-30 — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
85/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
50/100
Weak
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 77/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
What to askAsk the advisor to name every way the firm gets paid besides your fee, and how each one can affect their advice.
- 44/100
- Can you tell what you would pay?
- What you pay
- 92/100
- Is it written in plain English?
- Plain language
- 94/100
This firm's Form CRS averages 77 out of 100. It adds 4.19 points once the firm's filings and record score 90 on their own; they score 84.41 today.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Clients are generally charged an annual management fee of 1% of assets under management, billed quarterly in advance, subject to a minimum quarterly fee.p. 6
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
We may negotiate the amount of management fees depending upon the circumstances of each client, including, but not limited to, account composition, account complexity, and other client, employee, or family relationships, which may result in different fees being charged for accounts that are similar in composition and objectives.p. 6
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
The custodian is instructed by the Adviser to debit the fee directly from the SMA.p. 6
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
With respect to SMAs, the advisory fee is payable quarterly in advance, within ten days of the start of each quarter.p. 6
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
In addition to management fees, clients are responsible for all brokerage commissions and other fees or charges associated with securities transactions executed through brokerage firms, stock exchange fees, and other charges mandated by law or regulation.p. 7
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
If Client terminates the advisory agreement before the end of a calendar quarter that has already been billed, Black Swift will promptly refund any unearned portion of the advisory fee.p. 6
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity51/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If it has an affiliated adviser or private fund, does it explain what that means for you?
An affiliated adviser or private fund
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Black Swift Partners, LLC, an affiliate of Black Swift, serves as the general partner to the Black Swift Special Situations Fund, LP, the Pro Cyclist Fund, LP, and the Pro Cyclist Institutional Fund, LP (collectively, the "Funds").p. 24
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether any fund or adviser recommended to you is owned by or tied to the firm, and what fees that adds.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
However, Black Swift generally receives access to research provided by broker-dealers used for trading in fixed income securities, equities, options, and private placements.p. 27
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
If the firm pays people who refer clients, does it explain those payments?
Payments to people who refer clients to the firm
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Black Swift has entered into an arrangement with a placement agent to solicit investors for certain Funds.p. 31
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
Black Swift compensates the placement agent for these services at the Adviser’s expense.p. 31
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk whether anyone was paid to refer you to the firm, and whether that affects what you pay.
- Hedged wording
While Black Swift believes it does not “pay up” for brokerage services to obtain research, clients should be aware that more favorable pricing may sometimes be available from broker-dealers who do not provide research or ancillary services.p. 27
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars47/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
Such research may include information on economic trends, industries, asset classes, pricing services, market data, statistical analyses, credit analyses, and other topics that aid Black Swift’s investment decision-making process.p. 28
- Does it say the firm benefits by not paying for those things?Not found in the brochureItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
What to askAsk what the firm would have to pay for those services if it bought them itself.
- Does it say those perks can shape which broker it picks for you?Not found in the brochureItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
What to askAsk how the firm chooses the broker for your trades and whether perks play any part.
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
To the extent Black Swift receives research services, it does so in a manner consistent with the safe harbor provided under Section 28(e) of the Securities Exchange Act of 1934.p. 27
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?CoveredItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
Soft dollar benefits, if any, may be used for the benefit of all client Accounts, regardless of whether the Accounts generated the soft dollar benefits.p. 28
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
9 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Gregory Joel Casals | 2160891 | — | — |
| Donald Brendan Byrne | 2644819 | — | — |
| Timothy Joseph Shasserre | 6386878 | — | — |
| Ashley Nicole Papa | 5858844 | — | — |
| Richard B Anderson | 6968483 | — | — |
| Tyler Shumway Hamilton | 7170710 | — | — |
| Adam Charles Vrablec | 7373006 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #286084