Capital Trust Advisors is a investment adviser based in San Rafael, CA, that holds a 98.3/100 Fidelon TransparencyScore (100th percentile among SEC-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Capital Trust Advisors
Goldberg Advisers · CRD #134174
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Capital Trust Advisors is an SEC-registered investment adviser in San Rafael, CA. It used to be called Paladin Investment Advisors and Goldberg Advisers, LLC. It has 3 registered advisors. It manages $402.6 million across 514 client accounts. It charges a percentage of the money it manages for you, and it does not report earning commissions. Its services include financial planning, portfolio management and educational seminars. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
68th of 23,937
SEC-registered advisers
Top 1%
12th of 3,143
SEC-registered advisers in CA
Top 1%
2nd of 30
SEC-registered advisers in San rafael, CA
Top 7%
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
- Does not earn commissions on product sales
Specializations
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
Conflict Audit
Zero material conflicts identified 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
“The more assets you have in your advisory account, the more you will pay us. This gives us an incentive to encourage you to increase the assets in your account which will increase our fees.”
“We recommend Charles Schwab & Co., Inc. to serve as custodian to our clients. Schwab provides us with certain products and services at no cost that benefit us but do not benefit our clients.”
Source: the firm’s own Form CRS, filed 2024-03-30 — 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.
93/100
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.
74/100
Fair
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
- 95/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 91/100
- 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 93 out of 100 and adds 8.25 points to the score above.
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.
CTA is typically compensated for its investment advisory services by charging you a management fee based on the market value of your assets under our management according to the fee schedule set forth below:p. 5
- 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 your fee depending upon circumstances including but not limited to account composition and complexity; other client employee or family relationships; or other conditions which may result in different fees being charged by us for client accounts similar in composition and objectives.p. 5
- 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.
We require that you authorize your custodian to allow us to directly debit our fee from your account or accounts.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.
Fees are billed quarterly in arrears based upon the market value of the assets at the end of the quarter.p. 5
- 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.
The fees you pay us do not include brokerage commissions or other fees or charges associated with securities transactions implemented with or through a brokerage firm, mark-ups or mark-downs in principal transactions, deferred sales charges, stock exchange fees, wire transfer or related processing fees, transfer taxes or other charges mandated by law or regulation, all of which will be charged to you in addition to our fee.p. 6
- 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 your relationship with us has begun or ended during a calendar quarter, your fee will be will be prorated for the appropriate number of days completed or remaining in the quarter and you will be issued an invoice for the final fees.p. 5
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity75/100
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 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.
The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions.p. 12
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions.p. 12
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account.p. 11
- 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?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
The availability of these services from Schwab benefits us because we do not have to produce or purchase them.p. 12
- 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.
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 Dollars71/100
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.
The additional services we receive from Schwab, as disclosed in the section entitled “Products and Services Available to Us From Schwab” above, would fall under this description of soft dollars.p. 12
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
The availability of these services from Schwab benefits us because we do not have to produce or purchase them.p. 12
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions.p. 12
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- 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?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
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
3 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| John Jackson Goldberg | 4340059 | — | — |
| James Jeffrey Lambert | 726677 | — | — |
| Sanford Philip Lowengart III | 2170252 | — | — |
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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: 3.14 · CRD #134174