Central States Capital Markets is a dual-registered firm based in Prairie Village, KS, that holds a 60.0/100 Fidelon TransparencyScore (0th percentile among state-registered advisers), with 16 registered advisors. Score based on public SEC and FINRA filings.
Central States Capital Markets
Central States Capital Markets, LLC · CRD #155291
A dual-registered firm offering both advisory and brokerage services.
Fidelon Fact Sheet
Central States Capital Markets, LLC is an investment adviser and broker-dealer in Prairie Village, KS. It has 16 registered advisors. It manages $13.7 million across 7 client accounts. It charges a percentage of the money it manages for you. When it gives advice, it must put your interests first. When it sells products, it only has to pick ones that are suitable for you. Its services include financial planning and educational seminars. It has regulatory actions and criminal charges on file, most recently in 2018.
Peer Context
15,776th of 15,825
state-registered advisers
Bottom 1%
147th of 147
state-registered advisers in KS
Bottom 1%
4th of 4
state-registered advisers in Prairie village, KS
Bottom 1%
How This Firm Works
Registration & Standard of Care
Dual-Registered — this firm operates as both an investment adviser (fiduciary) and a broker-dealer. Some services come with fiduciary protection, while brokerage services may involve commissions.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Representatives can earn commissions on product sales
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Registered as investment adviser with fiduciary obligation
Things You Should Know
- Also operates as a broker-dealer — may not always be required to put your interests first
- 9 regulatory complaints reported by FINRA
- $167K in regulatory fines
Conflict Audit
Multiple structural conflicts identified in regulatory filings. These are disclosed business arrangements — worth asking about, not disqualifying.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
9
Disclosures
$167K
Total Fines
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
45/100
Weak
Avg for dual-registered firms: 66.8 | Top 10%: 97.2
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
80/100
Fair
Avg for dual-registered firms: 70.4 | Top 10%: 80.7
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.
71/100
Fair
Avg for dual-registered firms: 62.2 | Top 10%: 79.3
Enforcement History
Past actions taken by the SEC, FINRA, or state regulators, and how well the firm supervised its people.
38/100
Poor
Avg for dual-registered firms: 59.6 | Top 10%: 86.5
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 Clarity85/100
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.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
The maximum annual fee for portfolio management services is 1.25% of assets under management.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.
Management fees are negotiable based upon the Client’s individual needs and circumstances, such as the account size and the nature of the investment activity within the account.p. 7
- 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.
Payment for management fees will be made by the qualified custodian holding the Client’s funds and securities provided the Client grants written authorization permitting the fees to be paid directly from their account.p. 5
- 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.
Portfolio management fees will be billed quarterly in advance based on the value of the assets on the last business day of the preceding calendar quarter.p. 7
- 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.
Your account may incur other fees such as transaction fees, exchange fees and SEC fees.p. 7
- Does it say how you get money back if you leave mid-period?Not found in the brochureItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
What to askAsk what happens to fees already paid if you close the account partway through a billing period.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity50/100
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 its people earn commissions on securities, does it explain them?
Securities commissions
- 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.
CSCM is a broker/dealer as well as an investment adviser and will receive commissions on purchases and sales of securities which are executed on behalf of your account.p. 7
- 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 anyone at the firm earns a commission on investments recommended to you, and whether it lowers your fee.
If its people can earn insurance commissions, does it explain them?
Insurance commissions
- 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.
CSCM’s IARs may accept compensation from the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.p. 7
- 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 anyone at the firm earns a commission on insurance recommended to you, and whether it lowers your fee.
If it uses an affiliated broker-dealer, does it explain what that means for you?
An affiliated broker-dealer
- 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.
CSCM is also a registered broker/dealer with the Financial Industry Regulatory Authority (FINRA).p. 13
- 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 your trades or products go through a company the firm owns or is tied to, and what that costs.
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.
We may, from time to time, make cash payment to introducing broker-dealers, investment advisory firms or qualified solicitors for client referralsp. 17
- 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 anyone was paid to refer you to the firm, and whether that affects what you pay.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation75/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
The practice of receiving commissions and compensation for the purchase and sale of securities and other investment products, presents a conflict of interest and may give CSCM an incentive to recommend investment products based on the compensation received, rather than on a client’s needs.p. 7
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
The practice of receiving commissions and compensation for the purchase and sale of securities and other investment products, presents a conflict of interest and may give CSCM an incentive to recommend investment products based on the compensation received, rather than on a client’s needs.p. 7
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?CoveredItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
We will not reduce your advisory fees to offset any commissions or markups received by us.p. 8
Do they get free research or services from brokers, and does it affect you?Brochure Soft DollarsNot applicable
Not applicable: the brochure describes no research or services from brokers
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
16 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Benjamin Robert Young | 4461674 | — | — |
| Michael Alan Horton | 1041106 | — | — |
| Sandra Kay Stump | 1219774 | — | — |
| Terry Owen Everson | 1769354 | — | — |
| Robert Philip Dorweiler | 867654 | — | — |
| Jeffrey Paul Goble | 2330167 | — | — |
| Jeremy Thomas Dunning | 7358994 | — | — |
| Justin Bryce Lawhon | 7971023 | — | — |
| John Connor Stepp | 7138010 | — | — |
| Emma J Ludgate | 5483738 | — | — |
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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.
What does dual registration mean for me?
It means your advisor can act as a fiduciary (putting your interests first) for some services and as a broker (suitability standard) for others. The key question to ask: 'For this specific recommendation, are you acting as my fiduciary?' Get the answer in writing.
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.
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Last scored: · Score version: 3.15 · CRD #155291