Cgn Advisors is a investment adviser based in Manhattan, KS, that holds a 85.5/100 Fidelon TransparencyScore (49th percentile among SEC-registered advisers), with 37 registered advisors. Score based on public SEC and FINRA filings.
Cgn Advisors
Cgn Advisors, LLC · CRD #159359
A registered investment adviser held to a fiduciary standard.
Fidelon Fact Sheet
Cgn Advisors, LLC is an SEC-registered investment adviser in Manhattan, KS. It used to be called Jeffrey A. Drayton Financial Planning & Wealth Management and Argonaut Financial Planning & Investment Management. It has 37 registered advisors. It manages $1.6 billion across 4,023 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it does not report earning commissions. Its services include financial planning, portfolio management, educational seminars and investment newsletters. It reports that it can hold or access client money, which the SEC requires firms to disclose. Its filing reports disclosures.
Peer Context
5,544th of 10,815
SEC-registered advisers
Bottom 49%
50th of 119
SEC-registered advisers in KS
Top 42%
2nd of 2
SEC-registered advisers in Manhattan, KS
Bottom 1%
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
Blended across 1 tiers, from $500,000 - $750,000.
This fee is negotiable
“Our published fees are negotiable;”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Any transactional or custodial fees assessed by your selected service providers, individual retirement account fees or qualified retirement plan account termination fees
- • Pension consulting fees up to 1% of plan assets plus up to $2,000 annually
- • Hourly fees up to $600 for Financial Planner and up to $150 for Paraplanner
- • Fixed fees ranging from $300 to $8,000 annually for projects or retainers
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 |
|---|---|
| $0 - $500,000 | 1.00% |
| $500,000 - $750,000 | 0.75% |
Billed monthly or quarterly, in arrears
Extracted from Form ADV Part 2A brochure
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
- Transparent fee structure — charges advisory fees, no commissions
- TransparencyScore in the top 51% of SEC-registered advisers
Things You Should Know
- Has regulatory disclosures on file — count not available yet
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 amount of assets in your account affects our advisory fee; the more assets you have in your advisory account, the more you will pay us and thus we have an incentive to increase those assets in order to increase our fee.”
Source: the firm’s own Form CRS — quoted directly
Regulatory Track Record
On file
Disclosures
Count not available
—
Total Fines
Not available
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
98/100
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.
83/100
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.
66/100
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
- 98/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 65/100
- Can you tell what you would pay?
- What you pay
- 69/100
- Is it written in plain English?
- Plain language
- 96/100
This firm's Form CRS averages 82 out of 100. It adds 5.5 points once the firm's filings and record score 90 on their own; they score 85.48 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.
Fees for asset management programs vary and do not exceed 1.00%.p. 12
- 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.
Our published fees are negotiable;p. 11
- 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.
Your written authorization is required in order for the custodian of record to deduct advisory fees from your account.p. 13
- 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 will be billed monthly or quarterly, in arrears, and will be determined by the complexity of the portfolio strategy and investment vehicles selected.p. 12
- 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.
Any transactional or custodial fees assessed by your selected service providers, individual retirement account fees or qualified retirement plan account termination fees will be borne by you and are as provided in the current, separate fee schedule of the selected service provider.p. 13
- 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.
In the case of most of our prepaid fees, we will promptly return the unearned amount upon receipt of written termination notice.p. 14
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity61/100
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 availability of these services from a custodian benefits our firm because it does not have to produce or purchase them as long as firm clients maintain assets in accounts at the custodian.p. 29
- 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.
Therefore, there is an appearance of a conflict of interest since our firm may have an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving favorable trade execution.p. 29
- 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.
- Hedged wording
Strategies involving Core + Satellite investing may have the potential to be affected by “active risk” or “tracking error risk,” which might be defined as a deviation from the stated benchmark.p. 18
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 Dollars82/100
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.
These benefits may include the following products and services (provided either without cost or at a discount): • receipt of duplicate client statements and confirmations • research related products and tools • access to trading desks serving our clients • access to block trading servicesp. 29
- 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 a custodian benefits our firm because it does not have to produce or purchase them as long as firm clients maintain assets in accounts at the custodian.p. 29
- 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.
Therefore, there is an appearance of a conflict of interest since our firm may have an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than your interest in receiving favorable trade execution.p. 29
- 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.
certain research and other previously referenced services may qualify as "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934.p. 29
- 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
37 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| John Joseph Flanagan | 2538635 | — | — |
| Carrie Nola Kulig | 2871845 | — | — |
| Jonathan Bernstein | 5221328 | — | — |
| Jason Lee Williams | 6544349 | — | — |
| Sheila Rae Stowers | 3005789 | — | — |
| Jeffrey Patrick Euting | 3242133 | — | — |
| Daniel Edward King | 4054679 | — | — |
| Diane Marie Pearson | 1962827 | — | — |
| David John Walz | 2366221 | — | — |
| Kristin Lynn Rogers | 3098023 | — | — |
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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 #159359