Fairbanks Capital Management is a investment adviser based in Rancho Santa Fe, CA, that holds a 96.9/100 Fidelon TransparencyScore (96th percentile among SEC-registered advisers), with 3 registered advisors. Score based on public SEC and FINRA filings.
Fairbanks Capital Management
Fairbanks Capital Management, INC. · CRD #107650
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Fairbanks Capital Management, INC. is an SEC-registered investment adviser in Rancho Santa Fe, CA. It used to be called Quality Growth Management, INC. and Kingsbury Financial, LLC. It has 3 registered advisors. It manages $210.6 million across 234 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
462nd of 10,815
SEC-registered advisers
Top 4%
64th of 1,277
SEC-registered advisers in CA
Top 5%
1st of 6
SEC-registered advisers in Rancho santa fe, CA
#1 ranked
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
What you’d pay
Your balance falls in the All accounts band, charged at up to 1.70% on the full amount. The brochure files this rate as a maximum, not a price. What you actually pay is set in your agreement and may be lower.
This fee is negotiable
“Not all clients will be charged as described and in certain circumstances fees are subject to negotiation.”
From their Form ADV Part 2A. Most investors never ask.
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 | Up to 1.70% |
Billed monthly 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
- 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 under our management, the more you will pay us in fees and therefore we may have an incentive to encourage you to increase those assets.”
“We are incentivized to have you invest in those investments since we may receive added compensation in the form of investment management and/or incentive fees from those investments.”
Source: the firm’s own Form CRS — 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.
91/100
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.
70/100
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
- 93/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
- 61/100
- Can you tell what you would pay?
- What you pay
- 100/100
- Is it written in plain English?
- Plain language
- 96/100
This firm's Form CRS averages 88 out of 100 and adds 6.88 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.
Generally, we charge up to 1.75% per year, assessed monthly, if total managed relationship assets are under $500,000; lower fees shall apply to higher amounts of relationship assets.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.
Not all clients will be charged as described and in certain circumstances fees are subject to negotiation.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.
We generally deduct fees from accounts either monthly in arrears or quarterly in the middle of the quarter.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.
Generally, we charge up to 1.75% per year, assessed monthly, if total managed relationship assets are under $500,000; lower fees shall apply to higher amounts of relationship assets.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.
Clients pay all brokerage commissions, stock transfer fees, margin charges, foreign exchange and settlement fees, and/or other charges incurred in connection with transactions in accounts, from the assets in the account.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.
We will refund any prepaid unearned management fees based on the effective date of termination.p. 7
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity70/100
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.
The brochure answers every one of these.
The brochure states the firm has no conflicts of this kind, and its Form ADV Part 1 agrees.
- Does the brochure say the firm has no conflicts of this kind?CoveredItems 10/11/12.B/14 + Part 1A
A clear statement that the firm earns nothing from commissions, perks or referrals is the simplest answer there is.
FCM does not compensate non-advisory personnel (solicitors) for client referrals.p. 20
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 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
3 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Steven Lee Re | 822483 | — | — |
| Chris Hoon Cho | 4868921 | — | — |
| Raphael Biderman | 7033275 | — | — |
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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 #107650