Capital Management Group

High Flows Capital Group LLC is an independent investment adviser that delivers portfolio management and financial advice through its San Diego Managed Asset Program (SD MAP), a wrap‑fee asset‑allocation program. The firm’s brochure describes clients as including high‑net‑worth individuals, trusts, estates, charitable organizations, retirement plans, institutions and small‑to‑mid‑sized businesses, and it does not present a focus on serving non‑HNW retail individuals.

Investment management is provided via diversified model portfolios made up primarily of no‑load mutual funds, ETFs and occasional 529 plans, with an investment philosophy citing Modern Portfolio Theory, the Fama‑French three‑factor model and behavioral finance; clients can work directly with an advisor or use a risk‑based GPS client portal to select a model. The SD MAP is presented as a wrap fee that covers custody and execution through Interactive Brokers LLC, and the brochure discloses the possibility of performance‑based fees for “qualified clients” (with a high‑water‑mark and an example up to 30% of profits) while another section of the filing also states the firm will not accept performance‑based fees.

What is uncommon for a solo independent adviser is that the firm sponsors and manages its own wrap program and also offers institutional/plan services (including designated investment alternatives, QDIAs and model management) overseen by an Investment Committee composed of the firm’s principals. The brochure also highlights operational and conflict‑of‑interest items that distinguish the practice: reliance on Interactive Brokers’ institutional program and related economic benefits, stated incentives around IRA rollovers and 529 recommendations, and the principal’s separate insurance licensing.