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Is Citizens Private Wealth a Fiduciary? What Its Own Form CRS Says (2026)

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Updated September 22, 2026. Quick answer: Yes, on every account. Citizens Private Wealth is registered with the SEC only as an investment adviser (it is not a broker-dealer), so the Investment Advisers Act of 1940 requires it to act as your fiduciary. Its own Form CRS states: “When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.”

How it’s registered

From Form CRS: Client Relationship Summary: Citizens Private Wealth (March 31, 2026): “Citizens Private Wealth, LLC (f/k/a Clarfeld Financial Advisors, LLC) is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser.”

The CRS discloses the firm is a wholly-owned subsidiary of Citizens Bank, N.A. and affiliated with Citizens Securities, Inc. (a separate SEC-registered broker-dealer/IA). Per the bucketing rule this affiliated-commission relationship does not make the cited CRD itself a dual registrant.

The standard of conduct, in its own words

“When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours.”

On commissions: “Some of our financial professionals are compensated on a salary basis, whereas others receive a percentage of the Advisory Fees you pay us. Certain of our financial professionals, depending upon their individual professional ability, receive a performance bonus at year end.”

Fiduciary status by capacity

CapacityRegistrationStandard you’re owedCan earn commissionsSource
As your investment adviserSEC-registered investment adviserFiduciary duty (Investment Advisers Act of 1940)No (asset-based advisory fee: $7,500 a year, 1.50% on a $500,000 account)Form CRS: Client Relationship Summary: Citizens Private Wealth, March 31, 2026

What this means for what you pay

Fiduciary status is one input, not the whole picture. Citizens Private Wealth discloses a published fee that runs $7,500 a year on a $500,000 account; see the full dollar breakdown from Citizens Private Wealth’s own fee disclosure before deciding whether the standard of conduct here changes your answer.

If the answer above changes your mind about staying, read the general mechanics of switching financial advisors, or use a dated termination letter once you decide.

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Sources

Methodology. This page was built September 22, 2026, quoting directly from Citizens Private Wealth’s own current Form CRS, with the source linked above; any distinction we could not independently confirm this session is named as an honest gap rather than presented as verified. Nothing here is personalized financial, tax, legal, or investment advice, and it is not a substitute for reading the firm’s own Form CRS. See our Editorial Policy, Corrections, Affiliate Disclosure, and Disclaimer.

What does it actually take to open an account? See Citizens Private Wealth’s minimum investment, quoted verbatim from its own Form ADV Part 2A / wrap-fee brochure.

Weighing whether to move ahead? Read the full Citizens Private Wealth review, including its fiduciary status and what it costs to leave.

Comparing Citizens Private Wealth against other options? See Citizens Private Wealth alternatives, including a flat-fee route and a robo/hybrid, plus a lower-fee full-service firm.

Already with Citizens Private Wealth and weighing a move? How to leave Citizens Private Wealth covers what it costs to transfer out.