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FORM ADV PART 2A APPENDIX (WRAP PROGRAM BROCHURE)
Rbf Wealth Advisors (CRD 104771), brochure dated April 20, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Item 1 – Cover Page
Form ADV Part 2A Appendix 1 -
Investment Management Wrap Fee
Program Brochure
Roman, Butler, Fullerton & Co.
d/b/a “RBF Wealth Advisors”
680 Craig Road, Suite 201
St. Louis, MO 63141
www.rbfadvisors.net
314-997-1652
April 13, 2026
This Investment Management Wrap Fee Program Brochure provides information about the
qualifications and business practices of RBF Wealth Advisors (RBF). If you have any
questions about the contents of this Brochure, please contact us at 314-997-1652. The
information in this Brochure has not been approved or verified by the United States
Securities and Exchange Commission or any state securities authority.
RBF is a registered investment adviser. Registration as an investment adviser does not
imply any level of skill or training. The oral and written communications of an adviser
provide you with information from which you can determine whether to hire or retain an
adviser.
Additional information about RBF is also available via the SEC’s web site
www.adviserinfo.sec.gov.
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Item 2 – Material Changes
This Brochure Appendix, dated April 13, 2026, is the annual amendment to RBF Wealth
Advisors’ previously published annual update Brochure Appendix.
Since the last filing of the firm’s Brochure on February 24, 2026, we have updated the
Brochure to reflect the purchase of the firm by Paul T. Fullerton, Sr. from Anthony E
Kalinowski on March 2, 2026, and to reflect Mr. Fullerton becoming President and Chief
Compliance Officer of the firm at that time. We have also made other minor updates, but no
other material changes were made.
Pursuant to SEC Rules, we will deliver to you a summary of any materials changes to this
and subsequent Brochures within 120 days of the close of our fiscal year. We may further
provide other ongoing disclosure information about material changes as necessary. All
such information will be provided to you free of charge.
Currently, our Brochures may be requested by contacting us at (314) 997-1652 or may be
viewed on our website at www.rbfadvisors.net.
Additional information about RBF is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons
affiliated with RBF who are registered as investment adviser representatives of the firm.
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Item 3 - Table of Contents
Item 1 – Cover Page .................................................................................................................................................. i
Item 2 – Material Changes .................................................................................................................................... ii
Item 3 - Table of Contents .................................................................................................................................... iii
Item 4 – Services, Fees and Compensation ................................................................................................... 1
Item 5 – Account Requirements and Types of Clients .............................................................................. 2
Item 6 – Portfolio Manager Selection and Evaluation .............................................................................. 3
Item 7 – Client Information Provided to Portfolio Managers ................................................................ 4
Item 8 – Client Contact with Portfolio Managers ........................................................................................ 4
Item 9 – Additional Information ........................................................................................................................ 4
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Item 4 – Services, Fees and Compensation
Investment Management Services
RBF provides discretionary investment management services through this Wrap Fee
Program whereby participants receive portfolio management, custodial services, trading,
and reporting, for one all inclusive fee.
RBF begins by assisting a client in assessing their current financial situation, financial goals
and attitudes towards risk, and will then recommend an appropriate asset allocation based
on that information. After an investment plan is presented to the client, individual
portfolios are managed by the advisory representative on a discretionary basis.
Portfolios will be invested in a variety of investment classes, including stocks, bonds,
mutual funds, and exchange traded funds, among others. Changes to a client's portfolio will
be made as necessary based on market, economic, or political circumstances and the
individual characteristics of the securities in the portfolio.
RBF currently offers the following Wrap Fee program:
Standard Wrap Account
Our standard wrap account (held at Fidelity IWS) is a no transaction fee platform that
offers complete product availability and no minimum account value.
Portfolio Value
Maximum Fee
$0 - $250,000
2.75%
$250,001 - $750,000
2.25%
$750,001 - $2,000,000
1.75%
$2,000,001 +
1.50%
Investment Management Fee Terms
Fees are payable in advance, generally on a quarterly basis, and are typically deducted
directly from the client’s account. However, in some limited instances, clients may be billed
directly. Fees are calculated based on the beginning balance of the account(s) (i.e. based on
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the ending balance of the prior period) and are charged shortly after the beginning of the
applicable billing period.
Fees for new accounts opened during a billing period will be billed in arrears for that initial
billing period based on the amount of the initial deposit and will be prorated for the
number of days assets will be under management during the initial billing period.
Advisory agreements may be terminated by either party at any time by written notice.
Upon termination, any unearned prepaid fees will be refunded.
Fees for withdrawals out of an account of $100,000 or more will be prorated and refunded
based on the number of days assets were under management. Fees for deposits into an
account of $100,000 or more will be prorated and charged based on the number of days
assets will be under management.
The fees listed above, which are negotiable, include portfolio management, custodial
services, trading services and reporting. Fees are separate from charges that may be
imposed by third parties, such as mutual fund expense charges, etc. Services purchased
through this program may cost clients more or less than purchasing similar services from
the firm on a stand-alone basis depending on the volume of activity since various costs are
paid on behalf of the client through the Wrap Program. Clients should also note that
because RBF pays transaction costs on a client’s behalf in the Wrap Program, a conflict of
interest exists in that RBF would pay less in trading costs if the firm were to trade less
frequently. However, we feel that the cost of trading is not material enough to influence
our investment recommendations, and we feel that the harm to our clients and our
reputation far outweighs any potential cost savings. It is our policy to always act in the
best interests of our clients.
Item 5 – Account Requirements and Types of Clients
RBF provides personalized fee-based investment management under this Wrap Program to
individuals, profit sharing plans, trusts, charitable organizations and businesses.
The firm has not set a minimum investment amount to open a Wrap Program account;
however we reserve the right to decline certain accounts if we feel a relationship would not
be beneficial or economical for the client.
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Item 6 – Portfolio Manager Selection and Evaluation
RBF functions not only as the Wrap Program sponsor but also as the portfolio manager. No
outside portfolio managers are used.
Since RBF functions as the Wrap Program’s sole portfolio manager, a conflict of interest
may exist because RBF pays certain client trading costs from the fee RBF charges. This may
give us an incentive to make recommendations that cost us less, or to recommend fewer
trades, regardless of the benefit to our client. However, we feel that the cost of trading is
not material enough to influence our investment recommendations, and we feel that the
harm to our clients and our reputation far outweighs any potential cost savings. It is our
policy to always act in the best interests of our clients.
Advisory Business
In addition to providing investment management services under this Wrap Program, RBF
also provides financial planning and consulting services on a stand-alone basis (See Form
ADV Part 2A Brochure). These financial planning and consulting services include strategies
for education funding, retirement planning, and estate planning, as well as general financial
planning and consultation services.
Whether services are provided through this Wrap Program or on a stand-alone basis,
services are tailored to the individual needs of clients. Clients can also impose restrictions
on investing in certain securities or types of securities.
Performance Based Fees and Side by Side Management
RBF does not charge performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) under its Wrap Program. However, in limited
instances, RBF may offer such an arrangement to qualified clients, and the terms of which
are negotiable and may vary. All such arrangements are documented in writing in the
client agreement and are made consistent with securities laws. See Part 2A Brochure for
additional details.
Methods of Analysis, Investment Strategies, and Risk of Loss
RBF’s general investment strategy, consistent with the tenets of modern portfolio theory, is
to attempt to reduce risk and volatility by building diversified portfolios.
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To implement this strategy, we use various forms of analysis, which may include
fundamental and/or technical analysis, to screen various investment options for use in
client portfolios. When creating portfolios, we will allocate the client's assets among
various investments taking into consideration the overall management style selected by
the client and the platform where the assets are held. We feel our independent structure
gives us the objectivity and client-focus to consider our clients’ needs above all other
interests.
Clients should however be aware that investing in securities involves risk of loss that they
should be prepared to bear. These risks include market risk, interest rate risk, currency
risk, and political risk, among others. No investment or investment strategy can assure a
profit or avoid a loss.
Voting Client Securities
RBF does not vote proxies on behalf of clients.
Item 7 – Client Information Provided to Portfolio Managers
As the Wrap Program’s sole portfolio manager, RBF does not communicate client
information to outside portfolio managers.
Item 8 – Client Contact with Portfolio Managers
RBF does not use outside portfolio managers, and consequently has no restrictions related
to client contact with account managers.
Item 9 – Additional Information
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to the evaluation of the firm or the
integrity of its management. RBF is currently not subject to, nor has ever been subject to,
any legal or disciplinary events of a material nature.
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Other Financial Industry Activities and Affiliations
Some affiliated persons of RBF may also be registered representatives of Private Client
Services, LLC (PCS), a securities broker-dealer and member of the Financial Industry
Regulatory Authority, Inc. (FINRA). As such, these individuals, in their separate capacities
as registered representatives, will be able to effect securities transactions and will receive
separate customary compensation for effecting any securities transactions. They may also
from time to time receive 12b-1 distribution fees from investment companies in connection
with the placement of client funds into investment companies. They do not however
receive these fees for investments placed in an account which RBF manages.
Some associated persons of RBF are also licensed insurance agents. As such, these
individuals will be able to receive separate customary commission compensation resulting
from implementing insurance product transactions on behalf of advisory clients outside of
the Wrap Program.
While these individuals endeavor at all times to put the interest of the clients first as part of
RBF's fiduciary duty, clients should be aware that the receipt of additional compensation
creates a potential conflict of interest and may affect the judgment of these individuals
when making recommendations. However, our clients are under no obligation to purchase
products recommended by our associated persons or to purchase products through our
associated persons. We believe that our recommendations are in the best interests of our
clients, and are consistent with our clients’ needs.
These activities represent relatively little of each individual’s time.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
RBF has adopted a Code of Ethics expressing the firm's commitment to ethical conduct.
RBF's Code of Ethics describes the firm's fiduciary duties and responsibilities to clients, and
details practices for reviewing the personal securities transactions of supervised persons
with access to client information. The Code also requires compliance with applicable
securities laws, addresses insider trading, and details possible disciplinary measures for
violations. RBF will provide a complete copy of its Code of Ethics to any client upon
request to the Chief Compliance Officer.
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Trading Conflicts of Interest
Individuals associated with RBF are permitted to buy or sell securities for their personal
accounts identical to or different than those recommended to clients. However, no person
employed by RBF is allowed to favor his or her own interest over that of a client or make
personal investment decisions based on the investment decisions of advisory clients.
In order to address potential conflicts of interest, RBF requires that associated persons
with access to advisory recommendations provide annual securities holdings reports and
quarterly transaction reports to the firm's Chief Compliance Officer. RBF also requires
prior approval from the Chief Compliance Officer for investing in any IPOs or private
placements (limited offerings).
Review of Accounts
Investment management accounts are supervised by the investment advisors of RBF. In
addition to ongoing supervision, accounts are generally reviewed more formally on a
quarterly basis. The quarterly review generally includes assessing client goals and
objectives, evaluating the employed strategy, monitoring the portfolio, and addressing the
need to rebalance. Where applicable, RBF will periodically, and at least annually, review
client's investment policy and risk profile, and discuss the re-balancing of each client's
accounts to the extent appropriate.
Additional account reviews may be triggered by a specific client request, by a change in
client goals or objectives, by an imbalance in a portfolio asset allocation, or by market or
economic conditions. All ongoing clients are advised that it remains their responsibility to
advise RBF of any changes in their investment objectives and/or financial situation.
Regular Reports Provided to Clients
Investment management clients are provided with account statements from their
custodian on at least a quarterly basis which list account holdings and transactions for the
period. Investment management clients may also be provided with written performance
reports from RBF periodically that detail current market value, performance relative to
market benchmarks, and overall portfolio allocation. We urge our clients to carefully
review custodial statements they receive. Custodial statements are the official record of
results and transactions and supersede all other kinds of reports and correspondence
provided by us.
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Client Referrals and Other Compensation
RBF may pay individuals or other professional entities to market or refer clients to us.
Such arrangements are structured to be in compliance with applicable securities laws.
Each client is provided disclosures prior to and/or at the time of entering into any advisory
contract which describe the compensation arrangement where applicable. Advisory fees
charged to clients are not increased as a result of marketing or referral arrangements.
Additionally, RBF may receive economic benefits from custodians in the form of support
products and services that are made available to us. These products and services, how they
benefit us, and the related conflicts of interest are described in Item 12 of our Brochure.
The availability to us of these products and services however is not based on us giving
particular investment advice, such as buying particular securities for our clients.
Furthermore, RBF representatives do not receive sales awards or other such prizes in
connection with selling particular securities or giving particular advice.
Financial Information
Registered investment advisers are required in some cases to provide certain financial
information and or disclosures about their financial condition. For example, if the firm
requires prepayment of fees for six months in advance or has custody of client funds it is
required to disclose any condition that is reasonably likely to impair its ability to meets it
contractual commitments to its clients.
RBF has no financial or operating conditions which trigger such additional reporting
requirements.
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