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RJ PATTERSON GROUP ADV PART 2A & 2B
Rj Patterson Group (CRD 281752), brochure dated October 9, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
TEM 1: COVER PAGE
RJ Patterson Capital Investment Group, Inc.
Dba RJ Patterson Group
402 West Broadway
Suite 2600
San Diego, CA 92101
Tel.: (619) 331-4133
Fax: (619) 684-3911
www.rjpattersongroup.com
FIRM BROCHURE
Part 2A of Form ADV
October 9, 2026
the contents of
this brochure, please contact us at
Part 2A of Form ADV (“Brochure”) provides information about the qualifications and business
practices of RJ Patterson Capital Investment Group, Inc. CRD #281752. If you have any questions
about
(619) 331-4133 or
info@RJPattersonGroup.com. The information in this Brochure has not been approved or verified
by the United States Securities and Exchange Commission (the “SEC”) or by any state securities
authority.
RJ Patterson Capital Investment Group, Inc. is a registered investment adviser with the U.S.
Securities and Exchange Commission; however, such registration does not imply a certain level of
skill or training and no inference to the contrary should be made. Additional information about RJ
Patterson Capital Investment Group, Inc., and our investment adviser representatives is also
available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 2: MATERIAL CHANGES
The purpose of this page is to inform you of material changes to our brochure. If you are receiving
this brochure for the first time, this section may not be relevant to you.
RJ Patterson Capital Investment Group, Inc. (“RJP”) reviews and updates our brochure at least
annually to confirm that it remains current. We have not made any material changes to our
brochure since the previous annual update, dated February 11, 2026.
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ITEM 3: TABLE OF CONTENTS
TEM 1: COVER PAGE ...........................................................................................................................1
ITEM 2: MATERIAL CHANGES ..............................................................................................................2
ITEM 3: TABLE OF CONTENTS..............................................................................................................3
ITEM 4: ADVISORY BUSINESS ..............................................................................................................5
Description of Advisory Firm ..................................................................................................................... 5
Advisory Services Offered ......................................................................................................................... 6
Participation in Wrap Program ................................................................................................................. 9
Tailored Services and Client Imposed Restrictions ................................................................................... 9
Assets Under Management..................................................................................................................... 10
ITEM 5: FEES AND COMPENSATION .................................................................................................. 10
Fee Schedule ........................................................................................................................................... 10
Billing Method ......................................................................................................................................... 11
Other Fees and Expenses ........................................................................................................................ 12
Termination ............................................................................................................................................. 12
Other Compensation ............................................................................................................................... 13
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................ 13
ITEM 7: TYPES OF CLIENTS ................................................................................................................ 13
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................. 13
Methods of Analysis and Investment Strategies .................................................................................... 13
Specific Investment Strategies ................................................................................................................ 14
Risks......................................................................................................................................................... 15
ITEM 9: DISCIPLINARY INFORMATION ............................................................................................... 21
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................... 21
Representative of Broker-Dealer and Licensed Insurance Agent ........................................................... 21
Tax Planning and Return Preparation ..................................................................................................... 21
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ......................................................................................................................................... 22
ITEM 12: BROKERAGE PRACTICES ..................................................................................................... 22
The Custodian and Brokers We Use ........................................................................................................ 22
Aggregation and Allocation of Transactions ........................................................................................... 25
ITEM 13: REVIEW OF ACCOUNTS ...................................................................................................... 26
Account Reviews ..................................................................................................................................... 26
Account Reporting .................................................................................................................................. 26
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ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................ 26
Schwab Support Products and Services .................................................................................................. 26
Client Referral Fees ................................................................................................................................. 26
Outside Referrals .................................................................................................................................... 27
Affiliate Referrals and Compensation ..................................................................................................... 28
ITEM 15: CUSTODY ........................................................................................................................... 28
ITEM 16: INVESTMENT DISCRETION .................................................................................................. 29
ITEM 17: VOTING CLIENT SECURITIES ................................................................................................ 29
Proxy Voting ............................................................................................................................................ 29
Class Actions and Similar Matters ........................................................................................................... 30
ITEM 18: FINANCIAL INFORMATION ................................................................................................. 30
Form ADV, Part 2B Brochure Supplement....................................................................................... i
ITEM 1 - COVER PAGE ................................................................................................................................ i
Robert J. Patterson ............................................................................................................................ ii
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ....................................................... ii
ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iii
ITEM 4 - OTHER BUSINESS ACTIVITIES ..................................................................................................... iii
ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iii
ITEM 6 - SUPERVISION ............................................................................................................................. iii
Kameron S. Barzegar ......................................................................................................................... iv
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................... iv
ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iv
ITEM 4 - OTHER BUSINESS ACTIVITIES ..................................................................................................... iv
ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iv
ITEM 6 - SUPERVISION ............................................................................................................................. iv
Malek Hassan .................................................................................................................................... v
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ....................................................... v
ITEM 3 - DISCIPLINARY INFORMATION ..................................................................................................... v
ITEM 4 - OTHER BUSINESS ACTIVITIES ...................................................................................................... v
ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... v
ITEM 6 - SUPERVISION .............................................................................................................................. v
Privacy Information .......................................................................................................................... A
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ITEM 4: ADVISORY BUSINESS
Description of Advisory Firm
RJ Patterson Capital Investment Group, Inc. (“RJP,” “we,” “our,” or “us”) is a privately owned
corporation headquartered in San Diego, California. RJP is registered as an investment adviser
with the U.S. Securities and Exchange Commission. Robert J. Patterson, Chief Executive
Officer, founded RJP in 2015 and remains the principal owner of the firm.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty
carries with it an obligation to act in the best interest of our clients pursuant to a relationship of
trust and confidence. It encompasses a duty of care and a duty of loyalty.
Duty of Care
The duty of care includes, among other things:
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of the
client’s objectives is a critical component of the duty of care. Providing suitable advice includes
making a reasonable inquiry into the client’s financial situation, investment experience, and
financial goals and then updating this information as necessary throughout the course of the
relationship to reflect the client’s changing objectives over time and adjusting the advice we
provide to reflect any changed circumstances.
When RJP has the responsibility to select broker-dealers to execute client trades in discretionary
accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the
most favorable under the circumstances. In doing so, we consider the full range and quality of a
broker’s services and so the determinative factor is not necessarily the lowest possible
commission cost but whether the transaction represents the best qualitative execution. Moreover,
we periodically and systematically evaluate the execution we receive on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in
the best interest of the client, taking into account the scope of the agreed relationship. This scope
is indicated by the duration and nature of the services as outlined in each client’s advisory
arrangement and extends to all personalized advice provided to clients.
Duty of Loyalty
RJP adheres to a duty of loyalty where we seek to serve the best interests of our clients and never
subordinate the interests of our clients to our own. Simply put, RJP cannot place our own
interests ahead of the interests of our clients. In observance of this duty, we must make full and
fair disclosure to clients of all material facts relating to the advisory relationship. Further, we
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also seek to eliminate or at least expose through full and fair disclosure all conflicts of interest
which might incline RJP, consciously or unconsciously, to render advice that is not disinterested.
We believe that in order for disclosure to be full and fair, it should be sufficiently specific so that
each client is able to understand the material fact or conflict of interest and make an informed
decision whether to provide consent. Consequently, we provide this ADV 2A brochure to all
prospective clients at or before entering into a contract so that they can use the information
within to decide whether or not to enter into an advisory relationship.
Advisory Services Offered
Investment Management Services
RJP provides continuous and regular investment supervisory services on a discretionary basis.
Robert J. Patterson works with clients and has the ongoing responsibility to select investments
based upon the objectives of the client, as to specific securities that RJP purchases and sells in
client accounts.
RJP primarily utilizes the following investment types when making investment purchases in
client accounts:
1. Exchange traded funds (ETFs)
2. Mutual funds
3. Equity securities, such as stocks and foreign securities listed on US exchanges (ADRs)
and/or foreign exchanges (ordinaries)
4. Fixed income securities, including corporate bonds
5. Cash and cash equivalents such as money market funds, floating rate funds, cash sweeps,
and short-term U.S. treasuries
RJP may also occasionally offer advice regarding/utilize additional types of investments if we
believe they are appropriate to address the individual needs, goals, and objectives of the client or
in response to client inquiry. RJP may offer investment advice on any investment held by the
client at the start of the advisory relationship. We describe the material investment risks for many
of the securities that we utilize/recommend in Item 8 below. We discuss our discretionary
authority below under Item 16 - Investment Discretion. We describe the fees charged for
investment management services below under Item 5 - Fees and Compensation.
Advisory Agreements
Prior to engaging RJP to provide investment advisory services, the client will be required to enter
into one or more written agreements setting forth the terms and conditions under which we shall
render services. RJP will provide this Form ADV Part 2A, and one or more supplements, to each
client or prospective client at or before the time the client signs the agreement.
Participant Account Management
RJP utilizes the Pontera Order Management System (“Pontera”), a third-party platform, to
facilitate discretionary management of the accounts of retirement plan participants, including but
not limited to 401(k) and defined contribution plan participant accounts (collectively, “held-away
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accounts”). These held-away accounts are not maintained with the custodian(s) we recommend
but rather custodied at an institution selected by the client and/or their employer. Neither RJP nor
Pontera serves as the client’s custodian. A link will be provided to the client allowing them to
connect the held-away account(s) to Pontera’s platform. Once accounts are connected to the
platform, RJP will regularly review the available investment options in these accounts, monitor
them, and rebalance them, though using different tools, as necessary.
Third-Party Investment Management
In providing our discretionary management services, RJP sometimes engages the services of a
third-party investment adviser to manage all or a portion of your assets through a turnkey asset
management program ( “TAMP”). When we do so, you will be provided with a copy of the
outside manager’s current Disclosure Brochure, Privacy Policy, and Form CRS (“Disclosure
Documents”). You should read these documents carefully to be sure you understand the TAMP.
Using information RJP gathers from you, we evaluate your financial situation, investment
objectives, financial goals, tolerance for risk, and investment time horizon. This information
helps us determine whether your participation in the TAMP is appropriate for you, and if so,
allows us to choose what we deem to be an appropriate Investment Strategy for the management
of your assets. Once we choose the Investment Strategy and allocate all or a portion of your
assets to the Investment Strategy, the third-party manager will provide ongoing discretionary
management of your assets according to the mandate of the Investment Strategy.
Outsourced Trading Services
In providing our discretionary management services, RJP sometimes engages the services of
Advyzon Investment Management LLC (“AIM”) as an outsourced agent to provide certain
operational, administrative, and trading functions. In these instances, RJP provides AIM with
asset allocation model portfolios and designates the appropriate model portfolio for each client
account. We will also define the parameters for the supervision of your account, such as the
frequency of rebalancing and allowable drift from asset allocation targets. Once we choose the
model portfolio for your account and define parameters, AIM will provide ongoing supervision
of your account according to the model portfolio and our defined parameters. When utilized, RJP
pays AIM for utilization of AIM’s Outsourced Trading Services; clients are not charged an
additional fee from the customary management fees RJP charges.
When RJP engages the third-party manager to manage your assets and/or in AIM’s case, to serve
as an outsourced agent, as each service is described above, the third-party provider will obtain
access to your confidential information from us and/or from the custodian of your brokerage
account. As stated in RJP’s Privacy Policy, we are authorized to share your personal information
with third parties who need the information for our everyday business purposes. Our agreements
with such entities include provisions requiring the third-party provider to hold your information
in strict confidence, and to maintain reasonable technological protections, precautions, and
safeguards for your information.
Financial Planning and Consultations
RJP provides traditional financial planning and consultation services to individuals, families, and
other clients regarding the management of their financial resources based upon an analysis of
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client’s current situation, goals, and objectives. This planning or consulting may encompass one
or more of the following areas: Investment Planning, Retirement Planning, Estate Planning,
Insurance Analysis and Personal Financial Planning.
For written financial planning engagements, RJP provides clients with a written summary of
their financial situation, observations, and recommendations. For financial consulting
engagements, RJP usually does not provide clients with a written summary of our observations
and recommendations as the process is less formal than our planning service. Plans or
consultations are typically completed within six (6) months of the client signing a written
agreement, assuming that all the information and documents requested are provided promptly.
Clients that engage us for financial planning services are customarily introduced to our
investment management services as part of the planning process. Clients that choose to engage
us for investment management services pay advisory fees that are separate from the fees paid for
financial planning services. Financial Consulting Services are typically performed at no
additional charge to Investment Management Service clients as an ancillary service to the
portfolio management they receive.
General Financial Planning information
Each of RJP’s planning services usually include general recommendations for a course of
activity or specific actions to be taken by the clients. For example, recommendations may be
made that the clients begin or revise investment programs, obtain, or revise insurance coverage,
commence or alter retirement savings, or establish education or charitable giving programs. It
should also be noted that RJP customarily refers clients to an accountant, attorney, or other
specialist, as necessary for non-advisory related services. See Item 14 – Client Referrals for
more information regarding the professionals we refer.
Our financial planning services do not include preparation of any kind of income tax, gift, or
estate tax returns nor preparation of any legal documents, including wills or trusts.
Emerging Professional Program
RJP also offers a monthly subscription-based planning service utilizing financial planning
software administered by RightCapital. Areas covered typically include but are not limited to
analysis of the client’s investments, cash flow, social security, real estate, life insurance, and
estate planning needs. RJP typically interfaces with Emerging Professional Program clients on a
monthly basis but may meet less frequently as mutually agreed to by the client and RJP. Clients
may also choose to utilize the software on their own. Included in the service are tasks/action
items delivered through a secure client portal, which subscribers then complete with our
assistance in an effort to fulfill their planning-related goals.
Clients that engage us through the Emerging Professional Program are generally introduced to
our investment management services. Clients that also choose to engage us for investment
management services pay advisory fees that are separate from the monthly fees paid for
Emerging Professional Program services. However, clients that engage RJP separately for
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investment management services on portfolios of $500,000 or more will have their monthly
Emerging Professional Program fee waived.
Participation in Wrap Program
We do not provide portfolio management services to a wrap fee program.
Limitations on Investments
In some circumstances, our advice may be limited to certain types of securities.
No Load Mutual Funds
RJP generally limits mutual fund selections to no load funds or load-waived equivalents.
Limitation by Custodian
There may also be limitations on the mutual funds that we recommend. All clients establish
brokerage accounts with Schwab Advisor Services™, a division of Charles Schwab & Co., Inc.
(“Schwab”), registered broker-dealer, Member SIPC. RJP is limited to the mutual funds
available through Schwab.
Limitation by Client
RJP may also limit advice based on certain client-imposed restrictions. For more
information about the restrictions clients can put on their accounts, see Tailored Services
and Client Imposed Restrictions in this Item below.
Tailored Services and Client Imposed Restrictions
RJP manages client accounts based on the investment strategy the client chooses, as
discussed below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of
Loss. RJP applies the selected strategy for each client, based on the client’s individual
circumstances and financial situation. RJP attempts to control risk and seeks returns consistent
with the client’s guidelines and restrictions. The investment advice we provide is managed based
upon the investment guidelines and restrictions furnished by each client and other important and
necessary information. Clients provide us with information that we use to implement their
chosen investment strategy.
RJP will not assume any responsibility for the accuracy of the information provided by the client.
Under all circumstances, clients are responsible for promptly notifying us in writing of any
material changes to the client’s investment guidelines. In the event that a client notifies us of
changes, we will review such changes and recommend any necessary revisions to the client’s
portfolio.
Clients may also request other restrictions on the account, such as when they need to keep a
minimum level of cash in the account or does not want RJP to buy or sell certain specific
securities or security types in the account. RJP reserves the right not to accept and/or terminate
management of a client’s account if we feel that the client-imposed restrictions would limit or
prevent us from meeting or maintaining the client’s investment strategy.
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Assets Under Management
RJP manages client assets in discretionary accounts on a continuous and regular basis. As of
April 30, 2026, the total amount of assets under our management was $142,396,919.
ITEM 5: FEES AND COMPENSATION
Fee Schedule
Investment Management Services
RJP charges advisory fees for investment management services in accordance with each client’s
advisory agreement. Fees vary with type of investment strategy, the size of the account, the asset
class being managed, and the investment product. The maximum fees charged to an account
under a net fee arrangement are as follows:
Assets Under Management
Up to $5,000,000
$5,000,001 to $8,000,000
$8,000,001 to $10,000,000
Over $10,000,000
Annual Fee Percentage
(paid quarterly)
1.00%
0.90%
0.80%
Negotiable
Once a client’s portfolio reaches a breakpoint, RJP bills all portfolio assets under management at
the lower rate. Advisory fees may be negotiated and therefore can be different from those listed
in the above schedule. RJP aggregates related account balances of clients within the same
household for purposes of achieving the advisory fee breakpoints listed above. We also manage
some family and related accounts at a reduced fee.
Third-Party Investment Management Fees
If we engage a third-party manager to manage all or a portion of your assets, the third-party
manager will receive an annual fee not to exceed 0.35% of your assets under management in the
TAMP, including cash and cash equivalents. This fee is in addition to the investment
management fee charged by RJP.
Financial Planning and Consultations
RJP will provide an estimate of the total fee required at the start of the relationship. The actual
time spent, and therefore the fee, may be lower or higher than the estimated amount. After work
has started, we will notify the client in advance if we anticipate that a flat fee will exceed or fall
short of our original estimate.
Financial Planning
RJP charges on an hourly or flat fee basis for financial planning and consultation services. The
total estimated fee, as well as the ultimate fee that RJP charges you, is based on the scope and
complexity of our engagement with you. Our hourly fees are $250.
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Financial Consultations
As stated above in Item 4 – Advisory Business, Financial Consulting Services are typically
performed at no additional charge to Investment Management Service clients as an ancillary
service to the portfolio management they receive. However, in situations where a client does not
also engage us for Investment Management Services, we will bill on an hourly or fixed fee basis,
according to the terms of Financial Planning Services in this Item above.
Emerging Professional Program
RJP charges $250 per month for our Emerging Professional Program services. This fee is
negotiable at our discretion. As stated above in Item 4 – Advisory Business, Emerging
Professional Program fees are waived for Investment Management Service clients with portfolios
of $500,000 or more managed by RJP under separate engagement.
Billing Method
Investment Management Services
Our fees are calculated as a percentage of assets under management and billed quarterly in
advance based on the ending market value of the client’s portfolio on the last business day of the
calendar quarter. We adjust clients’ fees on a pro-rata basis for withdrawals removed from and
additions made to client accounts during the prior quarter when the total contributions and
withdrawals was $10,000 or more. The formula used for the calculation is as follows: (Total
Assets Under Management at Quarter-End) x (Annual Rate) / 4.
For new client accounts, the first payment is a pro-rata calculation that takes into consideration
the number of days remaining in the quarter and the initial value of the portfolio, including
inflows and outflows during the initial partial quarter. The formula used to calculate the initial
advisory fee would be as follows: (Result of Quarterly Calculation) x (Days Remaining in
Quarter) / (Total Number of Days in Quarter).
Clients authorize their independent custodian to automatically withdraw RJP’s advisory fee from
their account. Typically, the custodian withdraws advisory fees from the client accounts during
the first month of each quarter based on our instruction. All clients receive brokerage statements
from the custodian no less frequently than quarterly. The custodian statement will show the
deduction of our advisory fee. It is the client’s responsibility to verify the accuracy of the fee
calculation. The custodian will not determine whether the fee is properly calculated.
Participant Account Management
RJP’s management fees for held-away accounts managed through Pontera (also see Item 4 –
Advisory Business, above) will be charged to the client either by (1) debiting another client
brokerage account also managed by RJP; or (2) direct invoice. RJP is not affiliated with Pontera
in any way and receives no compensation from them for using their platform; however, RJP pays
a fee to Pontera for use of the service. Clients do not pay an additional fee for use of this service.
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Third-Party Investment Management Fees
TAMP fees for third-party managers are charged using the same method, frequency, and billable
market value as described in this section above under Investment Management Services. Fees for
partial billing periods will be prorated based on the number of days in the billing period that the
account was under the third-party manager’s management. If services are commenced during a
billing cycle, prorated fees for the initial billing period will not generally be collected in advance
but will instead be added to the fee for the first full billing cycle. Upon termination, any
unearned fees paid in advance will be refunded.
Financial Planning and Consultations
Full payment is due and payable at the time the client executes the agreement for fixed fee
arrangements. For hourly payment arrangements, fees billed in arrears as services are rendered.
Emerging Professional Program
RJP generally bills clients enrolled in the Emerging Professional Program through automatic
monthly credit card payments. We will also accept payment by check or fee debit of the client’s
brokerage account held at a qualified custodian.
Other Fees and Expenses
Clients should understand that the advisory fees described in the sections above do not include
certain charges imposed by third parties such as custodial fees and expenses. Client assets may
also be subject to transaction costs, “prime broker” and “trade away fees,” odd-lot differentials,
transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. These fees and expenses are separate from and in addition
to the fees charged by RJP. Accordingly, the client should review the fees charged together with
the fees charged by RJP, to fully understand the total amount of fees to be paid by the client and
to thereby evaluate the advisory services being provided. Although RJP believes our advisory
fees are competitive and reasonable in light of the types of services to be provided, clients should
be aware that lower fees for comparable services may be available from other sources.
In addition, any fund shares held in a client’s account are subject to fund-related expenses and, if
applicable, 12b-1 fees and/or early redemption fees on mutual funds. Each fund’s prospectus
fully describes the fees and expenses. All fees paid to RJP for investment advisory services are
separate and distinct from the fees and expenses charged by funds. Funds pay advisory fees to
their managers, which are indirectly charged to all holders of the fund shares.
Termination
Investment Management Services
Either the client or RJP may terminate the investment advisory agreement on thirty (30) days’
written notice and in such a case, RJP will RJP will refund any prepaid, unearned advisory fees
based on the effective date of termination, using the following formula: (Fees Paid) x (Days
Remaining in Quarter)/(Total Number of Days in Quarter).
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Financial Planning and Consultations
RJP considers the planning phase of our services to be complete, and the agreement terminated
upon delivery of a satisfactory financial planning project. In the event that either the client or
RJP wishes to terminate the financial planning agreement before completion of the plan, either
party may terminate the agreement at any time by providing written notice to the other party.
Upon notice of termination, RJP will provide the client with an invoice for services provided
through the date of termination. If the client paid fees in advance that were more than the amount
due for services, RJP will refund any unearned fees.
Other Compensation
As both a registered representative and insurance agent, Mr. Patterson expects to receive
compensation from both Purshe Kaplan Sterling Investments and variable annuity sponsors for
the sale of securities and other investment products. This practice presents a conflict of interest
and gives individuals an incentive to recommend investment products based on the compensation
received, rather than on a client’s needs. Clients have the option to purchase investment products
that RJP recommends through any broker or agent they desire. Also see Item 10 – Other
Financial Industry Activities and Affiliations.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
RJP does not charge performance-based fees or other fees based on a share of capital gains or
capital appreciation of the assets of a client.
ITEM 7: TYPES OF CLIENTS
RJP offers investment, portfolio management, and planning services to a variety of clients
including individuals, high net worth individuals, retirement accounts, and corporations.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS
Methods of Analysis and Investment Strategies
General Investment Strategies
For each investment strategy listed, RJP applies a fundamental research process which may
include financial analysis of a company’s balance sheet, cash flow statement, historical earnings,
and dividends, as well as other fundamental metrics.
Equities
For equity securities, RJP uses a value investing style focusing on companies with low
valuations across a broad range of industry groups. RJP expects the common stocks and funds in
which it invests will generate income (for example, by paying dividends).
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Fixed Income
For fixed income securities, RJP reviews the issuer’s credit rating, the coupon rate, duration, and
other terms of the security (e.g., callable, general obligation or revenue)
Specific Investment Strategies
Conservative Strategy
This strategy seeks long-term growth of capital and income. This strategy seeks to achieve its
investment objective by investing in U.S. dollar denominated fixed income securities and equity
securities. The strategy targets a long-term average asset allocation of approximately 60% to
80% exposure to municipal and corporate fixed income securities, and 20% to 40% exposure to
equities of the 500 largest publicly traded companies in the United States (in terms of market
capitalization), and exchange-traded funds and mutual funds that invest primarily in large cap
stocks.
Moderate Strategy
This strategy seeks long-term growth of capital and income. This strategy seeks to achieve its
investment objective by investing in U.S. dollar denominated fixed income securities and equity
securities. The strategy targets a long-term average asset allocation of approximately 40% to
60% exposure to municipal and corporate fixed income securities, and 40% to 60% exposure to
equities. This strategy will normally have some exposure to small, medium, and large
capitalization companies, although RJP reserves the flexibility to vary this strategy’s relative
weightings to each capitalization range based on a number of factors.
The strategy may also invest in equity securities of companies that are domiciled in or tied
economically to non-U.S. countries, including countries with emerging securities markets – that
is, countries with securities markets which are, in the opinion of RJP, less sophisticated than
more developed markets in terms of participation by investors, analyst coverage, liquidity and
regulation. This may be achieved by investing in exchange traded funds, mutual funds, ADRs
and other depositary receipts, in addition to direct investments in the securities of non-US
issuers. The strategy may also invest in derivative instruments such as participatory notes. The
strategy may also invest a small portion of its equity portion in any combination of the following
asset classes: commodity interests, options, and publicly traded and non-publicly real estate
investment trusts (“REITs”). The strategy may either invest directly in these different asset
classes or indirectly through derivatives and other instruments.
Aggressive Strategy
This strategy seeks long-term growth of capital and income. This strategy seeks to achieve its
investment objective by investing in U.S. dollar denominated fixed income securities and equity
securities. The strategy targets a long-term average asset allocation of approximately 20% to
40% exposure to municipal and corporate fixed income securities, and 60% to 80% exposure to
equities. This strategy will normally have some exposure to small, medium, and large
capitalization companies, although RJP reserves the flexibility to vary this strategy’s relative
weightings to each capitalization range based on a number of factors.
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The strategy may also invest in equity securities of companies that are domiciled in or tied
economically to non-U.S. countries, including countries with emerging securities markets – that
is, countries with securities markets which are, in the opinion of RJP, less sophisticated than
more developed markets in terms of participation by investors, analyst coverage, liquidity and
regulation. This may be achieved by investing in exchange traded funds, mutual funds, ADRs
and other depositary receipts, in addition to direct investments in the securities of non-US
issuers. The strategy may also invest in derivative instruments such as participatory notes. The
strategy may also invest a small portion of its equity portion in any combination of the following
asset classes: commodity interests, options, and publicly traded and non-publicly real estate
investment trusts (“REITs”). The strategy may either invest directly in these different asset
classes or indirectly through derivatives and other instruments.
Risks
Investing in securities and other financial instruments involves risk of loss that clients should be
prepared to bear. Those risks will depend on the nature of the investment strategy and the types
of investments used within the strategy.
Dependence on Key Persons
Each strategy is highly dependent on the expertise and skill of Robert J. Patterson to develop and
implement investment techniques that achieve the strategy’s investment objective. In the event
Mr. Patterson became unable to participate in the management of RJP, the consequences would
be material.
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in
stocks, bonds, short-term money-market instruments, other securities or assets, or some
combination of these investments. The portfolio of the fund consists of the combined holdings it
owns. Each share represents an investor’s proportionate ownership of the fund’s holdings and the
income those holdings generate. The price that investors pay for mutual fund shares is the fund’s
per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of
purchase.
The benefits of investing through mutual funds include:
Professionally Managed
Mutual funds are professionally managed by investment advisers who research, select, and
monitor the performance of the securities the fund purchases.
Diversification
Mutual funds typically have the benefit of diversification, which is an investing strategy that
generally sums up as “Don’t put all your eggs in one basket.” Spreading investments across a
wide range of companies and industry sectors can help lower the risk if a company or sector
fails. Some investors find it easier to achieve diversification through ownership of mutual funds
rather than through ownership of individual stocks or bonds.
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Affordability
Some mutual funds accommodate investors who do not have a lot of money to invest by setting
relatively low dollar amounts for initial purchases, subsequent monthly purchases, or both.
Liquidity
Generally, mutual fund investors can readily redeem their shares at the current NAV, less any
fees and charges assessed on redemption. Less frequently, some mutual funds have the option to
redeem shares using the underlying stocks in the fund’s portfolio or may delay redemption for a
defined period.
Mutual funds also have features that some investors might view as disadvantages:
Costs Despite Potential for Negative Returns
funds pay operating and other expenses from fund assets regardless of how the fund performs,
which are indirectly charged to all holders of the mutual fund shares. Depending on the timing of
their investment, investors may also have to pay taxes on any capital gains distribution they
receive. This includes instances where the fund went on to perform poorly after purchasing
shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time,
nor can they directly influence which securities the fund manager buys and sells or the timing of
those trades.
Price Uncertainty
With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or
investment adviser. Investors can also monitor how a stock’s price changes from hour to hour—
or even second to second. By contrast, with a mutual fund, the price at which an investor
purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not
calculate until many hours after the investor placed the order. In general, mutual funds must
calculate their NAV at least once every business day, typically after the major U.S. exchanges
close.
Different Types of Funds
When it comes to investing in mutual funds, investors have literally thousands of choices. Most
mutual funds fall into one of three main categories; money market funds, bond funds (also called
“fixed income” funds), and stock funds (also called “equity” funds). Each type has different
features and different risks and rewards. Generally, the higher the potential return, the higher the
risk of loss.
Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and most other
investments). By law, they can invest in only certain high quality, short-term investments issued
by the U.S. Government, U.S. and foreign corporations, state and local governments, and bank
issued certificates of deposit. Money market funds try to keep their net asset value (NAV), which
represents the value of one share in a fund, at a stable $1.00 per share. However, the NAV may
fall below $1.00 if the fund’s investments perform poorly. Investor losses have been rare, but
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they are possible. Money market funds pay dividends that generally reflect short-term interest
rates, and historically the returns for money market funds have been lower than for either bond
or stock funds.
Bond Funds
Bond funds generally have higher risks than money market funds, largely because they typically
pursue strategies aimed at producing higher yields. Unlike money market funds, the SEC’s rules
do not restrict bond funds to high quality or short-term investments. Because there are many
different types of bonds, bond funds can vary dramatically in their risks and rewards.
Some of the risks associated with bond funds include:
Credit Risk
There is a possibility that companies or other issuers may fail to pay their debts (including the
debt owed to holders of their bonds). Consequently, this affects mutual funds that hold these
bonds. Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury
Bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally
will be subject to higher risk.
Interest Rate Risk
There is a risk that the market value of the bonds will go down when interest rates go up.
Because of this, investors can lose money in any bond fund, including those that invest only in
insured bonds or U.S. Treasury Bonds. Funds that invest in longer-term bonds tend to have
higher interest rate risk.
Prepayment Risk
Issuers may choose to pay off debt earlier than the stated maturity date on a bond. For example,
if interest rates fall, a bond issuer may decide to “retire” its debt and issue new bonds that pay a
lower rate. When this happens, the fund may not be able to reinvest the proceeds in an
investment with as high a return or yield.
Stock Funds
A stock fund’s value can rise and fall quickly (and dramatically) over the short term but may
demonstrate more stability over the long-term. Overall “market risk” poses the greatest potential
danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such
as the overall strength of the economy or demand for particular products or services. Not all
stock funds are the same.
Exchange-Traded Funds (ETFs)
An exchange-traded fund (“ETF”) is a type of security (usually, an open-end fund or unit
investment trust) containing a basket of stocks, fixed income instruments, and/or commodities.
ETFs may be structured to track the performance of a particular market index, including broad-
based or sector-specific indexes. These “passive” ETFs seek to achieve investment results that
correspond, before fees and expenses, to the performance of the underlying index by generally
holding the same securities, or a representative sample of the securities, included in the index.
However, such ETFs may not perfectly track their target index due to fees, expenses, tracking
error, market conditions, or portfolio rebalancing. Other ETFs do not seek to replicate the
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performance of a specific index and instead rely on active portfolio management. Actively
managed ETFs may invest in a more limited number of securities, may deviate significantly from
market indexes, and may underperform or outperform the broader market depending on market
conditions and the effectiveness of the investment manager’s strategies.
Unlike traditional mutual funds, which can only be redeemed at the end of a trading day, ETFs
trade throughout the day on an exchange. Like mutual funds, the prices of the underlying
securities and the overall market generally affect ETF prices. Similarly, factors affecting a
particular industry segment typically affect ETF prices that track that particular sector.
Leveraged & inverse ETFs
Leveraged ETFs seek to deliver multiples of the performance of the index or benchmark they
track. Some ETFs are “inverse” or “short” funds, meaning that they seek to deliver the opposite
of the performance of the index or benchmark they track. Some funds are both short and
leveraged, meaning that they seek to achieve a return that is a multiple of the inverse
performance of the underlying index. Most leveraged and inverse ETFs “reset” daily, meaning
that they are designed to achieve their stated objectives on a daily basis. Due to the effect of
compounding, their performance over longer periods of time can differ significantly from the
performance (or inverse of the performance) of their underlying index or benchmark during the
same period of time. This effect is magnified by the use of leverage. Therefore, inverse and
leveraged ETFs that are reset daily typically are unsuitable for retail investors who plan to hold
them for longer than one trading session, particularly in volatile markets.
Equity Securities
The value of equity securities is subject to market risk, including changes in economic
conditions, growth rates, profits, interest rates and the market’s perception of these securities.
Prices will increase and decrease, reflecting fluctuations in the value of securities underlying the
securities held in an account. Investments in small and medium sized companies entail greater
risk because these companies have unproven track records, limited product and service base,
limited access to capital and may be more likely to fail than larger companies.
Small and Medium Sized Companies
Securities issued by small and medium sized companies have the risk of greater loss and
volatility because these companies have unproven track records, limited product and service
base, limited access to capital and may be more likely to fail than larger companies.
Non-U.S. Securities
Investing in non-U.S. securities is subject to additional market risks. The securities markets of
many non-U.S. countries are relatively small, with a limited number of companies representing a
small number of industries. Additionally, issuers of non-U.S. securities are often not subject to
the same degree of regulation as U.S. issuers. Reporting, accounting, and auditing standards of
non-U.S. countries differ, in some cases significantly, from U.S. standards. Also, nationalization,
expropriation or confiscatory taxation, currency blockage, market disruption, political changes,
security suspensions or diplomatic developments could adversely affect a strategy’s investments
in a non-U.S. country. In the event of nationalization, expropriation or other confiscation, a client
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could lose its entire investment in non-U.S. securities. To the extent a strategy invests in
countries with emerging and frontier markets, that is, securities of issuers tied economically to
countries with developing economies, these risks are magnified since the countries in which
these markets are located may have unstable governments and less established markets.
Corporate Bonds Risk
The investment return of corporate bonds reflects interest and changes in the market value of the
bond. The market value of a corporate bond may be expected to rise and fall inversely with
interest rates generally. Bonds may be subject to a greater risk of rising interest rates than would
normally be the case due to the current period of historically low rates. In addition to interest rate
risk, corporate bonds also involve the risk that the issuers of the securities may not be able to
meet their obligations on interest or principal payments at the time called for by an instrument.
The rate of return or return of principal on some debt obligations may be linked or indexed to the
level of exchange rates between the U.S. dollar and a foreign currency or currencies.
Municipal Securities Risk
Interest rate risk is the risk that the value of municipal bonds will decline because of rising
interest rates. Municipal bonds may be subject to a greater risk of rising interest rates than would
normally be the case due to the current period of historically low rates and the effect of potential
government fiscal policy initiatives and resulting market reaction to those initiatives. When
interest rates change, the values of longer-duration debt securities usually change more than the
values of shorter-duration debt securities. The values of municipal securities may be adversely
affected by local political and economic conditions and developments. Adverse conditions in an
industry significant to a local economy could have a correspondingly adverse effect on the
financial condition of local issuers. Income from municipal bonds could be declared taxable
because of, among other things, unfavorable changes in tax laws, adverse interpretations by the
Internal Revenue Service or state tax authorities, or noncompliant conduct of a bond issuer.
High Yield Securities Risk
Investing in high yield securities involves special risks in addition to the risks associated with
investments in higher rated debt securities. While investments in high yield securities generally
provide greater income and increased opportunity for capital appreciation than investments in
higher quality securities, investments in high yield securities typically entail greater price
volatility as well as principal and income risk and may be more susceptible to real or perceived
adverse economic and competitive industry conditions. High yield securities are regarded as
predominantly speculative with respect to the issuer’s continuing ability to meet principal and
interest payments. Analysis of the creditworthiness of issuers of high yield securities may be
more complex than for issuers of higher quality debt securities. RJP may continue to hold high
yield securities in a strategy following a decline in their rating if in our opinion it would be
advantageous to do so. Investments in high yield securities are described as “speculative” by
ratings agencies. Securities ranked in the lowest investment grade category may also be
considered speculative by certain ratings agencies.
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Currency Risk
Certain strategies may gain exposure to foreign (non-U.S.) currencies, or invest in securities that
trade in, or receive revenues in, foreign currencies, or in derivatives that provide exposure to
foreign currencies that are subject to the risk that those currencies will decline in value relative to
the U.S. dollar, or, in the case of hedging positions, that the U.S. dollar will decline in value
relative to the currency being hedged.
Option Transactions
We do not typically utilize options in new client accounts; however, upon request of a client and
at RJP’s discretion, we will engage in option strategies. The purchase or sale of an option
involves the payment or receipt of a premium payment and the corresponding right or obligation,
as the case may be, to either purchase or sell the underlying security or other instrument for a
specific price at a certain time or during a certain period. Purchasing options involves the risk
that the underlying instrument does not change price in the manner expected, so that the option
expires worthless, and the investor loses its premium.
Selling options, on the other hand, involve potentially greater risk because the investor is
exposed to the extent of the actual price movement in the underlying security or other instrument
in excess of the premium payment received. “Naked” written call options are riskiest because
there is no underlying security that can act as a partial hedge. “Naked” written call options have
speculative characteristics, and the potential for loss is theoretically unlimited. When a “naked”
written call option is exercised, the strategy must purchase the underlying security to meet its
delivery obligation or make a payment equal to the value of its obligation in order to close out
the option.
There is also a risk, especially with less liquid preferred and debt securities or small
capitalization securities, that the securities may not be available for purchase. Option positions
generally are marked-to-market, although short option positions may require additional margin if
the market moves against the position.
Options on indices may not correlate perfectly with the underlying investments (basis risk) and
may not act as expected. This may cause given transactions not to achieve their objectives and
may result in losses, which may more than offset any gains from options premiums.
Options are dependent on the smooth functioning of the option exchanges trading the particular
options utilized in the strategy. If the option exchanges are not operating as expected, the option
strategies herein could be adversely affected.
Financial Planning Risk
The financial planning tools RJP uses to create financial plans for clients rely on various
assumptions, such as estimates of inflation, risk, economic conditions, and rates of return on
security asset classes. Return assumptions generally reflect asset class returns instead of actual
investment returns, and do not always include fees or expenses that clients would pay if they
invested in some specific products.
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Financial planning software is only a tool used to help guide RJP and the client in developing an
appropriate plan, and we cannot guarantee that clients will achieve the results shown in the plan.
Results will vary based on the information provided by the client regarding the client’s assets,
risk tolerance, and personal information. Changes to the program’s underlying assumptions or
differences in actual personal, economic, or market outcomes will generally impact client results.
Clients should carefully consider the assumptions and limitations of the financial planning
software and should discuss the results of the plan with us before making any changes to their
investments or financial plan. If the financial plan includes recommendations for investing in
securities, you should understand that investing in securities involves risk of loss, and you should
be prepared to bear that risk.
ITEM 9: DISCIPLINARY INFORMATION
Neither RJP nor our employees have been the subject of legal or regulatory findings or are the
subject of any pending criminal proceedings.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Representative of Broker-Dealer and Licensed Insurance Agent
Robert Patterson also serves as a registered representative of Purshe Kaplan Sterling Investments
(“PKS”), a FINRA-registered broker-dealer/member SIPC and offers securities products in that
capacity. Mr. Patterson is also licensed as insurance agent and recommends life insurance and
variable insurance products. When acting in his capacity as registered representative or insurance
agent, Mr. Patterson receives commission-based compensation, including commissions and other
transaction-based compensation, from PKS and from insurance companies whose products he
recommends. These activities are separate and apart from the advisory services provided by RJP.
The receipt of commissions creates a conflict of interest, as it provides an incentive for Mr.
Patterson to recommend securities or insurance products that generate compensation rather than
recommending investments solely based on a client’s needs. In addition, clients who purchase
such products typically pay commissions or other transaction-based charges in addition to
advisory fees paid to RJP. To address these conflicts, Mr. Patterson operates under a fiduciary
duty that requires him to place the interests of our clients ahead of his own and to make
recommendations that he believes are in the best interest of the client.
Clients are not obligated to purchase securities or insurance products through Mr. Patterson. If
clients choose to implement recommendations made as part of their financial plan, they may do
so through Mr. Patterson in his separate capacity as registered representative or insurance agent,
or through any other broker-dealer, insurance agent, or professional of their choosing.
Tax Planning and Return Preparation
RJP owns a 50% interest in RJP Tax, LLC (“RJP Tax”). RJP utilizes the services and expertise
of an unaffiliated Certified Professional Accountant (CPA) to provide tax planning services and
preparation of tax returns. Robert J. Patterson offers advisory services to some accounting clients
through RJP. However, he does not have signatory authority over RJP clients’ accounts in
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connection with the activities of RJP Tax. The professional services and fees of RJP Tax are
entirely separate and distinct from RJP’s investment advisory services and fees.
There are times when RJP refers clients in need of accounting, tax return preparation, and other
business advisory services to RJP Tax. Similarly, RJP Tax refers clients to RJP for investment
management, financial planning, and other services offered by RJP. While neither entity
compensates the other for these referrals, there is a conflict of interest where RJP has a financial
incentive to refer clients in need of accounting services only to RJP Tax and not to unaffiliated
service providers. Additionally, a conflict exists where the tax planning services of RJP Tax
could be tailored to increase the utilization of advisory services to be provided by RJP. RJP
recognizes these conflicts and in observance of our fiduciary duty to all clients will never
recommend services that we do not believe are suitable and appropriate for each client based on
their individual circumstances and needs.
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
RJP takes the issue of regulatory compliance seriously and is committed to maintaining
compliance with state and applicable federal securities laws. Additionally, RJP has a position of
public trust, and it is our goal to maintain that trust and provide excellent service, good
investment performance, and advice that is suitable. RJP places great value on ethical conduct.
Therefore, the ultimate goal of our internal policies is to challenge our staff to live up not only to
the letter of the law, but also to the ideals set forth by RJP.
RJP believes that we owe clients the highest level of trust and fair dealing. As a registered
investment adviser, RJP is a fiduciary to clients. As a fiduciary, our duties to clients include:
1. Providing advice that is suitable;
2. Providing full disclosure of material facts and conflicts of interest (so that clients have
complete and honest disclosure in order to make an informed decision about our services
and investment recommendations);
3. Conducting ourselves with the utmost and exclusive loyalty and good faith;
4. Seeking best execution of transactions under the available circumstances;
5. Taking reasonable care to avoid misleading clients; and
6. Acting in the best interests of clients.
It is our policy to protect the interests of each of our clients and to place the clients’ interests first
in every situation. In all cases, we will abide by fair, equitable, and ethical principles. We will
provide a copy of our Code of Ethics to any client or prospective client upon request.
ITEM 12: BROKERAGE PRACTICES
The Custodian and Brokers We Use
RJP does not maintain custody of our clients’ assets. However, we are deemed to have custody
when clients give us the authority to withdraw assets from their accounts. Client assets must be
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maintained in an account at a “qualified custodian,” generally a broker-dealer or bank.
Accordingly, RJP has entered into a relationship with and recommend that our clients use
Schwab Advisor Services™, a division of Charles Schwab & Co., Inc. (“Schwab”), registered
broker-dealer, Member SIPC, pursuant to which Schwab will maintain individual client account
records and custody of our clients’ funds and securities.
Schwab holds each client’s assets in a separate brokerage account and will buy and sell securities
in the account when we instruct them to. While RJP recommends that the client consider this
arrangement, they must decide whether to do so and open accounts directly with Schwab, as we
do not open accounts for our clients. Even though your account is maintained at Schwab, we may
still use other brokers to execute trades for your account as described further in this Item below.
RJP is independently owned and operated and not affiliated with Schwab.
How We Select Brokers/Custodians to Recommend
RJP considers a wide range of factors, including, among others, these:
1. combination of transaction execution services along with asset custody services
(generally without a separate fee for custody)
2. capability to execute, clear and settle trades (buy and sell securities for your account)
3. capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
4. availability of investment research and tools that assist us in making investment decisions
5. quality of services
6. competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate them
7. reputation, financial strength, and stability of the provider
8. their prior service to us and our other clients
9. availability of other products and services that benefit us (see Products and Services
Available to Us From Schwab in this Item below)
Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab does not charge separately for custody services
but is compensated by charging commissions, mark-up and mark-down or other fees which in
the case of gross fee arrangements are paid by RJP. In addition to commissions, mark-ups, and
mark-downs, Schwab charges clients a flat dollar amount as a “prime broker” or “trade away”
fee for each trade that RJP has executed by a different broker-dealer, but where the securities
bought or the funds from the securities sold are deposited (settled) into your account. All clients
bear these “prime broker” or “trade away” fees. Because of this, in order to minimize the trading
costs, RJP has Schwab execute most trades for our clients’ account. Clients who direct us to use
broker-dealers or custodians other than Schwab are responsible for their own custody and
brokerage costs, which are in addition to the investment advisory fee.
Products and Services Available to Us from Schwab
Access to Schwab provides us and our clients with its institutional brokerage, trading, custody,
reporting and related services – many of which are not typically available to retail customers.
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There are also various support services available. Some of those services help us manage or
administer our clients’ accounts while others help us manage and grow our business. These
support services are generally available on an unsolicited basis (we do not have to request
them) and at no charge to us.
Following is a more detailed description of Schwab’s support services:
Services That Benefit Our Clients
Schwab’s institutional brokerage services include access to a broad range of investment
products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access
or that would require a significantly higher minimum initial investment by our clients. Schwab’s
services described in this paragraph generally benefit our clients and their accounts.
Services That May Not Directly Benefit Our Clients
There are other products and services that benefit us but may not directly benefit our clients or
their accounts. These products and services assist us in managing and administering our clients’
accounts. They include investment research which RJP uses to service all or some substantial
number of our clients’ accounts. In addition to investment research, RJP can access software and
other technology that:
1. provides access to client account data (such as duplicate trade confirmations and account
statements);
2. facilitates trade execution and allocate aggregated trade orders for multiple client
accounts;
3. provides pricing and other market data;
4. facilitates payment of our fees from our clients’ accounts; and
5. assists with back-office functions, recordkeeping, and client reporting.
Other services intended to help us manage and further develop our business enterprise include:
1. educational conferences and events; and
2. technology, compliance, legal, and business consulting.
Schwab may provide some of these services to us themselves. In other cases, they will arrange
for third-party vendors to provide the services to us. They may also provide us with other
benefits such as occasional business entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of the above services benefits us because RJP does not have to produce or
purchase them. This may give us an incentive to recommend that clients maintain accounts with
Schwab based on our interest in receiving services that benefit our business rather than based on
their interest in receiving the best value in custody services and the most favorable execution of
transactions. This is a potential conflict of interest. RJP believes, however, that the selection of
Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by
the scope, quality, and price of their services and not the services that benefit only us.
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Advyzon Investment Management Agreement
RJP uses the Advyzon technology platform for certain operational functions, such as portfolio
management, client reporting, and billing. We have also engaged Advyzon Investment
Management LLC ("AIM") for investment management services through AIM's turnkey asset
management program (TAMP) and for outsourced trading services. Based on the revenue
generated from these services, AIM will grant RJP a discount or waiver of our Advyzon
technology fee when we reach certain revenue breakpoints. Therefore, we have an incentive to
increase our use of AIM's TAMP or trading services to achieve technology fee discounts or
waivers.
Brokerage for Client Referrals
RJP does not consider, in selecting or recommending broker-dealers, whether it receives client
referrals from a broker-dealer or third party. As noted below, a client may direct RJP to use the
services of a particular broker-dealer in executing transactions for that client’s account. In some
cases, the directed broker may have recommended it as the investment manager for that account.
Directed Brokerage
In certain instances, clients of separately managed accounts may direct RJP in writing to use a
particular broker-dealer to execute some or all transactions for the client. In those cases, the
client is responsible for paying the brokerage commissions. The client will negotiate terms and
arrangements for the account with that broker-dealer, which may interfere with our ability to
obtain best price and execution or to aggregate that client’s transactions for execution through
other broker-dealers with orders for other accounts managed by us. As a result, the client may
pay higher commissions or other transaction costs or greater spreads, or receive less favorable
net prices, on transactions for the account than would otherwise be the case. RJP may decline a
client’s request to direct brokerage, in our sole discretion, for any reason.
Aggregation and Allocation of Transactions
Order Aggregation
RJP enters transactions for each client independently and does not aggregate (combine) client
orders. Because orders for individual client accounts may be entered over the course of the
trading day, or in some cases the following day, different clients trading the same security
around the same time typically receive different execution prices. To help ensure that no client is
systematically advantaged or disadvantaged by this practice, RJP follows a generally consistent
methodology for determining the order in which client accounts are entered for similar
transactions, so that no single account is consistently traded first or last. Given RJP's size and
trading volume, our trades are also generally not large enough, individually or in combination,
for aggregation to produce a better execution price through block size. For these reasons, we do
not believe clients are systematically disadvantaged because we do not aggregate client orders.
To the extent we use mutual funds in client accounts, aggregation provides no pricing advantage,
as mutual funds are priced once daily at the same price for each investor. Additionally, the
broker-dealer/custodians we recommend charge each account an individual transaction fee
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regardless of whether we aggregate or not, so we are unable to lower trading costs through
aggregation.
Trade Allocations
Given the different client guidelines and liquidity needs, as well as market constraints, RJP
manages each client account independently. Generally, however, RJP attempts to allocate
investment opportunities pro rata across similar accounts. When allocating trades among clients,
RJP considers an account’s restrictions and liquidity.
ITEM 13: REVIEW OF ACCOUNTS
Account Reviews
RJP seeks to meet client objectives by monitoring accounts regularly and rebalancing clients’
investment portfolios, as we deem appropriate. In addition, RJP reviews client accounts as
needed in cases of material market changes, company news, changes in a client’s investment
objectives, or at the request of a client. We encourage clients to notify us of any changes in their
investment guidelines that might affect their investment needs, objectives, or time horizon. RJP
representatives will generally meet with all clients no less than annually to review the client’s
investment goals and current advisory portfolios. Robert Patterson, Chief Executive Officer, and
Kameron S. Barzegar, Investment Adviser Representative, regularly review all client accounts
and remain available during normal business hours to consult with clients.
Account Reporting
Each client receives a written statement from the custodian that includes an accounting of all
holdings and transactions in the account for the reporting period. In addition, RJP provides
clients with written portfolio statement reports through our Client Portal. Available report
options include descriptions of the assets held, the quantity and market value of each position,
the total market value of each account, and account performance. The Client Portal is available at
no additional charge to all RJP clients that opt-in to global electronic delivery. We may also
provide supplemental reporting as agreed upon by RJP and the client on a case-by-case basis.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Schwab Support Products and Services
We receive an economic benefit from Schwab in the form of the support products and services
they make available to us and other independent investment advisors whose clients maintain
their accounts at Schwab. These products and services, how they benefit us, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). We do not base
particular investment advice, such as buying particular securities for our clients, on the
availability of Schwab’s products and services to us.
Client Referral Fees
When an unaffiliated solicitor introduces a client to RJP, we pay that solicitor a referral fee in
accordance with corresponding state securities law requirements. RJP’s current solicitor
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arrangements obligate us to compensate the solicitor for each prospective client lead they refer to
us. Clients are not charged for the referral fees we pay to the solicitor. RJP currently utilizes
solicitor services through SmartAsset (CRD# 307375).
SmartVestor Pro
The SmartVestor™ program is designed to assist member Pros in advertising their services and
to facilitate initial introductions between interested consumers and Pros who are located within
their geographic location and is operated by The Lampo Group, LLC d/b/a Ramsey Solutions®
(“RS”). When you provide your contact information through the SmartVestor site, RS will
introduce you to up to five (5) investment professionals (“Pros”) that cover your geographic area,
including Robert Patterson with RJ Patterson Capital Investment Group, Inc. (“RJP”). RJP has
entered into an agreement with RS under which RJP pays RS a one-time training fee of $3,000, a
flat monthly membership fee of $400, and a flat monthly territory fee (generally $900 per
territory) to advertise RJP’s services through SmartVestor and to receive contact information
from interested consumers who are in RJP’s geographic region.
The fees paid by RJP to RS are paid irrespective of whether you become a client of RJP and are
not passed along to you. However, you should understand that all of the Pros that are available
through SmartVestor pay RS fees to participate in the program. Further, the amount of
compensation each Pro pays to RS will vary based on certain factors, including whether the Pros
choose to advertise in local or national markets. RS has a financial incentive to present certain
Pros that offer their services on a national basis (“National Pros”) more often than other National
Pros that pay lower fees.
RS is not affiliated with RJP and neither RS nor any of its representatives are authorized to
provide investment advice on behalf of RJP or to act for or bind RJP. RS introduces you to Pros
that cover your geographic area based on your zip code. Neither RS nor its affiliates provide
investment advice or recommendations as to the selection or retention of any Pro, nor does RS
evaluate whether any particular Pro is appropriate for you based on your investment objectives,
financial situation, investment needs, or other individual circumstances. Robert Patterson has
completed Ramsey Pro Training and signed a Code of Conduct under which he has agreed to
certain general investment principles, such as eliminating debt and investing for the longer-term,
but RS does not monitor or control the investment advisory services RJP provides.
Outside Referrals
RJP may refer clients to unaffiliated professionals for specific needs, such as insurance,
mortgage brokerage, real estate sales, estate planning, and/or legal. In turn, these professionals
may refer clients to RJP for investment management/financial planning needs. We do not have
any arrangements with individuals or companies that we refer clients to, and we do not receive
any compensation for these referrals. However, it could be concluded that RJP is receiving an
indirect economic benefit from this practice, as the relationships are mutually beneficial. For
example, there could be an incentive for us to recommend services of firms who refer clients to
RJP.
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RJP only refers clients to professionals we believe are competent and qualified in their field, but
it is ultimately the client’s responsibility to evaluate the provider, and it is solely the client’s
decision whether to engage a recommended firm. Clients are under no obligation to purchase any
products or services through these professionals, and RJP has no control over the services
provided by another firm. Clients who choose to engage these professionals will sign a separate
agreement with the other firm. Fees charged by the other firm are separate from and in addition
to fees charged by RJP.
If the client desires, RJP will work with these professionals or the client’s other advisors (such as
an accountant or attorney) to help ensure that the provider understands the client’s financial
plan/investments and to coordinate services for the client. In such instances, RJP makes
information about RJP portfolio positions and other related information available to outside
professionals when authorized by the client.
Affiliate Referrals and Compensation
RJP Tax
Please see Item 10 - Other Financial Industry Activities And Affiliations in Part 2A above for a
description of the services associated with RJP Tax, LLC, including conflicts of interest
correlated with reciprocal referrals.
ITEM 15: CUSTODY
RJP does not take physical custody of client funds or securities. For the convenience of the
client, we will set up quarterly fee deduction ability from the client’s account, when authorized
by the client. For client accounts where we have this authority, the following procedures apply:
1. Clients’ accounts are held by a qualified custodian (generally a broker-dealer, bank, trust
company, or other financial institution).
2. Clients will receive statements directly from their qualified custodian at least quarterly.
The statements will reflect the client’s funds and securities held with the qualified
custodian as well as any transactions that occurred in the account, including the deduction
of RJP’s fee.
3. We send the amount of our fee to the custodian.
4. It is the client’s responsibility to verify the accuracy of the fee calculation. The custodian
will not determine whether the fee is properly calculated.
RJP is also deemed to have custody of clients’ funds or securities when clients have standing
authorizations with their custodian to move money from a client’s account to a third-party
(“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers with
the custodian. The SEC has set forth a set of standards intended to protect client assets in such
situations, which we follow.
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Third-Party Investment Management Program
For accounts managed through AIM’s Third-Party Investment Management Program, AIM
debits from the client’s Schwab account both its Program Fee and RJP’s separate investment
management fee, at the rate(s) agreed to by the client in RJP’s advisory agreement
ITEM 16: INVESTMENT DISCRETION
When a client grants RJP investment and brokerage discretion, we will have authority to
determine without specific client consent the (1) securities to be bought and sold; (2) the amount
of securities to be bought and sold; (3) the broker or dealer to be used; and (4) the commissions
to be paid. RJP exercises investment discretion on behalf of our client accounts only when
expressly authorized to do so in writing by the client. Full discretion allows RJP, without the
prior consent of the client, to buy and sell securities in client accounts, select the amount of
securities to be bought or sold, decide when to initiate transactions, and select the broker or
dealers with which transactions will be executed. RJP exercises this discretion in accordance
with client guidelines and limits.
Client guidelines and limits are often tailored to reflect a particular client’s investment objective,
benchmark, risk tolerance and other requirements. Initial client account guidelines are
established and incorporated in the investment advisory agreement. From time to time, RJP may
recommend changes to account guidelines that it believes are in the best interest of the client.
RJP documents changes to client guidelines and provides those changes to the account’s
investment team.
Limited Discretion for Accounts Under Third-Party Investment Manager
When we engage a third-party manager to provide investment management of all or a portion of
your assets, RJP has the discretion to choose the Investment Strategy. Once the Investment
Strategy is selected, the third-party manager has discretionary authority over the management of
your account and RJP no longer retains discretion to implement transactions in your account/the
portion of your account managed by the third-party manager.
ITEM 17: VOTING CLIENT SECURITIES
Proxy Voting
Investment Management Services
Clients give us discretion to vote proxies on securities held in their accounts. RJP’s ability to
vote proxies depends on the client’s custodian delivering the proxies in proper form and in a
timely manner to us. RJP votes proxies in the best interests of our clients as shareholders and in a
manner that we believe maximizes the economic value of our clients’ holdings. Our proxy voting
guidelines set forth general guidelines for voting proxies, but we evaluate each proposal on its
own merits. The portfolio manager for each client’s account has the authority to decide the final
vote, absent a material conflict of interest. The portfolio manager may cast a vote that differs
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from RJP’s proxy voting guidelines if they believe it to be in the best interest of our clients and
will document their rationale for such variances, when applicable.
If RJP enters a direct or indirect business relationship with an issuer whose securities are held in
a client account, including an issuer that is also a client, or if a client expresses opposition to
initiatives proposed in a proxy statement, RJP will adopt policies and procedures reasonably
designed to reconcile the conflicts created by those business relationships at that time. Upon
request clients may write or call RJ Patterson Investment Capital Group, Inc. to obtain a copy of
our voting policies and procedures and information about how we voted their proxies. Clients
cannot direct RJP on how to vote a particular solicitation.
Proxy Voting by Third-Party Investment Manager
When we engage a third-party manager to provide investment management of all or a portion of
your assets, RJP will vote proxies for positions held in the account as described above. The third-
party manager does not exercise proxy voting authority over securities in your account.
Class Actions and Similar Matters
RJP does not instruct or give advice to clients on whether or not to participate as a member of
class action lawsuits and will not automatically file claims on the client’s behalf. However, if a
client notifies us that they wish to participate in a class action, we will provide the client with
any transaction information pertaining to the client’s account needed for the client to file a proof
of claim in a class action.
With respect to bankruptcies involving issuers of securities held in a strategy, RJP may, at our
discretion, participate in bankruptcy proceedings, make investment related elections, and join
creditors’ committees on behalf of some or all of our clients.
ITEM 18: FINANCIAL INFORMATION
RJP does not require or solicit pre-payment of more than $1,200 in fees per client six months or
more in advance and therefore is not required to provide, and has not provided, a balance sheet to
clients. RJP is not aware of any financial condition that will interfere with our ability to meet
contractual commitments to clients and has not been the subject of bankruptcy proceedings.
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Form ADV, Part 2B Brochure Supplement
Robert J. Patterson
Kameron S. Barzegar
Malek Hassan
RJ Patterson Capital Investment Group, Inc.
Dba RJ Patterson Group
402 West Broadway
Suite 2600
San Diego, CA 92101
Tel.: (619) 331-4133
Fax: (619) 684-3911
www.rjpattersongroup.com
October 9, 2026
This brochure supplement provides information about Robert J. Patterson, Kameron S. Barzegar,
and Malek Hassan that supplements the RJ Patterson Capital Investment Group, Inc. brochure.
You should have already received a copy of that brochure. Please contact us at the number above
if you did not receive our brochure or if you have any questions about the contents of this
supplement. Additional information about the above named individuals is available on the SEC’s
website at www.adviserinfo.sec.gov.
ITEM 1 - COVER PAGE
Robert J. Patterson
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Robert J. Patterson, Chief Executive Officer, Chief Compliance Officer, Chief Financial
Officer, b. 1964
Education:
• San Diego State University, BA; Liberal Arts & Sciences – Psychology, 1995
Business Background:
• RJ Patterson Capital Investment Group, Inc., San Diego, CA, Chief Executive Officer,
Chief Compliance Officer, Chief Financial Officer, 03/2016 to present
• Purshe Kaplan Sterling Investments, San Diego, CA, Registered Representative, 04/2014
to present
• DW Advisors, San Diego, CA, Investment Adviser Representative, 03/2014 to 03/2016
• Morgan Stanley, San Diego, CA, Registered Representative, 06/2009 to 03/2014
• Citigroup Global Markets, Inc. San Diego, CA, Financial Advisor, 01/2007 to 06/2009
Professional Designations
Robert J. Patterson holds the following professional designations:
Chartered Retirement Planning CounselorSM
The CRPC® designation is issued by The College for Financial Planning. Individuals who hold
the CRPC® designation have completed a course of study encompassing pre-and post-retirement
needs, asset management, estate planning and the entire retirement planning process using
models and techniques from real client situations. Additionally, individuals must pass an end-of-
course examination that tests their ability to synthesize complex concepts and apply theoretical
concepts to real-life situations. All designees have agreed to adhere to Standards of Professional
Conduct and are subject to a disciplinary process. Designees renew their designation every two-
years by completing 16 hours of continuing education, reaffirming adherence to the Standards of
Professional Conduct, and complying with self-disclosure requirements. More information
regarding the CRPC® is available at https://www.finra.org/investors/professional-
designations/crpc.
Chartered Retirement Plans SpecialistSM
Individuals who hold the CRPS® designation have completed a course of study encompassing
design, installation, maintenance, and administration of retirement plans. Additionally,
individuals must pass an end-of-course examination that tests their ability to synthesize complex
concepts and apply theoretical concepts to real-life situations. All designees have agreed to
adhere to a Standards of Professional Conduct and are subject to a disciplinary process.
Designees renew their designation every two-years by completing 16 hours of continuing
education, reaffirming adherence to the Standards of Professional Conduct, and complying with
self-disclosure requirements. More information regarding the CRPS® is available at
https://www.finra.org/investors/professional-designations/crps.
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ITEM 3 - DISCIPLINARY INFORMATION
Robert J. Patterson has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Robert J. Patterson is registered with Purshe Kaplan Sterling Investments as a General Securities
Representative. He is also licensed by the State of California to offer life insurance and variable
contracts. Mr. Patterson spends approximately 10 hours per month on securities/insurance-
related matters. Mr. Patterson receives compensation from variable annuity and insurance
sponsors whose products he recommends. Accordingly, a conflict of interests exists between
clients and Mr. Patterson. Clients are not obligated to follow our recommendation, and if clients
act on our recommendations, they are not obligated to effect the transaction through RJ Patterson
Capital Investment Group, Inc., or Mr. Patterson.
Mr. Patterson spends approximately 10 hours per month on activities related to the management
and oversight of RJP Tax, LLC. Please see Item 10 - Other Financial Industry Activities And
Affiliations in Part 2A above for more information on this activity.
ITEM 5 - ADDITIONAL COMPENSATION
In addition to compensation received from his salary and ownership of RJ Patterson Capital
Investment Group, Inc., Robert J. Patterson receives compensation from his association with
Purshe Kaplan Sterling Investments in connection with the sale of annuity and other insurance
products, as described in Item 4 – Other Business Activities, above.
Robert J. Patterson also receives compensation from RJP’s interest in RJP Tax, LLC (“RJP
Tax”) that provides tax planning services and preparation of tax returns. Please see Item 10 -
Other Financial Industry Activities And Affiliations in Part 2A above for more information on
this activity.
ITEM 6 - SUPERVISION
Robert J. Patterson is the Chief Compliance Officer of RJP and supervises all employees. Robert
J. Patterson can be reached by calling (619) 331-4133.
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Kameron S. Barzegar
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Kameron S. Barzegar, Investment Adviser Representative, b. 1998
Education:
• University of Arizona, Tucson AZ, Graduated Cum Laude, BS - Finance, 2021
• Bloomberg Market Concepts (BMC); Certified in 2020
Business Background:
• RJ Patterson Capital Investment Group, Inc., San Diego, CA, Investment Adviser
Representative, 06/2020 to present
ITEM 3 - DISCIPLINARY INFORMATION
Kameron S. Barzegar has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Kameron S. Barzegar’s only business is providing investment advice through RJP.
ITEM 5 - ADDITIONAL COMPENSATION
Kameron S. Barzegar’s only compensation comes through providing investment advice through
RJP.
ITEM 6 - SUPERVISION
Robert J. Patterson, Chief Executive Officer, is responsible for supervising Kameron S.
Barzegar’s activities. Robert J. Patterson monitors the advice provided by Kameron S. Barzegar
for consistency with client objectives. Robert J. Patterson can be reached by calling (619) 331-
4133.
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Malek Hassan
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Malek Hassan, Associate Advisor, b. 2004
Education:
• University of San Diego, San Diego, CA, Bachelor of Business Administration (BBA) -
Finance, 2025
Business Background:
• RJ Patterson Capital Investment Group, Inc., San Diego, CA, Associate Adviser
Representative, 02/2026 to present
• Sprouts, San Diego, CA, Meat Clerk, 03/2026 to present
• Axos Invest, San Diego, CA, Portfolio Analyst Intern, 05/2025 to 02/2026
• Santaluz Club, San Diego, CA, Server, 06/2024 to 05/2025
• North Island Credit Union, San Diego, CA, Wealth Management Intern, 06/2024 to
08/2024
• Home Consignment, San Diego, CA, Warehouse worker, 05/2023 to 08/2023
• Floor and Decor, San Diego, CA, Warehouse worker, 01/2023 to 06/2023
• Student, San Diego, CA, 08/2022 to 05/2025
• Flippin Pizza, San Diego, CA, Driver, 05/2019 to 06/2022
ITEM 3 - DISCIPLINARY INFORMATION
Malek Hassan has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Malek Hassan’s only business is assisting with investment advice provided through RJP.
ITEM 5 - ADDITIONAL COMPENSATION
Malek Hassan’s only compensation comes through his salary at RJP.
ITEM 6 - SUPERVISION
Robert J. Patterson, Chief Executive Officer, is responsible for supervising Malek Hassan’s
activities. Robert J. Patterson can be reached by calling (619) 331-4133.
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Privacy Information
May 2026
FACTS
WHAT DOES RJ PATTERSON CAPITAL INVESTMENT GROUP, INC. (“RJP”)
DO WITH YOUR PERSONAL INFORMATION?
Why?
Financial companies choose how they share your personal information.
Federal law gives consumers the right to limit some but not all sharing.
Federal law also requires us to tell you how we collect, share, and protect
your personal information. Please read this notice carefully to understand
what we do.
What?
The types of personal information we collect and share depend on the
product or service you have with us. This information can include:
Social Security number and income
•
• account balances and transaction history
• assets and risk tolerance
When you are no longer our customer, we continue to share your
information as described in this notice.
How?
All financial companies need to share customers’ personal information to
run their everyday business. In the section below, we list the reasons
financial companies can share their customers’ personal information; the
reasons RJP chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does RJP
share?
Can you limit
this sharing?
YES
NO
For our everyday business purposes -
as permitted by law
NO
We Don’t Share
For our marketing purposes - to offer our products and
services to you
For joint marketing with other financial companies
NO
We Don’t Share
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your transactions and experiences
NO
We Don’t Share
For our affiliates’ everyday business purposes -
information about your creditworthiness
For affiliates to market to you
NO
We Don’t Share
For nonaffiliates to market to you
NO
We Don’t Share
Questions? Call (619) 331-4133 or go to www.rjpattersongroup.com
Page 2
WHO WE ARE
Who is providing this notice?
RJ Patterson Capital Investment Group, Inc. (“RJP”)
WHAT WE DO
How does RJP protect my
personal information?
To protect your personal information from unauthorized
access and use, we use security measures that comply with
federal law. These measures include computer safeguards
and secured files and buildings.
We collect your personal information, for example, when you
How does RJP collect my
personal information?
seek advice about your investments
tell us about your investment or retirement portfolio
tell us about your investment or retirement earnings
•
• enter into an investment advisory contract
•
•
• give us your contact information
We also collect your personal information from other
companies.
Why can’t I limit all sharing?
Federal law gives you the right to limit only:
•
sharing for affiliates’ everyday business purposes -
information about your creditworthiness
sharing for nonaffiliates to market to you
• affiliates from using your information to market to you
•
State laws and individual companies may give you additional
rights to limit sharing.
DEFINITIONS
Affiliates
Companies related by common ownership or control. They
can be financial and nonfinancial companies.
• RJP is affiliated with RJP Tax, LLC.
Nonaffiliates
Companies not related by common ownership or control.
They can be financial and non-financial companies.
• RJP does not share with nonaffiliates so they can market
to you.
Joint Marketing
A formal agreement between nonaffiliated financial
companies that together market financial products or
services to you.
• RJP doesn’t jointly market.