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Part 2A of Form ADV: Firm Brochure
Form ADV, Part 2A, Item 1
Cover Page
Dale Q. Rice Investment Management, Ltd
17 Rue Du Rivoli Place
Henderson, NV 89011
Tel: (360) 693-7577
Fax: (360) 695-3899
April 29, 2026
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Dale Q.
Rice Investment Management, Ltd. If you have any questions about the contents of this brochure,
please contact us at (360) 693-7577. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about Dale Q. Rice Investment Management, Ltd is also available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Dale Q. Rice
Investment Management, Ltd is 310614.
Dale Q. Rice Investment Management, Ltd is a Registered Investment Adviser. Registration with
the United States Securities and Exchange Commission or any state securities authority does not
imply a certain level of skill or training.
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Form ADV, Part 2A, Item 2
Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April 30th.
We will further provide you with our most recent brochure at any time at your request, without
charge. You may request a brochure by contacting us at (360) 693-7577.
Material Changes since the Last Update
Since the last annual update was filed on February 18, 2026, the firm has had the following
material changes:
• Firm has changed its principal office location from 1000 NE 7th Avenue, Suite 215,
Vancouver, WA 98685 to 17 Rue Du Rivoli Place, Henderson, NV 89011.
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Form ADV, Part 2A, Item 3
Table of Contents
Item 1 Cover Sheet…………………………………………………………..….1
Item 2 Material Changes…………………………………………………….…2
Item 3 Table of Contents………………………………………………………3
Item 4 Advisory Business……………………………………………………. 4
Item 5 Fees and Compensation…………………………………………….. 5
Item 6 Performance-Based Fees and Side-By-Side Management……. 7
Item 7 Types of Clients………………………………………………………. 7
Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss 8
Item 9 Disciplinary Information…………………………………………….. 10
Item 10 Other Financial Industry Activities and Affiliations……………. 10
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading……………………………………………………………… 11
Item 12 Brokerage Practices……………………………………………….. 122
Item 13 Review of Accounts……………………………………………….. 13
Item 14 Client Referrals and Other Compensation…………………….. 13
Item 15 Custody………………………………………………………………… 14
Item 16 Investment Discretion……………………………………………….. 15
Item 17 Voting Client Securities…………………………………………… 15
Item 18 Financial Information……………………………………………… 15
Item 19 Requirements for State-Registered Advisers…………………… 166
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Form ADV Part 2A, Item 4
Advisory Business
Dale Q. Rice Investment Management, Ltd (hereinafter called “DQR”) is a Registered
Investment Adviser based in Nevada and incorporated under the laws of the State of
Washington. DQR is wholly owned by Dale Q. Rice. DQR became registered with the U.S.
Securities and Exchange Commission in March 2022 and subject to its rules and regulations.
Founded in September 2020, DQR provides investment advisory services, which may include,
but are not limited to, the review of client investment objectives and goals, recommending
asset allocation strategies of managed assets among investment products such as cash, stocks,
mutual funds and bonds, annuities, and/or preparing written investment strategies.
Subaccounts of variable annuities may be managed by DQR. Our investment advice is
tailored to meet our clients’ needs and investment objectives. Therefore, DQR will make
reasonable efforts to document and annually update client suitability information. This
information will include: Age (or date of birth), Annual income, Total net worth (excluding
primary residence), Liquid net worth, Employment status (if retired, former profession. If self-
employed, type of business), Fair market value of primary residence (and outstanding debt),
Tax status, which includes, type of account (natural person, entity, IRA, etc.), tax bracket, or
tax strategy for the account(s), Investment objectives (should be defined to ensure client
understanding), Investment experience (time/investment products), Investment time horizon,
Liquidity (cash flow) needs, Risk tolerance, Other investments (types of investments held
elsewhere), Any other information the client may disclose to the investment adviser in
connection with such recommendation or investment advice; and Any other relevant
information the investment adviser should ask based on the investment adviser’s strategy (for
example, source of funds for the purpose of this investment). Clients may impose restrictions
on investing in certain securities or types of securities (such as a product type, specific
companies, specific sectors, etc.) by providing a signed and dated written notification, of
which an e-mail is also an acceptable form of notification. DQR also provides financial
planning consulting services including, but not limited to, risk assessment/management,
investment planning, estate planning, financial organization, or financial decision
making/negotiation.
DQR provides investment advisory and other financial services through its Investment Advisory
Representatives ("IAR") to accounts opened with DQR. Managed accounts are available to
individuals and high net worth individuals.
DQR provides discretionary and non-discretionary investment advisory services to some of its
clients through various managed account programs. As a discretionary investment adviser, DQR
will have the authority to supervise and direct the portfolio without prior consultation with the
client. Non-discretionary accounts require client approval. DQR will assist clients in
determining the suitability of the managed account(s) for the client. The IAR is compensated
through a comprehensive single fee. DQR and its IAR, as appropriate, will be responsible for the
following:
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• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
DQR may recommend a Wrap Fee Program for the client’s account(s). A “wrap fee program” for
purposes of the SEC is a program under which investment advisory and brokerage execution
services are provided for a single “wrapped” fee that is not based on the transactions in a client
account. Clients with Wrap Fee Program accounts will be provided with DQR’s Wrap Fee
Brochure. DQR only offers management services through a wrap free program.
As of December 31, 2025, the firm manages $154,108,797 discretionary client assets and
$2,482,826 non-discretionary client assets.
Form ADV, Part 2A, Item 5
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged quarterly in advance and are based primarily on asset
size, the level of complexity of the services provided and aggregate value of all managed
accounts within the established household. Aggregate value will be identified on a contract
addendum. In individual cases, DQR has the sole discretion to negotiate fees that are lower than
the standard fee shown or to waive fees. Fees are not based on the share of capital gains or
capital appreciation of the funds or any portion of the funds. Comparable services for lower fees
may be available from other sources. Fees for the initial quarter will be prorated based upon the
number of calendar days in the calendar quarter that the advisory agreement is in effect. Fees are
based on the market value of the assets on the last business day of the previous quarter. Annual
fees range from 1.00% - 1.50%, depending on the amount of assets under management (“AUM”)
– See chart below. The fee schedule below is the same as that disclosed in the wrap fee
brochure, which includes transaction costs in the advisor’s fees. Financial planning and
consulting services are included in these fees for asset management services.
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Fee Schedule for Asset Management:
Total Account Value
Maximum Annual Advisory Fee
$0 - $1,249,999 1.50%
$1,250,000 – $1,999,999 1.25%
$2,000,000 or more
1.00%
As authorized in the client agreement, the account custodian withdraws Dale Q. Rice Investment
Management, Ltd.’s advisory fees directly from the clients’ accounts according to the
custodian’s policies, practices, and procedures. The custodial statement includes the amount of
any fees paid to DQR for advisory services. You should carefully review the statement from
your custodian/broker-dealer’s statement and verify the calculation of fees. Your
custodian/broker-dealer does not verify the accuracy of fee calculations. In all instances, the
Adviser will send the client a written invoice, including the fee, the formula used to calculate the
fee, the fee calculation itself, the time period covered by the fee, and, if applicable, the amount of
assets under management on which the fee was based. Also, the Adviser will include the name of
the custodian(s) on your fee invoice. The Adviser will send these to the client concurrent with
the request for payment or payment of the Adviser’s advisory fees. We urge the client to
compare this information with the fees listed in the account statement.
Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the quarter. Clients may terminate investment advisory services
obtained from DQR, without penalty, upon written or verbal notice, including phone or email
from either party, within five (5) business days after entering into the advisory agreement with
DQR. Thereafter, the client may terminate advisory services upon written notice delivered to
and received by DQR. The client is responsible for any fees and charges incurred by the client
from third parties as a result of maintaining the account such as transaction fees for any securities
transactions executed and account maintenance or custodial fees. Clients who terminate
investment advisory services during a quarter are charged a prorated advisory fee based on the
date of DQR’s receipt of client’s written notice to terminate. Any earned but unpaid fees are
immediately due and payable, and any prepaid and unearned fees will be immediately refunded.
DQR will provide an invoice to the client showing the fee(s) charged, the formula used to
calculate the fee(s), the fee calculation itself, the time period covered by the fee(s), and the
amount of assets under management on which the fee was based.
Additional Fees and Expenses
In addition to advisory fees paid to DQR as explained above, clients may pay custodial service,
account maintenance, transaction, and other fees associated with maintaining the account. These
fees vary by broker and/or custodian. Clients should ask DQR for details on transaction fees or
other custodial fees specific to their account, as these fees are not included in the annual advisory
fee. DQR does not share any portion of such fees. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
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management, investment advisory and administrative fees. Such fees are not shared with DQR
and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus
prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees that
would not exist if the purchase or sale were made directly with the mutual fund company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual fund
management fees may be more or less than the mutual fund management fees charged if the
client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of DQR or paying the advisory fee
on such shares (but subject to any applicable sales charges). Certain mutual funds are offered to
the public without a sales charge. In the case of mutual funds offered with a sales charge, the
prevailing sales charge (as described in the mutual fund prospectus) may be more or less than the
applicable advisory fee. However, clients would not receive DQR’s assistance in developing an
investment strategy, selecting securities, monitoring performance of the account, and making
changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Form ADV, Part 2A, Item 6
Performance-Based Fees and Side-By-Side Management
Dale Q. Rice Investment Management, Ltd does not charge performance-based fees or
participate in side-by-side management. Side-by-side management refers to the practice of
managing accounts that are charged performance-based fees while at the same time managing
accounts that are not charged performance-based fees. Performance-based fees are fees that are
based on a share of capital gains or appreciation of the assets of a client. Our fees are calculated
as described in Fees and Compensation section above and are not charged on the basis of
performance of your advisory account.
Form ADV, Part 2A, Item 7
Types of Clients
DQR offers investment advisory services to individuals and high net worth individuals. There is
no minimum account size to open and maintain an advisory account.
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Form ADV, Part 2A, Item 8
Methods of Analysis, Investment Strategies, and Risk of Loss
DQR’s methods of analysis and investment strategies incorporate the client’s needs and
investment objectives, time horizon, and risk tolerance. DQR is not bound to a specific
investment strategy for the management of investment portfolios, but rather consider the risk
tolerance levels pre-determined gathered at the account opening, as well as on an on-going basis.
Examples of methodologies that our investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will
gradually, over time, decrease the average share price of the security. Dollar-cost averaging
lessens the risk of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets to
predict the direction of both the overall market and specific stocks. The risk of market timing
based on technical analysis is that it may not accurately predict future price movements. Current
prices of securities may reflect all information known about the security and day to day changes
in market prices of securities may follow random patterns and may not be predictable with any
reliable degree of accuracy.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations. Frequent trading can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk
of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
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economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
DQR’s primary goal for investing is to help the client maintain purchasing power over the long
term. This may result in short term variability and loss of principal. Time horizon and risk
tolerance are key determinates of the proper asset allocation. DQR’s approach focuses on taking
appropriate risks for which clients are compensated (i.e. market risk) and seeking to limit or
eliminate risks that do not provide compensation over the long term (i.e. individual stock risk or
lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. DQR’s investment approach may fail to produce the intended results. If our
perception of the performance of a specific asset class or underlying fund is not realized in the
expected time frame, the overall performance of client’s portfolio may suffer.
Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment
of municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
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addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. DQR has no control over the risks taken by the
underlying funds.
Artificial Intelligence and Machine Learning Risk. Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
service providers have appropriate controls in place to protect our clients’ information and to
limit data inaccuracies when artificial intelligence is used by the service provider
Form ADV, Part 2A, Item 9
Disciplinary Information
Dale Q. Rice Investment Management, Ltd or its Principal Executive Officers have not had any
reportable disclosable events in the past ten years.
Form ADV, Part 2A, Item 10
Other Financial Industry Activities and Affiliations
Dale Q. Rice, owner and sole IAR of DQR, is not currently registered with any broker dealer.
Neither DQR nor its representatives are registered as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor.
Dale Q. Rice is also a licensed insurance agent. From time to time, he will offer clients advice or
products from those activities. Clients should be aware that these services pay a commission and
involve a possible conflict of interest, as commissionable products can conflict with the fiduciary
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duties of a registered investment adviser. DQR always acts in the best interest of the client;
including the sale of commissionable products to advisory clients. DQR owes the client a
fiduciary duty to put the client’s interest first which includes, but is not limited to, a duty of care,
loyalty, obedience, and utmost good faith. Clients are in no way required to implement the plan
through any representative of DQR in their capacity as an insurance agent. Not more than 20%
of Dale Q. Rice’s time is spent on this activity.
Form ADV, Part 2A, Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
DQR’s Code of Ethics includes guidelines for professional standards of conduct for our
Associated Persons. Our goal is to protect client interests at all times and to demonstrate our
commitment to fiduciary duties of honesty, good faith, and fair dealing. All of DQR’s
Associated Persons are expected to strictly adhere to these guidelines. Persons associated with
Dale Q. Rice Investment Management, Ltd are also required to report any violations to the Code
of Ethics. Additionally, the firm maintains and enforces written policies reasonably designed to
prevent the misuse or dissemination of material, non-public information about our clients or
client accounts by persons associated with our firm.
DQR and its employees may buy or sell securities that are also held by clients. It is the expressed
policy of the advisor that no person employed by our firm purchase or sell any security prior to the
transaction being implemented for an advisory account; therefore, preventing such employees
from benefiting from transactions placed on behalf of the advisory clients.
The advisor does not have, nor plans to have, a material financial interest or position in a security
which is then also recommended to the client. As these situations may present a conflict of interest,
the advisor has established the following restrictions in order to ensure its fiduciary responsibilities
should this issue ever arise:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of DQR shall prefer their own interest to that of the client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor may block personal trades with those of clients but will ensure that clients are
not at a disadvantage.
DQR’s Code of Ethics is available to you upon request. You may obtain a copy of our Code of
Ethics by contacting Dale Q. Rice at (360) 693-7577.
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Form ADV, Part 2A, Item 12
Brokerage Practices
DQR offers a clearing platform to execute securities business for investment advisory services
through Charles Schwab & Co., Inc., Member FINRA/SIPC. In order for DQR to provide asset
management services, we request you utilize the brokerage and custodial services of Schwab.
Schwab is an independent SEC-registered broker dealer and is separate and unaffiliated with
DQR. Schwab offers services to independently registered investment advisors which include
custody of securities, trade execution and clearance and settlement of transactions. The firm
receives some benefits from Schwab through its participation in the Schwab Advisor Services
program, as described in greater detail below.
DQR evaluates broker dealer/custodians based on our projected AUM and the best fit for our
business model. In considering which independent qualified custodian would be the best fit for
DQR’s business model, we evaluate the following factors, which is not an all-inclusive list:
Financial strength
Reputation
Reporting capabilities
Execution capabilities
Pricing, and
Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that
you establish an account with a brokerage firm with which we have an existing relationship.
Such relationships may include benefits provided to our firm, including, but not limited to
research, market information, and administrative services that help our firm manage your
account(s). We believe that recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by the recommended
broker-dealers, including the value of research provided, the firm’s reputation, execution
capabilities, commission rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these circumstances
a difference in commission charges may exist between the commissions charged to clients who
direct us to use a particular broker or dealer and other clients who do not direct us to use a
particular broker or dealer.
DQR does not receive client referrals from broker-dealers in exchange for cash or other
compensation, such as brokerage services or research.
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DQR does not formally participate in soft dollar arrangements, however the arrangement with
Schwab does include soft dollar benefits. This creates a conflict of interest as there is an
incentive for DQR to recommend Schwab based on the soft dollar benefits received rather than
the client’s needs. All clients receive the same benefits, and clients are not charged any more
from DQR or Schwab to get these benefits.
When DQR buys or sells the same security for two or more clients (including our personal
accounts), we may place concurrent orders to be executed together as a single “block” in order to
facilitate orderly and efficient execution. Each client account will be charged or credited with
the average price per unit. We receive no additional compensation or remuneration of any kind
because we aggregate client transactions. No client is favored over any other client. If an order
is not completely filled, it is allocated pro-rata based on an allocation statement prepared by
DQR prior to placing the order. Because of an order’s aggregation, some clients may pay higher
transaction costs, or greater spreads, or receive less favorable net prices on transactions than
would otherwise be the case if the order had not been aggregated.
Form ADV, Part 2A, Item 13
Review of Accounts
Client accounts are reviewed at least quarterly by Dale Q. Rice, Principal Executive Officer of
the firm. Dale Q. Rice reviews clients’ accounts with regards to their investment policies and risk
tolerance levels. All accounts at DQR are assigned to this reviewer.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
DQR does offer performance reporting at least annually. The reports include current
performance and will include historical performance as it develops. They provide a
comprehensive view, current balance and cost basis as well as offering a risk tolerance and
profile review to allow for any updates or changes.
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian. Clients are encouraged to review these statements to verify
accuracy and calculation correctness.
Form ADV, Part 2A, Item 14
Client Referrals and Other Compensation
DQR does not compensate any individual or firm for client referrals. In addition, DQR does not
receive compensation for referring clients to other professional service providers.
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Form ADV, Part 2A, Item 15
Custody
DQR does not have physical custody of any client funds and/or securities and does not take
custody of client accounts at any time. Client funds and securities will be held with a bank,
broker dealer, or other independent qualified custodian. However, by granting DQR written
authorization to automatically deduct fees from client accounts, DQR is deemed to have limited
custody. You will receive account statements from the independent, qualified custodian holding
your funds at least quarterly. The account statement from your custodian will indicate the
amount of advisory fees deducted from your account(s) each billing cycle. Clients should
carefully review statements received from the custodian. Clients are urged to compare the
account statements they receive from the qualified custodian with invoices and any
statements/reports they receive from the Adviser.
Standing Letters of Authorization Some clients may execute limited powers of attorney or
other standing letters of authorization that permit the firm to transfer money from their account
with the client’s independent qualified Custodian to third-parties. This authorization to direct the
Custodian may be deemed to cause our firm to exercise limited custody over your funds or
securities and for regulatory reporting purposes, we are required to keep track of the number of
clients and accounts for which we may have this ability. We will comply with the following:
1. The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
2. The client authorizes the investment adviser, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a specified
schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
4. The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
5. The investment adviser has no authority or ability to designate or change the identity of
the third party, the address, or any other information about the third party contained in the
client’s instruction.
6. The investment adviser maintains records showing that the third party is not a related
party of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction. We do not have physical custody
of any of your funds and/or securities. Your funds and securities will be held with a bank,
broker-dealer, or other independent, qualified custodian. You will receive account statements
from the independent, qualified custodian(s) holding your funds and securities at least quarterly.
The account statements from your custodian(s) will indicate any transfers that may have taken
place within your account(s) each billing period. You should carefully review account statements
for accuracy.
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Form ADV, Part 2A, Item 16
Investment Discretion
Before DQR can buy or sell securities on your behalf, you must first sign our discretionary
management agreement, a limited power of attorney, and/or trading authorization forms. By
choosing to do so, you may grant the firm discretion over the selection and amount of securities
to be purchased or sold for your account(s) without obtaining your consent or approval prior to
each transaction. Clients may impose limitations on discretionary authority for investing in
certain securities or types of securities (such as a product type, specific companies, specific
sectors, etc.), as well as other limitations as expressed by the client. Limitations on discretionary
authority are required to be provided to the IAR in writing. Please refer to the “Advisory
Business” section of this Brochure for more information on our discretionary management
services.
Form ADV, Part 2A, Item 17
Voting Client Securities
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you
advice regarding corporate actions and the exercise of your proxy voting rights. If you own
shares of common stock or mutual funds, you are responsible for exercising your right to vote as
a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in
the event we were to receive any written or electronic proxy materials, we would forward them
directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in
which case, we would forward any electronic solicitation to vote proxies.
Form ADV, Part 2A, Item 18
Financial Information
DQR is not required to provide financial information to our clients because we do not require or
solicit the prepayment of more than $1200 six or more months in advance.
DQR has not been the subject of a bankruptcy petition at any time during the past ten years and
does not have any financial condition that is reasonably likely to impair your ability to meet
contractual commitments to clients.
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Form ADV, Part 2A, Item 19
Requirements for State-Registered Advisers
This section is not applicable because the firm is registered with the Securities and Exchange Commission.
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