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Item 1: Cover Page
Rainier Family Wealth, Inc.
1102 Broadway Suite 312
Tacoma, WA 98402
253-448-2107
Form ADV Part 2A – Firm Brochure
Dated: February 23, 2026
This Brochure provides information about the qualifications and business practices of
Rainier Family Wealth, Inc.. If you have any questions about the contents of this
Brochure, please contact us at 253-448-2101. 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.
Rainier Family Wealth, Inc. is a registered investment adviser. Registration does not
imply a certain level of skill or training.
Additional information about Rainier Family Wealth, Inc. also is available on the SEC’s
website at www.adviserinfo.sec.gov, which can be found using the firm’s identification
number, 332062.
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Item 2: Material Changes
Since the previous annual filing of the Form ADV Part 2A for Rainier Family Wealth,
Inc. on February 19, 2025, the following material changes have been made to this
version of the brochure:
● Added language for Family Office Services in Items 4 & 5.
● Added language related to the use of Holistiplan for tax planning.
Future Changes From time to time, we may amend this Brochure to reflect changes in
our business practices, changes in regulations, and routine annual updates as required
by securities regulators. Either this complete Brochure or a Summary of Material
Changes shall be provided to each Client annually and if a material change occurs in
the business practices of Rainier Family Wealth, Inc.
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business
Item 5: Fees and Compensation
Item 6: Performance-Based Fees and Side-By-Side Management
Item 7: Types of Clients
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Item 9: Disciplinary Information
Item 10: Other Financial Industry Activities and Affiliations
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Item 12: Brokerage Practices
Item 13: Review of Accounts
Item 14: Client Referrals and Other Compensation
Item 15: Custody
Item 16: Investment Discretion
Item 17: Voting Client Securities
Item 18: Financial Information
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Item 4: Advisory Business
Description of Advisory Firm
Rainier Family Wealth, Inc. is an Investment Adviser principally located in the state of
Washington. We are an S-Corporation founded in November 2023. Rainier Family
Wealth, Inc. became registered in 2024. Jun Chea is the principal owner and Chief
Compliance Officer (“CCO”).
As used in this brochure, the words “RFW”, “we”, “our firm”, “Advisor” and “us”
refer to Rainier Family Wealth, Inc. and the words “you”, “your” and “Client” refer to
you as either a client or prospective client of our firm.
Types of Advisory Services
RFW is a fee-only firm, meaning the only compensation we receive is from our Clients
for our services. We offer Family Office Services, Wealth Management Services, and
Retirement Plan consulting. From time to time, RFW recommends third-party
professionals such as attorneys, accountants, tax advisors, insurance agents, or other
financial professionals. Clients are never obligated to utilize any third-party
professional we recommend. RFW is not affiliated with nor does RFW receive any
compensation from third-party professionals we may recommend.
Wealth Management Services
Wealth Management encompasses investment management services and financial
planning. Our firm provides continuous advice to a Client regarding the investment of
Client funds based on the individual needs of the Client. Through personal discussions
in which goals and objectives based on a Client’s particular circumstances are
established, we develop a Client’s personal investment policy or an investment
plan with an asset allocation target and create and manage a portfolio based on that
policy and allocation targets. We will also review and discuss a Client’s prior
investment history, as well as family composition and background. Account
supervision is guided by the stated objectives of the Client (e.g., maximum capital
appreciation, growth, income, or growth and income), as well as risk tolerance and tax
considerations.
We primarily advise our Clients regarding investments in stocks, bonds, mutual funds,
ETFs, U.S. government and municipal securities, and cash and cash equivalents. We
may also provide advice regarding investments held in Client’s portfolio at the
inception of our advisory relationship and/or other investment types not listed above,
at the Client’s request.
When we provide investment management services, Clients grant us limited authority
to buy and sell securities on a discretionary basis or non-discretionary basis. More
information on our trading authority is explained in Item 16 of this Brochure. Clients
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may impose reasonable restrictions in writing on investing in certain securities, types
of securities, or industry sectors.
In addition to managing investment portfolios directly, we will also provide ongoing
advice and supervision on accounts that the client chooses to have us monitor and
provide recommendations for but cannot be transferred to one of our recommended
custodians listed in Item 12. These accounts may include 529 Plans, 401(k) and other
employer sponsored tax qualified accounts, as well as other brokerage accounts that
the client maintains at other financial institutions (“held-away accounts”). This portion
of the service will include RFW’s selection of the appropriate investments based on
the options that are available for the clients’ held away account(s) and ongoing
monitoring and reporting on those accounts.
At no additional fee and at Client’s election, RFW also provides the Client with a
financial plan. A Client will be taken through establishing their goals and values
around money. Clients will be required to provide pertinent information to help
complete the following areas of analysis: net worth, cash flow, insurance, credit
scores/reports, employee benefits, retirement planning, insurance, investments, college
planning, and estate planning. Once the Client’s information is reviewed, their plan will
be built and analyzed, and then the findings, analysis and potential changes to their
current situation will be reviewed with the Client. Clients will receive a detailed
financial plan designed to help achieve Client’s stated financial goals and objectives.
The plan and the Client’s financial situation and goals will be monitored throughout
the year.
In general, the financial plan will address some or all of the following areas of concern.
The Client and RFW will work together to select specific areas to cover. These areas
may include, but are not limited to, the following:
● Business Planning: We provide consulting services for Clients who currently
operate their own business, are considering starting a business, or are planning for
an exit from their current business. Under this type of engagement, we work with
you to assess your current situation, identify your objectives, and develop a plan
aimed at achieving your goals.
● Cash Flow and Debt Management: We will conduct a review of your income and
expenses to determine your current surplus or deficit along with advice on
prioritizing how any surplus should be used or how to reduce expenses if they
exceed your income. Advice may also be provided on which debts to pay off first
based on factors such as the interest rate of the debt and any income tax
ramifications. We may also recommend what we believe to be an appropriate cash
reserve that should be considered for emergencies and other financial goals, along
with a review of accounts (such as money market funds) for such reserves, plus
strategies to save desired amounts.
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● College Savings: Includes projecting the amount that will be needed to achieve
college or other post-secondary education funding goals, along with advice on ways
for you to save the desired amount. Recommendations as to savings strategies are
included, and, if needed, we will review your financial picture as it relates to
eligibility for financial aid or the best way to contribute to children and
grandchildren (if appropriate).
● Employee Benefits Optimization: We will provide review and analysis as to
whether you, as an employee, are taking the maximum advantage possible of your
employee benefits. If you are a business owner, we will consider and/or recommend
the various benefit programs that can be structured to meet both business and
personal retirement goals.
● Estate Planning: This usually includes an analysis of your exposure to estate taxes
and your current estate plan, which may include whether you have a will, powers of
attorney, trusts, and other related documents. Our advice also typically includes ways
for you to minimize or avoid future estate taxes by implementing appropriate estate
planning strategies such as the use of applicable trusts. We always recommend that
you consult with a qualified attorney when you initiate, update, or complete estate
planning activities. We may provide you with contact information for attorneys who
specialize in estate planning when you wish to hire an attorney for such purposes.
From time-to-time, we will participate in meetings or phone calls between you and
your attorney with your approval or request.
● Financial Goals: We will help Clients identify financial goals and develop a plan to
reach them. We will identify what you plan to accomplish, what resources you will
need to make it happen, how much time you will need to reach the goal, and how
much you should budget for your goal.
● Insurance: Review of existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home, and automobile.
● Investment Analysis: This may involve developing an asset allocation strategy to
meet Clients’ financial goals and risk tolerance, providing information on investment
vehicles and strategies, reviewing employee stock options, as well as assisting you in
establishing your own investment account at a selected broker/dealer or custodian.
The strategies and types of investments we may recommend are further discussed in
Item 8 of this brochure.
● Retirement Planning: Our retirement planning services typically include
projections of your likelihood of achieving your financial goals, typically focusing on
financial independence as the primary objective. For situations where projections
show less than the desired results, we may make recommendations, including those
that may impact the original projections by adjusting certain variables (e.g., working
longer, saving more, spending less, taking more risk with investments).
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If you are near retirement or already retired, advice may be given on appropriate
distribution strategies to minimize the likelihood of running out of money or having
to adversely alter spending during your retirement years.
● Risk Management: A risk management review includes an analysis of your
exposure to major risks that could have a significant adverse impact on your
financial picture, such as premature death, disability, property and casualty losses, or
the need for long-term care planning. Advice may be provided on ways to minimize
such risks and about weighing the costs of purchasing insurance versus the benefits
of doing so and, likewise, the potential cost of not purchasing insurance
(“self-insuring”).
● Tax Planning Strategies: Advice may include ways to minimize current and future
income taxes as a part of your overall financial planning picture. For example, we
may make recommendations on which type of account(s) or specific investments
should be owned based in part on their “tax efficiency,” with the consideration that
there is always a possibility of future changes to federal, state or local tax laws and
rates that may impact your situation.
We recommend that you consult with a qualified tax professional before initiating
any tax planning strategy, and we may provide you with contact information for
accountants or attorneys who specialize in this area if you wish to hire someone for
such purposes. We will participate in meetings or phone calls between you and your
tax professional with your approval.
● Third-party tools (e.g., Holistiplan for tax analysis summaries) may be used to
support the planning process. These outputs are for planning purposes only
and do not constitute legal, tax-preparation, valuation, insurance, or
transaction advice. Clients should engage qualified independent
professionals for such services.
Family Office Services
Family Office Services are tailored to each Family Client. RFW will have thorough,
personal discussions with the Family Client to ensure the services RFW provides for
the Family Client are customized to the Family Client’s needs and goals. Potential
specific services RFW may provide a Family Client may include, but are not limited to,
portfolio management, tax planning, charitable planning, and coordination of private
travel.
Client Tailored Services and Client Imposed Restrictions
We tailor the delivery of our services to meet the individual needs of our Clients. We
consult with Clients initially and on an ongoing basis, through the duration of their
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engagement with us, to determine risk tolerance, time horizon and other factors that
may impact the Clients’ investment and/or planning needs.
Clients are able to specify, within reason, any restrictions they would like to place as it
pertains to individual securities and/or sectors that will be traded in their account. All
such requests must be provided to RFW in writing. RFW will notify Clients if they are
unable to accommodate any requests.
Wrap Fee Programs
We do not participate in wrap fee programs.
Assets Under Management
As of December 31, 2025, RFW has $327,449,178 in discretionary and $4,024,413 in
non-discretionary assets under management.
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Item 5: Fees and Compensation
Please note, unless a Client has received this brochure at least 48 hours prior to signing
an Advisory Contract, the Advisory Contract may be terminated by the Client within
five (5) business days of signing the Advisory Contract without penalty or incurring
any fees.
How we are paid depends on the type of advisory services we perform. Below is a
brief description of our fees, however, you should review your executed Advisory
Contract for more detailed information regarding the exact fees you will be paying. No
increase to the agreed-upon advisory fees outlined in the Advisory Contract shall
occur without prior Client consent
Wealth Management Services
The fee is based on a percentage of assets under management and is negotiable. The
annualized fees for investment management services are based on the following fee
schedule:
Assets Under Management
Annual Advisory Fee
$0 - $2,000,000
1.00%
$2,000,001 - $5,000,000
0.80%
$5,000,001 - $10,000,000
0.65%
$10,000,001 and Above
0.50%
The annual advisory fee is paid quarterly in advance based on the value of Client’s
account(s) as of the last day of the billing period. The advisory fee is a blended tier.
For example, for assets under management of $3,000,000, a Client would pay 1.00%
on the first $2,000,000 and 0.80% on the remaining balance. The quarterly fee is
determined by the following calculation: (($2,000,000 x 1.00%) + ($1,000,000 x
0.80%)) ÷ 4 = $7,000.
In determining the advisory fee, we may allow accounts of members of the same
household to be aggregated. RFW relies on the valuation as provided by Client’s
custodian in determining assets under management. Our advisory fee is prorated for
any partial billing periods occurring during the engagement, including the initial and
terminating billing periods. Clients may make additions or withdrawals from their
account at any time; however, RFW reserves the right to adjust our advisory fees on a
pro-rata basis on account of any such cash-flow transactions.
We charge a fee of 0.50% for providing ongoing advice and supervision on accounts
that the client chooses to have us monitor and provide recommendations for but
cannot be transferred to one of our recommended custodians listed in Item 12.
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Family Office Services
Our fees for our Family Office Services are largely dependent on the scope of
services we provide to each Family Office Client, and clients will be billed either a
fee based on the account’s assets under management, an hourly fee, or a flat fee.
Specific fees and billing procedures will be agreed upon with the Family Office
Client and disclosed in the advisory agreement signed by the Family Office Client.
Hourly fees will not exceed $500, and annual flat fees will not exceed $500,000.
Annual fees based on the assets under management fees will be negotiable based
on the following fee schedule:
Assets Under Management
Annual Advisory Fee
$0 - $25,000,000
0.65%
$25,000,001 - $50,000,000
0.55%
$50,000,001 - $75,000,000
0.45%
$75,000,001 - $100,000,000
0.40%
$100,000,001 and Above
0.30%
Fee Payment
We deduct our advisory fee from one or more account(s) held at an unaffiliated
third-party custodian, as directed by the Client. Please refer to Item 15 of this
Brochure regarding our policy on direct fee deduction. Clients may also pay by
electronic funds transfer (EFT) or check. We use an independent third party payment
processor in which the Client can securely input their payment information to pay
their fee. We do not have access to the Client’s banking or credit information at any
time. The Client will be provided with their own secure portal in order to make
payments.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which may be incurred by the Client. Clients may incur certain
charges imposed by custodians, brokers, and other third parties such as custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Mutual fund and exchange-traded funds also charge internal management fees, which
are disclosed in a fund's prospectus. Such charges, fees, and commissions are exclusive
of and in addition to our fee, and we shall not receive any portion of these
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commissions, fees, and costs. As a courtesy to our clients, we will refund wire transfer
fees.
Item 12 further describes the factors that we consider in selecting or recommending
custodians for Client’s transactions and determining the reasonableness of their
compensation (e.g., commissions).
Clients may incur fees from third-party professionals such as accountants and
attorneys that RFW may recommend, upon Client request. Such fees are separate and
distinct from RFW’s advisory fees.
Terminations and Refunds
The Advisory Contract may be terminated with written notice at least 30 calendar days
in advance. Upon termination of the Advisory Contract, a prorated refund will be
provided to the Client. Clients will be responsible for payment of fees up to the date
of termination.
Sale of Securities or Other Investment Products
Advisor and its supervised persons do not accept compensation for the sale of
securities or other investment products including asset-based sales charges or service
fees from the sale of mutual funds.
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Item 6: Performance-Based Fees and Side-By-Side Management
We do not offer performance-based fees and do not engage in side-by-side
management.
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Item 7: Types of Clients
We provide financial planning and investment management services to individuals,
high net-worth individuals, charitable organizations, corporations or other businesses.
Our minimum AUM relationship size requirement is $500,000 to engage our firm for
Wealth Management Services. Our minimum AUM relationship size requirement for
Family Office Services is $25,000,000. RFW may reduce or waive the minimum
account size requirement on a case-by-case basis.
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Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Below is a brief description of our methods of analysis and primary investment
strategies.
Methods of Analysis
Fundamental analysis involves analyzing individual companies and their industry
groups, such as a company’s financial statements, details regarding the company’s
product line, the experience, and expertise of the company’s management, and the
outlook for the company’s industry. The resulting data is used to measure the true
value of the company’s stock compared to the current market value. The risk of
fundamental analysis is that the information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a
stock’s value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative
strength in an effort to pick sectors that may outperform market indices. However,
there is no assurance of accurate forecasts or that trends will develop in the markets
we follow. In the past, there have been periods without discernible trends and similar
periods will presumably occur in the future. Even where major trends develop, outside
factors like government intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement
data, which can translate into price trends sufficient to dictate a market entry or exit
decision. In a trendless or erratic market, a technical method may fail to identify trends
requiring action. In addition, technical methods may overreact to minor price
movements, establishing positions contrary to overall price trends, which may result in
losses. Finally, a technical trading method may underperform other trading methods
when fundamental factors dominate price moves within a given market.
Cyclical analysis involves the gathering and processing of price and volume
information for a particular security. This price and volume information is analyzed
using mathematical equations. The resulting data is then applied to graphing charts,
which is used to predict future price movements based on price patterns and trends.
Charts may not accurately predict future price movements. Current prices of securities
may not reflect all information 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.
Charting analysis involves the gathering and processing of price and volume
information for a particular security. This price and volume information is analyzed
using mathematical equations. The resulting data is then applied to graphing charts,
which is used to predict future price movements based on price patterns and trends.
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Charts may not accurately predict future price movements. Current prices of securities
may not reflect all information 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.
Modern Portfolio Theory (MPT)
The underlying principles of MPT are:
1. Investors are risk averse. The only acceptable risk is that which is adequately
compensated by an expected return. Risk and investment return are related
and an increase in risk requires an increased expected return.
2. Markets are efficient. The same market information is available to all investors
at the same time. The market prices every security fairly based upon this equal
availability of information.
The design of the portfolio as a whole is more important than the selection of
any particular security. The appropriate allocation of capital among asset
classes will have far more influence on long-term portfolio performance than
the selection of individual securities.
3. Investing for the long-term (preferably longer than ten years) becomes critical
to investment success because it allows the long-term characteristics of the
asset classes to surface.
4. Increasing diversification of the portfolio with lower correlated asset class
positions can decrease portfolio risk. Correlation is the statistical term for the
extent to which two asset classes move in tandem or opposition to one
another.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of
the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic
conditions. We also look at the underlying assets in a mutual fund or ETF in an
attempt to determine if there is significant overlap in the underlying investments held
in other funds in the Client’s portfolio. In addition, we monitor the funds or ETFs in
an attempt to determine if they are continuing to follow their stated investment
strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful
may not be able to replicate that success in the future. In addition, as we do not
control the underlying investments in a fund or ETF, managers of different funds held
by the client may purchase the same security, increasing the risk to the client if that
security were to fall in value. There is also a risk that a manager may deviate from the
stated investment mandate or strategy of the fund or ETF, which could make the fund
or ETF less suitable for the Client’s portfolio.
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Investment Strategies
Asset Allocation
In implementing our Clients’ investment strategy, we begin by attempting to identify
an appropriate ratio of equities, fixed income, and cash (i.e. “asset allocation”) suitable
to the Client’s investment goals and risk tolerance.
A risk of asset allocation is that the Client may not participate in sharp increases in a
particular security, industry or market sector. Another risk is that the ratio of equities,
fixed income, and cash will change over time due to stock and market movements and,
if not corrected, will no longer be appropriate for the Client’s goals. We attempt to
closely monitor our asset allocation models and make changes periodically to keep in
line with the target risk tolerance model.
Passive Investment Management
Passive investing involves building portfolios that are composed of various distinct
asset classes. The asset classes are weighted in a manner to achieve the desired
relationship between correlation, risk, and return. Funds that passively capture the
returns of the desired asset classes are placed in the portfolio. The funds that are used
to build passive portfolios are typically index mutual funds or exchange-traded funds.
Passive investment management is characterized by low portfolio expenses (i.e. the
funds inside the portfolio have low internal costs), minimal trading costs (due to
infrequent trading activity), and relative tax efficiency (because the funds inside the
portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ
some method, strategy or technique to construct a portfolio that is intended to
generate returns that are greater than the broader market or a designated benchmark.
Passive and Active Investment Management
We may choose investment vehicles that are considered passive, active, or a
combination of both styles.
Passive investing involves building portfolios that are composed of various distinct
asset classes. The asset classes are weighted in a manner to achieve a desired
relationship between correlation, risk and return. Funds that passively capture the
returns of the desired asset classes are placed in the portfolio.
Active investing involves a single manager or managers who employ some method,
strategy or technique to construct a portfolio that is intended to generate returns that
are greater than the broader market or a designated benchmark. Actively managed
funds are also designed to reduce volatility and risk.
We may engage in both passive and active investing in the Client's portfolio. However,
we strive to construct portfolios of funds and individual securities that we believe will
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have the greatest probability for achieving our Clients’ personal financial goals with
the least amount of volatility and risk rather than attempt to outperform an arbitrary
index or benchmark.
Specific investment selections are based on a number of factors that we evaluate in
order to select, what we believe to be, the highest quality funds or individual securities
for our Clients. These factors include but are not limited to underlying holdings of
funds, percentage weighting of holdings within funds, liquidity, tax efficiency, bid/ask
spreads, and other smart/strategic beta factors. These factors may or may not result in
the lowest cost ETFs and mutual funds available when utilizing funds in a Client’s
portfolio, but we strive to keep internal fund expenses as low as possible.
Socially Responsible Investing
We may utilize various socially conscious investment approaches if a Client desires.
RFW may construct portfolios that utilize mutual funds, ETFs, or individual securities
with the purpose of incorporating socially conscious principles into a Client’s
portfolio. These portfolios may sometimes also be customized to reflect the personal
values of each indi`vidual, family, or organization. This allows our Clients to invest in a
way that aligns with their values. RFW may rely on mutual funds and ETFs that
incorporate Environmental, Social and Governance (“ESG”) research as well as
positive and negative screens related to specific business practices to determine the
quality of an investment on values-based merits. Additionally, RFW may construct
portfolios of individual securities in order to provide Clients with a greater degree of
control over the socially conscious strategies they are utilizing. RFW relies on
third-party research when constructing portfolios of individual securities with socially
conscious considerations.
If you request your portfolio to be invested according to socially conscious principles,
you should note that returns on investments of this type may be limited and because
of this limitation you may not be able to be as well diversified among various asset
classes. The number of publicly traded companies that meet socially conscious
investment parameters is also limited, and due to this limitation, there is a probability
of similarity or overlap of holdings, especially among socially conscious mutual funds
or ETFs. Therefore, there could be a more pronounced positive or negative impact on
a socially conscious portfolio, which could be more volatile than a fully diversified
portfolio.
Long-term/Short-term purchases
We purchase securities and generally hold them in the Client's account for a year or
longer. Short-term purchases may be employed as appropriate when:
● We believe the securities to be currently undervalued, and/or
● We want exposure to a particular asset class over time, regardless of the current
projection for this class.
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A risk in a long-term purchase strategy is that by holding the security for this length of
time, we may not take advantage of short-term gains that could be profitable to a
client. Moreover, if our predictions are incorrect, a security may decline sharply in
value before we make the decision to sell.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your
original investment which you should be prepared to bear. Many of these risks
apply equally to stocks, bonds, commodities, and any other investment or security.
Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market
value will fall because of a general market decline, reducing the value of the investment
regardless of the operational success of the issuer’s operations or its financial
condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may
not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and
medium market capitalizations are often more volatile and less liquid than investments
in larger companies. Small and medium cap companies may face a greater risk of
business failure, which could increase the volatility of the Client’s portfolio.
Turnover Risk: Actively managed mutual funds tend to have a higher turnover rate
than passive funds. A high portfolio turnover would result in higher transaction costs
and in higher taxes when shares are held in a taxable account. These factors may
negatively affect the account’s performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their
prices may at times be more volatile than at other times. Under certain market
conditions, we may be unable to sell or liquidate investments at prices we consider
reasonable or favorable or find buyers at any price.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise,
and the value may fall below par value or the principal investment. The opposite is
also generally true: bond prices generally rise when interest rates fall. In general, fixed
income securities with longer maturities are more sensitive to these price changes.
Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value
of investments, or the securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if
the dollar value of your investments remains the same.
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MPT Risk: Market risk is that part of a security's risk that is common to all securities
of the same general class (stocks and bonds) and thus cannot be eliminated by
diversification.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments,
specific securities may have other risks.
Common Stocks may go up and down in price quite dramatically, and in the event of
an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or
recessionary economic environment could have an adverse effect on the price of all
stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay
investors periodic interest and repay the amount borrowed either periodically during
the life of the security and/or at maturity. Alternatively, investors can purchase other
debt securities, such as zero coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time
to face value at maturity. The market prices of debt securities fluctuate depending on
factors such as interest rates, credit quality, and maturity. In general, market prices of
debt securities decline when interest rates rise and increase when interest rates fall.
The longer the time to a bond’s maturity, the greater its interest rate risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due
to market conditions. Certain Exchange Traded Funds may not track underlying
benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s
shares may trade at a market price that is above (premium) or below (discount) their
net asset value and an ETF purchased at a premium may ultimately be sold at a
discount; (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials
deem such action appropriate, the shares are delisted from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock
prices) halts stock trading generally. The Adviser has no control over the risks taken by
the underlying funds in which the Clients invest.
Municipal Bonds are debt obligations generally issued to obtain funds for various
public purposes, including the construction of public facilities. Municipal bonds pay a
lower rate of return than most other types of bonds. However, because of a municipal
bond’s tax-favored status, investors should compare the relative after-tax return to the
after-tax return of other bonds, depending on the investor’s tax bracket. Investing in
municipal bonds carries the same general risks as investing in bonds in general. Those
risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or
redemption risk, credit risk, and liquidity and valuation risk.
Mutual Funds 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
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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).
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Item 9: Disciplinary Information
Criminal or Civil Actions
RFW and its management persons have not been involved in any criminal or civil
action.
Administrative Enforcement Proceedings
RFW and its management persons have not been involved in any administrative
enforcement proceedings.
Self-Regulatory Organization Enforcement Proceedings
RFW and its management persons have not been involved in any self-regulatory
organization (SRO) proceedings.
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Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
Neither RFW or its management persons is registered, or have an application pending
to register, as a broker-dealer or a registered representative of a broker-dealer.
Other Affiliations
Neither RFW or its management persons is registered, or have an application pending
to register, as a futures commission merchant, commodity pool operator, commodity
trading advisor, or an associated person of the foregoing entities.
Related Persons
Neither RFW or its management persons have any relationship or arrangement with
any outside financial industry related parties.
Recommendations or Selections of Other Investment Advisers
RFW does not recommend or select other investment advisers for our clients.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
As a fiduciary, our firm has a duty of utmost good faith to act solely in the best
interests of each Client. Our Clients entrust us with their funds and personal
information, which in turn places a high standard on our conduct and integrity. Our
fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis
of all of our dealings. The firm also adheres to the Code of Ethics and Professional
Responsibility adopted by the CFP® Board of Standards Inc., and accepts the
obligation not only to comply with the mandates and requirements of all applicable
laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This Code of Ethics does not attempt to identify all possible conflicts of interest, and
compliance with each of its specific provisions will not shield our firm or its access
persons from liability for misconduct that violates a fiduciary duty to our Clients. A
summary of the Code of Ethics' Principles is outlined below.
● Integrity - Access persons shall offer and provide professional services with
integrity.
● Objectivity - Access persons shall be objective in providing professional
services to Clients.
● Competence - Access persons shall provide services to Clients competently
and maintain the necessary knowledge and skill to continue to do so in those
areas in which they are engaged.
● Fairness - Access persons shall perform professional services in a manner that
is fair and reasonable to Clients, principals, partners, and employers, and shall
disclose conflict(s) of interest in providing such services.
● Confidentiality - Access persons shall not disclose confidential Client
information without the specific consent of the Client unless in response to
proper legal process, or as required by law.
● Professionalism - Access persons conduct in all matters shall reflect the credit
of the profession.
● Diligence - Access persons shall act diligently in providing professional
services.
We periodically review and amend our Code of Ethics to ensure that it remains
current, and we require all firm access persons to attest to their understanding of and
adherence to the Code of Ethics at least annually. Our firm will provide a copy of its
Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and
Conflicts of Interest
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Neither our firm, its access persons, or any related person is authorized to recommend
to a Client or effect a transaction for a Client, involving any security in which our firm
or a related person has a material financial interest, such as in the capacity as an
underwriter, adviser to the issuer, principal transaction, among others.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Our firm, its access persons, and its related persons may buy or sell securities similar
to, or different from, those we recommend to Clients. In an effort to reduce or
eliminate certain conflicts of interest, our Code of Ethics may require that we restrict
or prohibit access persons’ transactions in specific reportable securities. Any
exceptions or trading pre-clearance must be approved by RFW’s Chief Compliance
Officer in advance of the transaction in an account. RFW maintains a copy of access
persons’ personal securities transactions as required.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time our firm, its access persons, or its related persons may buy or sell
securities for themselves at or around the same time as they buy or sell securities for
Clients’ account(s). To address this conflict, it is our policy that neither our firm or
access persons shall have priority over Clients’ accounts in the purchase or sale of
securities.
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Item 12: Brokerage Practices
Factors Used to Select Custodians
RFW does not have any affiliation with any custodian we recommend. Specific
custodian recommendations are made to the Client based on their need for such
services. We recommend custodians based on the reputation and services provided by
the firm.
In recommending custodians, we have an obligation to seek the “best execution” of
transactions in Client accounts. The determinative factor in the analysis of best
execution is not the lowest possible commission cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of the
custodian’s services. The factors we consider when evaluating a custodian for best
execution include, without limitation, the custodian’s:
● Combination of transaction execution services and asset custody services
(generally without a separate fee for custody);
● Capability to execute, clear, and settle trades (buy and sell securities for your
account);
● Capability to facilitate transfers and payments to and from accounts (wire
transfers, check requests, bill payment, etc.);
● Breadth of available investment products (stocks, bonds, mutual funds,
exchange-traded funds (ETFs), etc.);
● Availability of investment research and tools that assist us in making
investment decisions;
● Quality of services;
● Competitiveness of the price of those services (commission rates, margin
interest rates, other fees, etc.) and willingness to negotiate the prices;
● Reputation, financial strength, security and stability;
● Prior service to us and our clients.
With this in consideration, our firm recommends Fidelity Brokerage Services, LLC
(“Fidelity”), an independent and unaffiliated SEC registered broker-dealer firm and
member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities
Investor Protection Corporation (“SIPC”).
Research and Other Soft-Dollar Benefits
We do not have any soft-dollar arrangements with custodians whereby soft-dollar
credits, used to purchase products and services, are earned directly in proportion to
the amount of commissions paid by a Client. However, as a result of being on their
institutional platform, Fidelity may provide us with certain services that may benefit
us.
RFW has an arrangement with National Financial Services, LLC, and Fidelity
Brokerage Services, LLC (together with all affiliates, “Fidelity”) through which Fidelity
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provides RFW with Fidelity’s “platform” services. The platform services include,
among others, brokerage, custodial, administrative support, record keeping and related
services that are intended to support intermediaries like RFW in conducting business
and in serving the best interests of their clients, but that may benefit RFW.
1. SERVICES THAT BENEFIT YOU. Fidelity provides access to a range of
investment products, execution of securities transactions, and custody of
client assets through National Financial Services, LLC and Fidelity Brokerage,
LLC. Also, Fidelity provides discount brokerage rates that are generally lower
than retail investor rates. Fidelity services described in this paragraph generally
benefit you and your account.
2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Fidelity
also makes available to us other products and services that benefit us, but may
not directly benefit you or your account. These products and services assist
us in managing and administering our clients’ accounts, such as software and
technology that may:
● Assist with back-office functions, recordkeeping, and client reporting of
our clients’ accounts.
● Provide access to client account data (such as duplicate trade
confirmations and account statements).
● Provide pricing and other market data.
● Assist with back-office functions, recordkeeping, and client reporting.
● Investment research.
● Access to Fidelity’s trading desk for Advisors.
● Access to block trading.
3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using
Fidelity, we will be offered other services intended to help us manage and
further develop our business enterprise. These services include:
● Educational conferences and events.
● Consulting on technology, compliance, legal, and business needs.
● Publications and conferences on practice management and business
succession.
● Vendor discounts to purchase business services, such as consulting,
marketing and branding, technology support and other similar business
services.
4. YOUR BROKERAGE AND CUSTODY COSTS. Fidelity charges
brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual
funds, commissions are charged for individual equity and debt securities
transactions). Fidelity enables RFW to obtain many no-load mutual funds
without transaction charges and other no-load funds at nominal transaction
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charges. Fidelity’s commission rates are generally considered discounted from
customary retail commission rates. However, the commissions and transaction
fees charged by Fidelity may be higher or lower than those charged by other
custodians.
As part of its fiduciary duties to clients, RFW endeavors at all times to put the interests
of its clients first. Clients should be aware, however, that the receipt of economic
benefits by RFW or its related persons in and of itself creates a potential conflict of
interest and may indirectly influence RFW’s choice of Fidelity for custody and
brokerage services.
Brokerage for Client Referrals
We receive no referrals from a custodian, broker-dealer or third party in exchange for
using that custodian, broker-dealer or third party.
Clients Directing Which Broker/Dealer/Custodian to Use
Our firm requires Clients establish account(s) at Fidelity to execute transactions
through. We will assist with establishing your account(s) at Fidelity, however, we will
not have the authority to open accounts on the Client's behalf. Not all investment
advisers require their Clients to use their recommended custodian. By requiring that
Clients use Fidelity, we may be unable to achieve most favorable execution of Client
transactions, and this practice may cost Clients more money. We base our
recommendations on the factors disclosed in Item 12 herein and will only recommend
custodians if we believe it's in the best interest of the Client.
We do not permit Clients to direct brokerage (direct us to a broker-dealer of your
choosing).
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for
advisory accounts we manage (this practice is commonly referred to as “block
trading”). We will then distribute a portion of the shares to participating accounts in a
fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance
or the amount or structure of management fees. Subject to our discretion, regarding
particular circumstances and market conditions, when we combine orders, each
participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs. Accounts owned by our firm or access
persons may participate in block trading with your accounts; however, they will not be
given preferential treatment.
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Item 13: Review of Accounts
Periodic Reviews
Jun Chea, President and CCO of RFW, will work with Clients to obtain current
information regarding their assets and investment holdings and will review this
information as part of our financial planning services. RFW does not provide specific
reports to Clients, other than financial plans. Clients who engage us for investment
management services will have their account(s) reviewed not less than annually by the
Client’s advisor. The account(s) are reviewed with regards to the Client’s investment
objectives and risk tolerance levels.
Triggers of Reviews
Events that may trigger a special review would be unusual performance, addition or
deletions of Client-imposed restrictions, excessive draw-down, volatility in
performance, or buy and sell decisions from the firm or per Client's needs.
Review Reports
Clients will receive trade confirmations from the custodian(s) for each transaction in
their accounts as well as monthly or quarterly statements and annual tax reporting
statements from their custodian showing all activity in the accounts, such as receipt of
dividends and interest.
RFW will provide written performance and/or holdings reports to Investment
Management Clients on at least an annual basis. We urge Clients to compare these
reports against the account statements they receive from their custodian.
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Item 14: Client Referrals and Other Compensation
Compensation Received by Rainier Family Wealth, Inc.
RFW is a fee-only firm that is compensated solely by its Clients. RFW does not receive
commissions or other sales-related compensation. Except as mentioned in Item 12
above, we do not receive any economic benefit, directly or indirectly, from any third
party for advice rendered to our Clients.
Client Referrals from Solicitors
RFW does not, directly or indirectly, compensate any person who is not advisory
personnel for Client referrals.
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Item 15: Custody
RFW does not hold, directly or indirectly, Client funds or securities, or have any
authority to obtain possession of them. All Client assets are held at a qualified
custodian.
If RFW deducts its advisory fee from Client’s account(s), the following safeguards will
be applied:
i. The Client will provide written authorization to RFW, permitting us to be paid
directly from Client’s accounts held by the custodian.
ii. The custodian will send at least quarterly statements to the Client showing all
disbursements from the accounts, including the amount of the advisory fee.
We urge you to carefully review custodial statements and compare them to the account
invoices or reports that we may provide to you and notify us of any discrepancies.
Clients are responsible for verifying the accuracy of these fees as listed on the
custodian’s brokerage statement as the custodian does not assume this responsibility.
Our invoices or reports may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
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Item 16: Investment Discretion
or those Client accounts where we provide Investment Management Services, RFW
has discretionary authority and limited power of attorney to determine the securities
and the amount of securities to be bought or sold for a Client’s account without
having to obtain prior Client approval for each transaction. Investment discretion is
explained to Clients in detail when an advisory relationship has commenced. At the
start of the advisory relationship, the Client will execute a Limited Power of Attorney,
which will grant our firm discretion over the account(s). Additionally, the discretionary
relationship will be outlined in the Advisory Contract and signed by the Client. Clients
may limit our discretion by requesting certain restrictions on investments. However,
approval of such requests are at the firm’s sole discretion.
If you enter into non-discretionary arrangements with our firm, we will obtain your
approval prior to the execution of any transactions for your account(s). You have an
unrestricted right to decline to implement any advice provided by our firm on a
non-discretionary basis.
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Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for:
(1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s
investment assets. The Client shall instruct the Client’s qualified custodian to forward
to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets. If the Client has any questions on a particular proxy vote,
they may contact us at the number listed on the cover of this brochure.
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 you any electronic
solicitation to vote proxies.
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Item 18: Financial Information
We have no financial commitment that impairs our ability to meet contractual and
fiduciary commitments to our Clients, nor have we been the subject of any bankruptcy
proceeding. We do not have custody of Client funds or securities, except as disclosed
in Item 15 above, or require or solicit prepayment of more than $1,200 in fees six
months or more in advance.
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