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Item 1. Cover Page
Part 2A of Form ADV: Firm Brochure
Redmont Wealth Advisors LLC
444 W Lake St #1900
Chicago, IL 60606
Telephone: (312) 848-1136
Email:jlanger@redmontwealth.com
Web Address: www.redmontwealth.com
June 2, 2025
This brochure provides information about the qualifications and business practices of Redmont
Wealth Advisors LLC. If you have any questions about the contents of this brochure, please
contact us at jlanger@redmontwealth.com or by telephone at (312) 848-1136. The information
in this brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
Redmont Wealth Advisors LLC is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training.
Additional information about Redmont Wealth Advisors is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a
CRD number. The firm’s CRD number is 310981.
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Item 2. Material Changes
The material changes since the last annual updating amendment of Redmont Wealth Advisors,
LLC in March 2025 are described below. Material changes relate to Redmont Wealth Advisors,
LLC’s policies, practices or conflicts of interest.
• Since our last annual update, Redmont has added a new optional service offering related to
estate planning. Specifically, we may now recommend that clients utilize a self-preparation
will or trust software platform provided by a third-party vendor. This service is offered at a flat
fee, which is paid by the client. Redmont receives this fee for providing access to the
platform. Use of this service is entirely optional, and clients are encouraged to consult with a
qualified attorney for legal advice.
We encourage clients to review the full brochure for additional details.
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Item 3.Table of Contents
Item 1.
Cover Page ............................................................................................................... 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 ...................................... 6
Item 7.
Types of Clients ....................................................................................................... 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............................... 7
Item 9.
Disciplinary Information ......................................................................................... 14
Item 10. Other Financial Industry Activities and Affiliations ............................................... 14
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 14
Item 12. Brokerage Practices ............................................................................................... 15
Item 13. Review of Accounts ............................................................................................... 17
Item 14. Client Referrals and Other Compensation ............................................................ 18
Item 15. Custody ................................................................................................................... 18
Item 16.
Investment Discretion ............................................................................................. 18
Item 17. Voting Client Securities ......................................................................................... 19
Item 18. Financial Information ............................................................................................. 19
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Item 4. Advisory Business
Redmont Wealth Advisors LLC (“Redmont,” “firm,” “we,” “us” or “our”) is an SEC-registered
investment adviser with its principal place of business located in Chicago, Illinois. The firm began
conducting business in 2020. The firm is principally owned by James Langer in addition to two
minority owners, William Edwin Brancovsky and Herbert Scott Pressly. Mr. Langer serves as
Chief Investment Officer and Chief Compliance Officer of the firm and is responsible for the
investment advisory functions of the firm.
The firm provides a personalized, objective and responsive approach to assist clients in planning
their financial objectives. The firm’s objective is to design personalized programs to help clients
reach their life and financial goals.
The 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 strategy and create and manage a portfolio based on that strategy. During this
process, we determine the client’s individual objectives, time horizons, risk tolerance and liquidity
needs. As appropriate, we also review and discuss a client’s prior investment history, as well as
family composition and background.
We generally manage client assets on a discretionary basis. Account supervision is guided by
the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and
income), which may include certain tax considerations. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors.
While our advisory services generally focus on portfolios of listed equities, fixed income
instruments, mutual funds, exchange-traded funds (“ETFs”) and closed-end funds, our investment
recommendations are not limited to any specific security type.
We also may provide our clients with access to third-party advisers, including advisers of private
funds (each a “sub-adviser”). This service provides clients access to a wide range of investment
opportunities and asset classes, including, but not limited to, international equities, emerging
market equities, global fixed income and high-yield fixed income, private equity and options-
related products. By combining sub-advisers with our in-house resources, we seek to optimize
our customized portfolio management capabilities for clients. Where client assets are allocated
to a sub-adviser, the sub-adviser has discretionary authority for the day-to-day management of
the assets.
We also provide financial planning services on a limited basis. Financial planning is a
comprehensive evaluation of a client’s current and future financial state by using currently known
variables to predict future cash flows, asset values and withdrawal plans. Financial planning
clients receive an analysis which provides the client with a detailed financial plan designed to
assist the client in achieving his or her financial goals and objectives. Where we only provide
financial planning services to a client, we are not responsible for the implementation of any
investment recommendations.
Our Financial planning services may incorporate a recommendation that our clients take
advantage of a self-preparation will or trust SaaS product that we have obtained access to from
a third-party vendor. Neither that vendor nor we are engaged in the practice of law and any will
or trust that may be created by a client using this software service is created solely by the client
without any legal advice or guidance from us or from the vendor. Clients who have legal
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questions regarding their preparation of a will or trust in this or any other manner are strongly
encouraged to seek the advice of an attorney licensed to practice in the jurisdiction where the
client is domiciled.
As of December 31, 2024, Redmont has approximately $234,777,205 of regulatory assets under
management on a discretionary basis. Redmont has approximately $2,935,859 of assets on a
non-discretionary basis. As of December, Redmont has combined assets under management
and assets under advisement of $237,713,064.
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Item 5. Fees and Compensation
The annualized fee for investment supervisory services is typically charged as a percentage of
assets under management, ranging up to 1.50% per annum. The specific manner in which fees
are charged to a client is established in the applicable client’s advisory agreement. All client
assets are held by a qualified custodian. The firm may invoice a client for its fees, but more
typically fees are debited directly from the client’s account by the custodian in accordance with
the client authorization. Fees are typically billed quarterly, in arrears, at the end of each calendar
quarter based upon the value of the client’s account at the end of the quarter. If the advisory
agreement is executed at any time other than the first day of a calendar quarter or terminated
prior to the end of a calendar quarter, the advisory fees will apply on a pro rata basis. Any prepaid
but unearned fees will be refunded by the firm.
A client’s custodian will generally determine the market value of the investments in a client’s
portfolio. If the custodian is unable to determine a market value for an investment, the firm will
provide a fair valuation. To the extent the firm provides a fair value for an investment, the firm
has a conflict of interest as its advisory fee will be based on such valuation.
Asset-based fees subject the firm to a potential conflict of interest in that the more assets there
are in your advisory account, the more you will pay in fees, and thus the firm has an incentive to
encourage you to increase the assets in the account. Neither the firm nor its supervised persons
receives compensation, including asset-based sales charges or service fees from mutual funds,
for the sale of securities or other investment products.
We retain discretion to negotiate alternative fees, including fixed or hourly fees, on a client-by-
client basis. Client facts, circumstances and needs are considered in determining the fee
schedule. These include the complexity of the client, assets to be placed under management,
anticipated future additional assets, related accounts, portfolio style, account composition and
reports, among other factors. Certain accounts of persons affiliated with the firm or its affiliates
may be managed without fees or at reduced fees.
We may group certain related client accounts for the purposes of achieving the minimum account
size requirements and determining the annualized fee.
Financial Planning Fees and Optional Estate Planning Services
Basic financial planning services are included in Redmont’s overall investment management fee,
which is charged as a percentage of client assets under management.
In addition to these services, Redmont may recommend that clients take advantage of an
optional self-preparation will or trust software-as-a-service (SaaS) platform provided by a third-
party vendor. This service is available at an additional flat fee of up to $2,500, which is paid
directly by the client. Redmont receives this fee for providing access to the platform.
Clients are under no obligation to purchase or use this service and may choose to work with an
attorney or other provider of their choice for estate planning needs.
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Additional Fees and Expenses
Our fees are exclusive of administration expenses, brokerage commissions, transaction fees,
fund expenses and other related costs and expenses incurred by a client. Custody fees will vary
depending on the custodian. All brokerage charges and related transaction costs are charged to
the client account(s) as they occur. Clients incur certain charges imposed by custodians, brokers,
third party managers and other third parties such as fees charged by sub-advisers, 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.
All fees paid to the firm for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds, closed-end funds and/or ETFs to their shareholders as
well as for any other investment vehicle in which a client invests. These fees and expenses are
described in each investment vehicle’s prospectus or offering materials. These fees will generally
include a management fee, other fund expenses and a possible distribution fee. If the investment
vehicle also imposes sales charges, a client may pay an initial or deferred sales charge. A client
could invest in an investment vehicle directly, without our services. In that case, the client would
not receive the services provided by our firm which are designed, among other things, to assist
the client in determining which investment vehicle is most appropriate to each client’s financial
condition and objectives. Accordingly, the client should review both the fees charged by the
investment vehicles and our fees to fully understand the total amount of fees to be paid by the
client so that the client can evaluate the advisory services being provided.
Many investment vehicles offer multiple share classes available for investment based upon
certain eligibility and/or purchase requirements. For instance, in addition to more commonly
offered retail mutual fund share classes, some funds offer institutional share classes or other
share classes specifically designed for purchase by an account for a fee-based investment
advisory program. Such share classes may have varying operating expenses and may have
minimum purchase or other criteria that limit availability. The firm has implemented practices
designed to assure that each client is invested in the share class with the lowest expense ratio
for which the client is eligible to invest and that is determined appropriate by the firm, in its sole
discretion, after consideration of certain relevant factors, including account size and anticipated
holding period.
Where a portion of a client account is allocated to a sub-adviser, the firm will typically pay the sub-
advisory fee from the advisory fee payable to the firm, but for certain sub-advisers there may be a
separate written agreement between the client and the sub-adviser to pay an additional amount directly
to the sub-adviser
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Item 6. Performance‐Based Fees and Side-By-Side Management
Performance-Based Compensation
The firm does not charge any performance-based compensation.
Side-By-Side Management
In some cases, the firm manages clients in the same or similar strategies. This may give rise to
potential conflicts of interest if the clients have, among other things, different objectives or fees.
For example, potential conflicts may arise in the following areas: client orders do not get fully
executed; trades may get executed for an account that may adversely impact the value of
securities held by a client; there will be cases where certain clients receive an allocation of an
investment opportunity when other accounts may not; and/or trading and securities selected for
a particular client may cause differences in the performance of different accounts or funds that
have similar strategies.
The firm has adopted written policies and procedures designed to treat accounts equitably
regardless of the fee arrangement. In addition, we have adopted trading practices designed to
address potential conflicts of interest inherent in client discretionary trading. During periods of
unusual market conditions, the firm may deviate from its normal trade allocation practices. There
can be no assurance, however, that all conflicts have been addressed in all situations.
From time to time, certain clients may invest in limited investment opportunities. The allocation of
these investments across client portfolios is generally not executed on a pro rata basis as a
number of factors will determine whether the limited offering is appropriate or suitable for a client.
Accordingly, such opportunities may be allocated based on another approach, including random
selection, selection based on account size or another methodology. Factors which may impact the
allocation, include but are not limited to: account size, liquidity, investor qualification and risk
tolerance. We note that limited investment opportunities may not be appropriate for smaller
accounts, depending on factors such as minimum investment size, account size, risk and
diversification requirements, and accordingly may not be allocated such investments.
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Item 7.Types of Clients
The firm typically provides advisory services to the following types of clients:
•
Individuals (other than high net worth individuals)
•
High net worth individuals
•
Trusts and estates
•
Pension and profit sharing plans (other than plan participants)
•
Charitable organizations
•
Corporations or other entities not listed above
We may impose minimum account size requirements with respect to certain of our advisory
services. In addition, certain sub-advisers may impose more restrictive account requirements
and varying billing practices than us. In such instances, we may alter our corresponding account
requirements and/or billing practices to accommodate those of the sub-adviser(s).
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
The firm constructs portfolios for our clients using a mix of individual stocks, fixed income
instruments, ETFs, exchange-traded notes, closed-end funds, mutual funds and alternative
investments. The firm will manage its clients’ assets through the direct purchase of securities, by
allocating to sub-advisers and/or by investing in a variety of investment vehicles. Each client’s
asset allocation is determined by their specific objectives and unique circumstances. The firm’s
investment approach begins with a clear and thorough understanding of each client’s objectives,
time horizon, risk, profile and income needs. We utilize a long-term strategy when providing and
implementing our advice. However, should a client’s situation change or the basis for making an
investment change, there are occasions where we will utilize a short-term strategy and securities
are held less than one year.
Investment Strategies
The firm generally employs a conservative long-term asset allocation investment strategy based
on the needs of the client and consistent with the client’s investment objectives, risk tolerance
and time horizons, among other considerations. While the firm generally utilizes stocks, fixed
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income instruments, mutual funds, ETFs and closed-end funds for portfolio allocation, the firm
may recommend other types of securities to clients.
Long-term purchases
We purchase securities with the idea of holding them in the client’s account for a year or longer.
Typically, we employ this strategy 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.
•
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.
Short-term purchases
When utilizing this strategy, we purchase securities with the idea of selling them within a relatively
short time (typically a year or less). We do this in an attempt to take advantage of conditions that
we believe will soon result in a price swing in the securities we purchase.
A short-term purchase strategy poses risks should the anticipated price swing not materialize; we
are then left with the option of having a long-term investment in a security that was designed to
be a short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy, and will
result in increased brokerage and other transaction-related costs, as well as less favorable tax
treatment of short-term capital gains.
Risk of Loss
Investing in securities involves a risk of loss that you should be prepared to bear, including loss
of your original principal. Past performance is not indicative of future results, therefore, you should
not assume that future performance of any specific investment or investment strategy will be
profitable. We do not provide any representation or guarantee that your goals will be achieved.
In addition to general investment risks, there are additional material risks associated with the
types of strategies in which your account invests from time to time. Please refer to the relevant
prospectus or offering materials for more information regarding risk factors for a particular
investment in an ETF, closed-end fund, mutual fund, private fund or other pooled vehicle.
Depending on the different types of investments and strategies employed for your account, there
are varying degrees of risk:
•
Market Risk – Either the market as a whole, or the value of an individual company, goes
down, resulting in a decrease in the value of client investments. Global markets are
interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar
natural disturbances, war, terrorism or threats of terrorism, civil disorder, public health
crises and similar “Act of God” events have led, and may in the future lead, to increased
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short-term market volatility and may have adverse long-term and wide-spread effects on
world economies and markets generally. Clients may have exposure to countries and
markets impacted by such events, which could result in material losses.
•
Equity Risk – Stocks are susceptible to fluctuations and to the volatile increases and
decreases in value as their issuer’s confidence in or perceptions of the market change.
Investors holding common stock of any issuer are generally exposed to greater risk than
if they hold preferred stock or debt obligations of the issuer.
•
Company Risk – There is always a level of company or industry risk when investing in
stock positions. This is referred to as unsystematic risk and can be reduced through
appropriate diversification. There is the risk that a company will perform poorly or that its
value will be reduced based on factors specific to it or its industry.
•
Small- and Medium-Capitalization Companies – Depending on the strategy, the firm
invests assets in the stocks of companies with small- to medium-sized market
capitalizations. While the firm believes they often provide significant profit opportunities,
those stocks, particularly smaller-capitalization stocks, involve higher risks in some
respects than investments in stocks of larger companies. For example, prices of small-
capitalization and even medium-capitalization stocks are often more volatile than prices
of large-capitalization stocks, and the risk of bankruptcy or insolvency of many smaller
companies is higher than for larger, “blue-chip” companies. In addition, due to thin trading
in some small capitalization stocks, an investment in those stocks are likely illiquid.
•
Fixed Income Risk – Investing in bonds involves the risk that the issuer will default on the
bond and be unable to make payments. In addition, individuals depending on set amounts
of periodically paid income face the risk that inflation will erode their spending power.
Fixed-income investors receive set, regular payments that face the same inflation risk.
The fixed income instruments purchased by a client are subject to the risk that market
values of such securities will decline as interest rates increase. These changes in interest
rates have a more pronounced effect on securities with longer durations. Fixed income
instruments are also subject to reinvestment risk in that if interest rate are falling during a
period of reinvestment returns will be lower. Interest rate risk increases as portfolio
duration increases. Reinvestment risk increases as portfolio duration decreases.
•
Non-Investment Grade Bonds – Depending on the strategy, a client account will invest in
bonds (commonly known as “junk bonds”) that are of below investment grade quality
(rated below Baa3 by Moody’s Investors Service, Inc. or below BBB- by Standard & Poor’s
Ratings Group and Fitch Ratings or, if unrated, reasonably determined by the firm to be
of comparable quality (“non-investment grade bonds”). An account’s investments in non-
investment grade bonds are predominantly speculative because of the credit risk of their
issuers. While normally offering higher yields, non-investment grade bonds typically entail
greater potential price volatility and will likely be less liquid than investment grade
securities.
•
Convertible Securities Risks – Convertible securities are bonds, debentures, notes,
preferred stocks or other securities that may be converted into or exchanged for a
specified amount of common stock of the same or a different issuer within a particular
period of time at a specified price or formula. A convertible security entitles its holder to
receive interest that is generally paid or accrued on debt or a dividend that is paid or
accrued on preferred stock until the convertible security matures or is redeemed,
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converted or exchanged. Convertible securities have unique investment characteristics in
that they generally (i) have higher yields than common stocks, but lower yields than
comparable non-convertible securities, (ii) are less subject to fluctuation in value than
the underlying common stock due to their fixed income characteristics and (iii) provide
the potential for capital appreciation if the market price of the underlying common
stock increases. The value of a convertible security is a function of its “investment value”
(determined by its yield in comparison with the yields of other securities of comparable
maturity and quality that do not have a conversion privilege) and its “conversion value”
(the security’s worth, at market value, if converted into the underlying common stock).
The investment value of a convertible security is influenced by changes in interest rates,
with investment value declining as interest rates increase and increasing as interest rates
decline. The credit standing of the issuer and other factors may also have an effect on the
convertible security’s investment value. The conversion value of a convertible security is
determined by the market price of the underlying common stock. If the conversion value
is low relative to the investment value, the price of the convertible security is governed
principally by its investment value. To the extent the market price of the underlying
common stock approaches or exceeds the conversion price, the price of the convertible
security will be increasingly influenced by its conversion value.
•
Distressed Securities – An account, depending on the strategy, will invest in securities of
companies that are experiencing or have experienced significant financial or business
difficulties. Distressed securities may generate significant returns for an account, but also
involve a substantial degree of risk. In certain circumstances, an account will lose a
substantial portion or all of its investment in a distressed company or be required to accept
cash or securities with a value less than an account’s original investment. The market
prices of such investments are also subject to abrupt and erratic market movements and
above average price volatility, and the spread between the bid and asked prices of such
investments will likely be greater than for non-distressed securities.
•
ETF, Closed-end Fund and Mutual Fund Risk – ETF, closed-end fund and mutual fund
investments bear additional expenses based on a pro rata share of operating expenses,
including potential duplication of management fees. The risk of owning an ETF, closed-
end fund or mutual fund generally reflects the risks of owning the underlying securities
held by the ETF, closed-end fund or mutual fund. If the ETF, closed-end fund or mutual
fund fails to achieve its investment objective, the strategy’s investment in the fund may
adversely affect its performance. In addition, because ETFs and many closed-end funds
are listed on national stock exchanges and are traded like stocks listed on an exchange,
(1) the strategy may acquire ETF or closed-end fund shares at a discount or premium to
their NAV, and (2) the strategy may incur greater expenses since ETFs are subject to
brokerage and other trading costs. Since the value of ETF shares depends on the demand
in the market, we may not be able to liquidate the holdings at the most optimal time,
adversely affecting performance. Closed-end funds which are not publicly offered (also
known as interval funds) provide only limited liquidity to investors. Accordingly,
investments in interval funds can expose investors to liquidity risk, and that risk is greater
in funds that invest in securities of companies with smaller market capitalizations,
derivatives or securities with substantial market and/or credit risk.
•
Exchange Traded Notes – An account, depending on the strategy, may invest in exchange
traded notes (“ETNs”). ETNs are a type of senior, unsecured, unsubordinated debt
security issued by financial institutions that combine aspects of both bonds and ETFs. An
ETN’s returns are based on the performance of a market index minus fees and expenses.
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Similar to ETFs, ETNs are listed on an exchange and traded in the secondary market.
However, unlike an ETF, an ETN can be held until the ETN’s maturity, at which time the
issuer will pay a return linked to the performance of the market index to which the ETN is
linked minus certain fees. Like other index-tracking instruments, ETNs are subject to the
risk that the value of the index may decline, at times sharply and unpredictably. In addition,
ETNs—which are debt instruments—are subject to risk of default by the issuer. ETNs are
subject to both market risk and the risk of default by the issuer. ETNs are also subject to
the risk that a liquid secondary market for any particular ETN might not be established or
maintained.
•
REITs and Real Estate Risk – The value of a strategy’s investments in real estate
investment trusts (“REITs”) may change in response to changes in the real estate market.
A strategy’s investments in REITs may subject it to the following additional risks: declines
in the value of real estate, changes in interest rates, lack of available mortgage funds or
other limits on obtaining capital and financing, overbuilding, extended vacancies of
properties, increases in property taxes and operating expenses, changes in zoning laws
and regulations, casualty or condemnation losses and tax consequences of the failure of
a REIT to comply with tax law requirements. A strategy will bear a proportionate share of
the REIT’s ongoing operating fees and expenses, which may include management,
operating and administrative expenses.
•
Options Risk – In connection with the provision of certain investment strategies requested
by a client, the firm may make use of certain options. Options on securities are subject to
greater fluctuations in value than investing in the underlying securities. Purchasing and
writing put or call options are highly specialized activities and involve greater investment
risk. Puts and calls are the right to sell or buy a specified amount of an underlying asset
at a set price within a set time.
•
Derivatives Risk – In connection with the provision of certain investment strategies
requested by a client, the firm may make use of certain derivatives instruments. Derivative
instruments, which may include without limitation, warrants, options, swaps, forward
contracts, and futures contracts. The use of derivative instruments involves a variety of
material risks, including the extremely high degree of leverage often embedded in such
instruments and the possibility of counterparty nonperformance as well as of material and
prolonged deviations between the actual and the theoretical value of a derivative (i.e., due
to nonconformance to anticipated or historical correlation patterns). In addition, the
markets for certain derivatives are frequently characterized by limited liquidity, which can
make it difficult as well as costly to close out positions in order to realize gains or to limit
losses.
•
International Investing Risk – International investing, especially in emerging markets,
involves special risks, such as currency exchange and price fluctuations, as well as
political and economic risks.
•
Emerging Markets Risk – The risks associated with foreign investments are heightened
when investing in emerging markets. The governments and economies of emerging
market countries may show greater instability than those of more developed countries.
Such instability may result from, among other things, authoritarian governments, or military
involvement in political and economic decision-making, including changes or attempted
changes in governments through extra-constitutional means, internal insurgencies, hostile
relations with neighboring countries, ethnic, religious and racial disaffections or conflict.
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Certain emerging market countries may have in the past failed to recognize private
property rights and have at times nationalized or expropriated the assets of private
companies. As a result, the risks from clients investing in those countries, including the
risks of nationalization, expropriation and repatriation of assets, may be heightened. In
addition, unanticipated political and/or social developments may affect the values of any
client investments in emerging market countries and the availability of additional
investments in these countries. The risk that unfavorable trends or (political) events (e.g.
changes in economic or tax policy or legal environment, nationalizations, riots, war) take
place in a country where the assets have been invested that affect the country’s political
or economic stability or future development thereby causing the loss of the investments in
the country or diminishing the value of such investments for the clients. Such investments
tend to fluctuate in price more widely and to be less liquid than other foreign investments.
•
Liquidity Risk – Liquidity is the ability to readily convert an investment into cash. The less
liquid an asset is, the greater the risk that, if circumstances require an investor to sell the
asset quickly, it will be sold at a price below fair value. Generally, an asset is more liquid
if it represents a standardized product or security and there are many traders interested
in making a market in that product or security. For example, Treasury Bills are highly
liquid, while real estate properties are not.
•
Management Risk – Investments also vary with the success and failure of the investment
strategies, research, analysis and determination of portfolio securities. If our strategies
do not produce the expected returns, the value of your investments will decrease.
•
Non-Diversification Risk – If a strategy is “non-diversified,” its investments are not required
to meet certain diversification requirements under federal law. A “non-diversified” strategy
is permitted to invest a greater percentage of its assets in the securities of a single issuer
than a diversified strategy. Thus, the strategy may have fewer holdings than other
strategies. As a result, a decline in the value of those investments would cause the
strategy’s overall value to decline to a greater degree than if the strategy held a more
diversified portfolio.
•
Cybersecurity – The firm’s information and technology systems may be vulnerable to
damage or interruption from computer viruses, network failures, computer and
telecommunication failures, infiltration by unauthorized persons and security breaches,
usage errors by its professionals, power outages and catastrophic events such as fires,
tornados, floods, hurricanes and earthquakes. Although the firm has implemented various
measures to protect the confidentiality of its internal data and to manage risks relating to
these types of events, if these systems are compromised, become inoperable for extended
periods of time or cease to function properly, the firm will likely have to make a significant
investment to fix or replace them. The failure of these systems and/or of disaster recovery
plans for any reason could cause significant interruptions in the firm’s operations and
result in a failure to maintain the security, confidentiality or privacy of sensitive data,
including personal information relating to clients. Such a failure could harm the firm’s
reputation or subject it or its affiliates to legal claims and otherwise affect their business
and financial performance. The firm will seek to notify affected clients of any known
cybersecurity incident that will likely pose substantial risk of exposing confidential personal
data about such clients to unintended parties.
•
Epidemics and Pandemics - Since 2003, the world has seen a number of outbreaks of
new viral illnesses of varying severity, including Severe Acute Respiratory Syndrome
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travel
(SARS), Middle East Respiratory Syndrome (MERS), the H1N1 Flu (Swine Flu), and
COVID-19 caused by the novel Coronavirus known as SARS–CoV-2. The responses to
these outbreaks have varied as has their impact on human health, local economies and
the global economy, and it is impossible at the outset of any such outbreak to estimate
accurately what the ultimate impact of any such outbreak will be. Protective measures
taken by governments and the private sector to mitigate the spread of such illness,
including
restrictions and outright bans, quarantines and work-at-home
arrangements, and the spread of any such illness within the offices of Redmont and/or its
service providers could severely impair Redmont’s and/or its service providers’ operational
capabilities, potentially harming clients and their performance.
Allocations to sub-advisers and investors in private funds are subject to the following additional
risks:
•
Third-Party Aggressive Investment Technique Risk – Sub-advisers and private funds may
use investment techniques and financial instruments that may be considered aggressive,
including but not limited to investments in derivatives such as futures contracts, options
on futures contracts, securities and indices, forward contracts, swap agreements and
similar instruments. Such techniques may also include taking short positions or using other
techniques that are intended to provide inverse exposure to a particular market or other
asset class, as well as leverage, which can expose a client’s account to potentially
dramatic changes (losses or gains). These techniques may expose a client to potentially
dramatic changes (losses) in the value of its allocation to the sub-adviser or private fund.
•
Liquidity and Transferability – Certain private funds offer their investors only limited
liquidity and interests are generally not freely transferable. In addition to other liquidity
restrictions, investments in private funds may offer liquidity at infrequent times (i.e.,
monthly, quarterly, annually or less frequently). Accordingly, investors in private funds
should understand that they may not be able to liquidate their investment in the event of
an emergency or for any other reason.
•
Possibility of Fraud and Other Misconduct – When a client invests with a sub-adviser or
private fund, there is the risk that the sub-adviser, private fund or the custodian could divert
or abscond with those assets, fail to follow agreed upon investment strategies, provide
false reports of operations, or engage in other misconduct. Moreover, there can be no
assurances that the sub-advisers or private funds will be operated in accordance with all
applicable laws and that assets entrusted to those parties will be protected.
•
Counterparty Risk – The institutions (such as banks) and prime brokers with which the
firm or a sub-adviser does business, or to which securities have been entrusted for
custodial purposes, could encounter financial difficulties. This could impair the operational
capabilities or the capital position of the firm or a sub-adviser, or create unanticipated
trading risks.
When the firm engages a sub-adviser, we are highly dependent upon their investment expertise
and abilities as they have day-to-day investment discretion over the underlying portfolio assets.
Therefore, there is a risk that an event having a negative impact on a sub-adviser (such as a
significant change in personnel, corporate structure or resources) may adversely impact a client’s
investment results.
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The firm conducts due diligence in selecting, monitoring and overseeing its sub-advisers.
However, due diligence is not foolproof and may not uncover problems associated with a
particular sub-adviser. For example, one or more of the sub-advisers may engage in improper
conduct (including unauthorized changes in investment strategy) that may be harmful and may
result in losses. We may rely upon representations made by sub-advisers, accountants, attorneys
and/or other service providers. If any of these representations are misleading, incomplete or
false, this may result in the selection of a sub-adviser that might otherwise have been eliminated
from consideration if fully accurate and complete information had been made available to us.
Even if our due diligence efforts are effective at ensuring that we have a thorough understanding
of a particular sub-adviser, our judgment about whether a particular sub-adviser is able to perform
in a manner that meets our expectations over the long-term may be incorrect.
Although sub-advisers are generally subject to investment policies, strategies and guidelines,
there can be no assurance that the sub-adviser will comply with these policies, strategies and
guidelines. Failure to comply with the policies, strategies and guidelines could result in an
unintended deviation in the investment strategy and could result in losses.
The firm makes no guarantee or representation that investment recommendations will be
successful. Past performance is no guarantee of future results.
Item 9. Disciplinary Information
The firm and our personnel have no reportable disciplinary events to disclose.
Item 10. Other Financial Industry Activities and Affiliations
Neither the firm nor any of our personnel has any registration or application pending to register
as a broker-dealer, a registered representative of a broker-dealer, a futures commission
merchant, a commodity pool operator, a commodity trading advisor, or an associated person of
the firm.
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
The firm maintains a Code of Ethics (the “Code”) that is applicable to all its employees. Copies of
the Code are available for review by clients and prospective clients upon request. Requests for
the Code should be made to jlanger@redmontwealth.com or (312) 848-1136. Key provisions of
the Code include restrictions on personal trading, a requirement to report outside business
activities, restrictions on political contributions, requirements to disclose key disciplinary events
to the firm’s chief compliance officer (“CCO”), restrictions on the use of social media, restrictions
on the receipt and delivery of gifts and recordkeeping requirements.
All personal trading activity conducted by covered persons is reviewed by the CCO or the CCO’s
designee.
Neither the firm nor its related persons recommend to clients, or buy or sells for client accounts,
securities in which the firm or a related person has a material financial interest.
Certain personnel of the firm may invest in securities alongside clients. This creates a potential
conflict of interest that arises when the firm and such knowledgeable employees buy and/or sell
the same securities that clients concurrently buy and/or sell. To mitigate this conflict of interest
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the firm implements and enforces personal transaction policies and procedures documented in
the Code. Key provisions of these procedures include restrictions on personal trading and
monitoring by the CCO.
Item 12. Brokerage Practices
The firm generally requires discretionary clients to provide us with written authority to determine
the broker-dealer to be used to effect transactions for the client. Clients are responsible for the
transaction-related charges imposed by a broker-dealer with which the firm effects transactions
for the client’s account.
Clients must include any limitations on this discretionary authority in a written authority statement.
Clients may change/amend these limitations as required. Such amendments must be provided
to us in writing.
Unless directed otherwise by a client, the firm generally directs clients to open a brokerage
account at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer, member
SIPC. The firm is independently operated and owned and is not affiliated with Schwab. Although
we recommend that clients establish accounts at Schwab, it is the client’s decision to custody
assets with Schwab. Schwab will hold your assets in a brokerage account and buy and sell
securities when we instruct them to. While we recommend that you use Schwab as
custodian/broker, you will decide whether to do so and open your account with Schwab by
entering into an account agreement directly with them. We do not open the account for you.
For client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions and other
transaction-related or asset-based fees for securities trades that are executed through Schwab
or that settle into Schwab accounts. In addition, Schwab charges you a flat dollar amount as a
“prime broker” or “trade away” fee for each trade that we have executed by a different broker-
dealer but where the securities bought or the funds from the securities sold are deposited (settled)
into your Schwab account. These fees are in addition to the commissions or other compensation
you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we
have Schwab execute most trades for your account.
Schwab Advisor Services™ (formerly Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like us. They provide our clients and us with access to its
institutional brokerage – trading, custody, reporting, and related services – many of which are not
typically available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help us manage or administer our clients’ accounts, while others
help us manage and grow our business. Below is a more detailed description of Schwab’s support
services:
Services That Benefit You. Schwab’s institutional brokerage services include access to a broad
range of investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might not otherwise
have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services That May Not Directly Benefit You. Schwab 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. They include investment
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research, both Schwab’s own and that of third parties. We may use this research to service all
or some substantial number of our clients’ accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and other
technology that:
•
provide access to client account data (such as duplicate trade confirmations and account
statements);
•
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
•
provide pricing and other market data;
•
facilitate payment of our fees form our clients’ accounts; and
•
assist with back-office functions. Recordkeeping, and client reporting.
Services That Generally Benefit Only Us. Schwab also offers other services intended to help
us manage and further develop our business enterprise. These services include:
•
educational conferences and events;
•
technology, compliance, legal, and business consulting;
•
publications and conferences on practice management and business succession; and
•
access to employee benefits providers, human capital consultants, and insurance
providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of
these services or pay all or a part of a third party’s fees. Schwab may also provide us with other
benefits such as occasional business entertainment of our personnel.
The firm recommends Schwab to clients based on a number of factors including, but not limited
to: (1) breadth of investment products made available to clients, particularly mutual funds and
exchange-traded funds, (2) custodial platform provided to clients for which separate fees are not
charged by Schwab, (3) reputation, financial strength and stability, (4) prior service to firm clients,
and (5) other products and services that benefit the firm, as discussed above. Schwab charges
a transaction fee for transactions placed with other brokers (“trade away fee”), which is in addition
to the fee charged by the executing broker. The firm may not obtain execution as favorable as
the execution obtained by using broker-dealers other than Schwab. To the extent that we execute
individual transactions for clients, we will periodically compare the prices obtained through
Schwab, as applicable, with prices available through other brokers or execution venues for
reasonableness, taking into account any applicable trade away fees.
While broker-dealers that we select to execute transactions may from time to time refer clients to
the firm, we do not make commitments to any broker or dealer to compensate that broker or
dealer through brokerage or dealer transactions for client referrals; however, a potential conflict
of interest may arise between the client’s interest in obtaining the lowest commission cost and the
firm’s interest in receiving future referrals.
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A client may direct the firm to execute transactions for the client through a specific broker-dealer.
If a client directs its brokerage to a specific broker-dealer, the firm may be unable to obtain the
lowest commission cost.
Allocation and Aggregation of Orders. Redmont generally will aggregate client orders to
achieve more efficient execution, and/or to provide for equitable treatment among accounts.
Clients participating in aggregated orders will be allocated securities pro rata on an average price
basis in accordance with the relative order sizes of each, or in some other manner that Redmont
determines is fair and equitable under the circumstances.
Aggregating orders may tend to decrease the prices received, and increase the prices required
to be paid by a particular client for its portfolio sales and purchases, respectively. Where less than
the maximum desired number of shares of a particular security to be purchased is available at a
favorable price, the shares purchased will be allocated among the clients in an equitable manner
as determined by Redmont in its discretion.
Item 13. Review of Accounts
The firm provides continuous portfolio management for client accounts. The firm conducts an in-
depth review at engagement and on an annual basis thereafter for as long as a client has an
account managed by the firm. Informal update discussions may take place on a quarterly or semi-
annual basis. Clients may request interim reviews at any time to discuss their investment account.
Other conditions that may trigger an account review are changes in the investment landscape,
significant economic events and changes in a client’s own situation.
In addition to the statements and confirmations of transactions that clients receive from their
broker-dealer, we provide quarterly reports summarizing account performance, balances and
holdings.
Where we only provide financial planning services to a client, the client will receive a completed
financial plan. Additional plans will not be provided unless contracted otherwise.
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Item 14. Client Referrals and Other Compensation
The primary compensation the firm receives for providing advisory services to clients are the fees
paid by those advisory clients. Currently, neither the firm nor any supervised person of the firm
directly or indirectly compensates any person who is not a supervised person of the firm for client
referrals. Should the firm enter into a compensation arrangement for client referrals, all such
referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act as
well as relevant SEC guidance.
The firm receives an economic benefit from Schwab in the form of the support products and
services it generally makes available to the firm and other independent investment advisors with
clients that maintain accounts at Schwab. These products and services, how they benefit the
firm, and the related conflicts of interest are described in Item 12 – Brokerage Practices.
Item 15. Custody
The firm is deemed to have custody of client accounts where the firm has authority to instruct the
custodian of the client account to deduct for the firm’s advisory fees directly from the client
account. As part of this billing process, the client’s custodian is advised of the amount of the fee
to be deducted from that client’s account. On at least a quarterly basis, the custodian is required
to send to the client a statement showing all transactions within the account during the reporting
period.
Because the custodian does not calculate the amount of the fee to be deducted, clients are urged
to carefully review their custodial statements to verify the accuracy of the calculation, among other
things. Clients should contact us directly if they believe that there may be an error in their
statement.
Item 16. Investment Discretion
The firm accepts discretionary authority to manage securities accounts on behalf of clients subject
to an executed advisory agreement. The advisory agreement authorizes the firm to determine
whether and in what amount securities are to be purchased for and sold from the account without
prior instruction or authorization from the client. On a case by case basis, clients may negotiate
certain risk and/or operating guidelines that the firm will adhere to when exercising our
discretionary authority. Such risk and/or operating guidelines are described in each client’s
advisory agreement.
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Item 17. Voting Client Securities
The firm will vote client proxies, where such responsibility has been properly delegated to and
assumed by the firm. We are only able to vote proxies designated to us. We cast proxy votes in
a manner consistent with the best interest of our clients. In the event that the firm has authority to
vote proxies for a client, the firm will delegate the responsibility to review proxy proposals and
make voting recommendations to a non-affiliated third-party vendor. Proxies will be voted
consistent with our Proxy Voting Policies and Procedures. At any time, clients may contact us to
request information about how we voted proxies for that client’s securities or to get a copy of our
Proxy Voting Policies and Procedures.
Our Proxy Voting Policies and Procedures authorize the firm to delegate certain proxy voting
functions to service providers, and we have contracted with Institutional Shareholder Services
(“ISS”) to vote all proxies for our advisory clients. Under the terms of its arrangement with ISS,
the firm will generally follow the recommendations from ISS. The firm can instruct ISS to abstain
from or vote either for or against a particular type of proposal or the firm can instruct ISS to seek
instruction with respect to that particular type of proposal from the firm on a case-by-case basis
(“Voting Instructions”). ISS receives all proxy statements and sorts the proposals according to the
firm’s Voting Instructions. Proposals for which a voting decision has been pre-determined are
automatically voted by ISS pursuant to the Voting Instructions.
On occasion, the firm may determine not to vote a particular proxy. This may be done, for example
where: (1) the cost of voting the proxy outweighs the potential benefit derived from voting; (2) a
proxy is received with respect to securities that have been sold before the date of the shareholder
meeting and are no longer held in a client account; (3) despite reasonable efforts, the firm receives
proxy materials without sufficient time to reach an informed voting decision and vote the proxies;
(4) the terms of the security or any related agreement or applicable law preclude the firm from
voting; or (5) the terms of an applicable advisory agreement reserve voting authority to the client
or another party.
Additional information on our Proxy Voting Policies and Procedures is set forth below:
•
the firm’s policy is to vote client shares primarily in conformity with ISS’ recommendations,
in order to limit conflict of interest issues between the firm and its clients. ISS is neutral and issues
recommendations based upon its own internal guidelines.
the firm may vote client shares inconsistent with ISS’ recommendations if the firm believes
•
it is in the best interest of its clients.
•
the firm votes client shares via ISS which retains a record of proxy votes for each client.
•
In situations where there is a conflict of interest in the voting of proxies due to business or
personal relationships that the firm maintains with persons having an interest in the
outcome of certain votes, the firm will take appropriate steps to ensure that our proxy
voting decisions are made in the best interest of our clients.
Item 18. Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to clients and have not been the subject of a bankruptcy proceeding.
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