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March 2026
Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
March 2026
3 Twin Dolphin Drive, Suite 210
Redwood City, CA 94065
Firm Contact:
Benjamin Pettigrew
Chief Compliance Of�icer
This brochure provides information about the qualifications and business practices of Redwood Park
Advisors, LLC. If clients have any questions about the contents of this brochure, please contact us at
(866) 579 - 8808. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #307958.
Please note that the use of the term “registered investment adviser” and description of our �irm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our �irm’s associates who advise
clients for more information on the quali�ications of our �irm and our employees.
ADV Part 2A – Firm Brochure
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Redwood Park Advisors LLC
March 2026
Item 2: Material Changes
Redwood Park Advisors is required to notify clients of any information that has changed since the
last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can
request a full copy of our Brochure or contact us with any questions that they may have about the
changes.
Item 4: Advisory Business -
Since our last annual amendment filed March 2025, we have the following material changes to
disclose:
•
Regulatory assets under management has been updated to
re�lect discretionary and non-discretionary asset values as of December 31, 2025.
-
• Appendix A: Privacy Policy
Appendix A, Redwood Park Advisors’ Privacy Policy has been
updated as of March 2026.
ERISA Disclosure
-
• Appendix B: 408b-2
Appendix B, 408b-2 ERISA Disclosure has been
updated as of March 2026.
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Redwood Park Advisors LLC
March 2026
Item 3: Table of Contents
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 .............................................................................................................. 7
Item 6: Performance-Based Fees and Side-by-Side Management ............................................................ 9
Item 7: Types of Clients and Account Requirements ............................................................................. 10
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................... 10
Item 9: Disciplinary Information .......................................................................................................... 18
Item 10: Other Financial Activities and Af�iliations .............................................................................. 18
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 19
Item 12: Brokerage Practices ................................................................................................................ 20
Item 13: Review of Accounts or Financial Plans .................................................................................... 24
Item 14: Client Referrals and Other Compensation .............................................................................. 24
Item 15: Custody ................................................................................................................................... 25
Item 16: Investment Discretion ............................................................................................................ 25
Item 17: Voting Client Securities ........................................................................................................... 26
Item 18: Financial Information ............................................................................................................. 26
Appendix A: Privacy Policy - Redwood Park Advisors ........................................................................... 27
Appendix B: ERISA 408b-2 Disclosures - March 27, 2025 ..................................................................... 30
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Redwood Park Advisors LLC
March 2026
Item 4: Advisory Business
Our firm provides individuals and other types of clients with investment advisory services. Our firm
is a limited liability company formed under the laws of the State of California on April 28, 2016, and
has been in business as a registered investment adviser since June 26, 2020. Our firm is owned by
Benjamin Pettigrew and David Smith. In addition, our firm has elected Benjamin Pettigrew and David
Smith to manage and operate Redwood Park Advisors, LLC.
The purpose of this Brochure is to disclose the conflicts of interest associated with investment
transactions, compensation, and any other matters related to investment decisions made by our firm
or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is
accomplished in part by knowing our client. Our firm has established a service-oriented advisory
practice with open lines of communication for many different types of clients to help meet their
financial goals while remaining sensitive to risk tolerance, return objectives, and constraints. Helping
clients understand their investment objectives facilitates the kind of working relationship we value.
With respect to Retirement Accounts (defined below), RPA will provide services as a “fiduciary” (as
that term is defined in Section 3(21)(A) of the Employee Retirement Income Security Act of 1974
(“ERISA”) and/or Section 4975 of the Internal Revenue Code (the “Code”)), and RPA will act in a
manner consistent with the requirements of a fiduciary under ERISA and the Code. For purposes of
this Brochure, the term “Retirement Account” covers: (i) “employee benefits plans” (as defined under
Section 3(3) of ERISA), which include pension, profit sharing or welfare plans sponsored by private
employers; and (ii) individual retirement accounts (“IRAs”) (as defined in Section 4975 of the Code).
Types of Advisory Services Offered:
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals using a financial plan or consultation. Our firm conducts client
meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of: individual stocks and bonds; ETFs; options; mutual funds; and other public and private
securities or investments. Once the appropriate portfolio has been determined, portfolios are
continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals, and constraints. Upon client request, our firm provides a summary of
observations and recommendations for the planning or consulting aspects of this service.
Our firm may utilize the sub-advisory services of a third-party investment advisory firms or
individual advisors to aid in the implementation of an investment portfolio designed by our firm.
Before selecting a firm or individual, our firm will ensure that the chosen party is properly licensed
or registered. Our firm will not offer advice on any specific securities or other investments in
connection with this service. We will provide initial due diligence on third party money managers
and ongoing reviews of the management of client accounts. In order to assist in the selection of a third-
party money manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review third-party money manager reports provided to the client at least
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annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives, communicate information to third-party money managers, as warranted and assist
the client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Asset Management:
As part of our Asset Management service, a portfolio is designed, consisting of individual stocks and
bonds; exchange traded funds (“ETFs”); options; mutual funds; and other public and private
securities or investments. The client’s individual investment strategy is tailored to their specific
needs and may include some or all of the previously mentioned securities. Portfolios will be designed
to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once
the appropriate portfolio has been determined, portfolios are continuously and regularly monitored,
and if necessary, rebalanced based upon the client’s individual needs, stated goals, and constraints.
Our firm may utilize sub-advisory services of third-party investment advisory firms or individual
advisors to aid in the implementation of an investment portfolio designed by our firm. Before
selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or
registered. Our firm will not offer advice on any specific securities or other investments in connection
with this service. We will provide initial due diligence on third party money managers, and ongoing
reviews of the management of client accounts. In order to assist in the selection of a third-party
money manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review third-party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives, communicate information to third-party money managers, as warranted, and assist
the client in understanding and evaluating the services provided by the third-party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Separately Managed Account Services (“SMA”) for Comprehensive Portfolio Management and
Asset Management Clients:
We participate in the Schwab Managed Account Program and offer separately managed accounts from
the Managed Account Select and Managed Account Access programs. These Schwab programs allow
access to independent money management firms offered by the Schwab Advisor Services division of
Charles Schwab & Co. Inc. (“Schwab”). Our firm performs management searches of various investment
managers. Based on the client's individual circumstances we determine which selected manager's
portfolio management style is appropriate for that client. Factors considered in making this
determination include account size, risk tolerance, the objectives of each client, and the investment
philosophy of the selected manager. Clients should refer to the manager's Firm Brochure or other
disclosure documents for a full description of the services offered. We will furnish a copy of the disclosure
brochures for each manager selected. We will recommend one or more managers who will manage the
client's account on a discretionary basis. On an ongoing basis, we monitor the performance of the
manager(s).
• Managed Account Marketplace (“Marketplace”):
ADV Part 2A – Firm Brochure
We participate in the Schwab Connection Marketplace program for certain larger clients. The
services provided are “unbundled,” meaning fees for asset management and fees for trading
are charged separately, in addition to the fees charged by our firm. The fees for asset
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management with the money management firm are negotiated with the individual manager
by our firm on behalf of the Client and are based on the total assets with that manager
included in the program and the type of management services (equity or fixed income)
provided.
Execution of security transactions may be paid in one of two ways: (1) a percentage of assets
based on pricing schedules set by Schwab that are determined by trade volume for an
individual money manager; or (2) on a transaction basis, where each transaction is charged
a commission as negotiated with Schwab.
It may be possible for a client to use Marketplace and receive the same research services and
benefits (subject to internal restrictions identified earlier) for a lower fee than available
under the Select program. The bundled fees charged for the Select program may be higher
than the “unbundled fees” charged under Marketplace because of the initial and ongoing due
diligence provided by the Schwab Center for Financial Research and pricing set by the money
management firms for each program.
Financial Planning & Consulting
:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial assets based upon an analysis of their current situation, goals, and
objectives. Financial planning services will typically involve preparing a financial plan and holding a
financial consultation to understand the client’s financial goals, investment objectives, and
constraints. This planning or consulting may encompass investment planning, retirement planning,
estate planning discussions, charitable planning, education planning, corporate and personal tax
discussion, corporate structure, real estate analysis, mortgage/debt analysis, insurance needs, lines
of credit evaluation, or business and personal financial planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. If all the
information and documents requested from the client are provided promptly, plans or consultations
are typically completed within six months of the client signing a contract with our firm.
Retirement Plan Consulting
:
Our firm may provide retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the
plan sponsor dictate, areas of advising may include:
•
•
•
Establishing an Investment Policy Statement – Our �irm will assist in the development of a
statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our �irm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Investment Monitoring – Our �irm will monitor the performance of the investments and notify
the client in the event of over/underperformance, and in times of acute market volatility.
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Redwood Park Advisors LLC
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•
Participant Education – Our �irm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance on
allocation strategies.
Tailoring of Advisory Services
:
Our �irm offers individualized investment advice to our Asset Management and Comprehensive
Portfolio Management clients. General investment advice will be offered to our Financial Planning &
Consulting, Retirement Plan Consulting, and referrals to third-party money management clients.
Each Asset Management and Comprehensive Portfolio Management client has the opportunity to
place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on
investments in certain securities or types of securities may not always be possible due to the level of
dif�iculty it would entail in managing the account.
Participation in Wrap Fee Programs
:
Our �irm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
:
As of December 31, 2025, Redwood Park Advisors manages $170,335,362 of assets; $156,954,599 of
assets are managed on a discretionary basis, and $13,380,763 of assets are managed on a non-
discretionary basis.
Item 5: Fees and Compensation
Compensation for Our Advisory Services:
Asset Management
:
The maximum annual fee charged for this service is based on a tiered or set fee schedule and will not
exceed 1.25% of the account assets managed. Client’s may pay additional fees when utilizing SMAs,
as disclosed below in section Other Types of Fees and Expenses. Fees to be assessed will be outlined
in the Advisory Agreement signed by the Client. Annualized fees are billed on a pro-rata basis,
quarterly in advance, based on the value of the account(s) on the last day of the previous quarter. Our
firm bills on cash balances unless otherwise indicated in writing. Fees are negotiable and will be
deducted from client account(s). Our firm may make adjustments for deposits and withdrawals
during the quarter; exact arrangements will be outlined in the Advisory Agreement to be signed by
the Client. In rare cases, our firm will agree to directly invoice.
•
•
•
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our �irm;
Clients will provide authorization permitting our �irm to be directly paid by these terms. Our
�irm will send an invoice directly to the custodian; and
If our �irm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the quali�ied custodian will be
included.
Comprehensive Portfolio Management
:
The maximum annual fee charged for this service is based on a tiered or set fee schedule and will not
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exceed 1.50% of the account assets managed. Client’s may pay additional fees when utilizing SMAs,
as disclosed below in section Other Types of Fees and Expenses. Fees to be assessed will be outlined
in the Advisory Agreement to be signed by the Client. Annualized fees are billed on a pro-rata basis,
quarterly in advance, based on the value of the account(s) on the last day of the previous quarter. Our
firm bills on cash balances unless otherwise indicated in writing. Fees are negotiable and will be
deducted from client account(s). Our firm may make adjustments for deposits and withdrawals
during the quarter; exact arrangements will be outlined in the Advisory Agreement to be signed by
the Client. In rare cases, our firm will agree to directly invoice.
•
•
•
The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our �irm;
Clients will provide authorization permitting our �irm to be directly paid by these terms. Our
�irm will send an invoice directly to the custodian; and
If our �irm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the quali�ied custodian will be
included.
Financial Planning & Consulting
:
Our firm charges an hourly or flat fee for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
engagement with the client. The maximum hourly fee to be charged will not exceed $250/hour. Flat
fees range from $2,000 to $5,000. Our firm requires payment in full upon execution of the Agreement
or a retainer of 50% of the ultimate financial planning or consulting fee at the time of signing. The
remainder of the fee will be directly billed to the client and due within 30 days of a financial plan
being delivered or consultation rendered. Our firm will not require a retainer exceeding $1,200 when
services cannot be rendered within 6 months.
Retirement Plan Consulting
:
Our Retirement Plan Consulting services are billed an annual fee, based on the percentage of plan
assets under management (“AUM”). The total estimated fee, as well as the ultimate fee charged, is
based on the scope and complexity of our engagement with the client. Fees based on a percentage of
managed plan assets will not exceed 1.00%. The fee-paying arrangements will be determined on a
case-by-case basis and will be detailed in the signed consulting agreement.
Other Types of Fees and Expenses
:
Clients will incur transaction fees (for instance mutual funds transaction fees can be $29 per trade)
for trades executed by their chosen custodian via individual transaction charges. These transaction
fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles
Schwab & Co., Inc. (“Schwab”) generally does not charge transaction fees for U.S. listed equities and
exchange traded funds.
Clients will also pay the management and operating fees imposed directly by a mutual fund, index
fund, and/or exchange traded fund, which are disclosed in the fund’s prospectus (i.e., fund
management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender
charges, and other fund expenses), and custodian imposed fees such as variable annuity fees, IRA
and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees
for trades executed away from custodian, wire transfer fees, and other fees and taxes on brokerage
accounts, and securities transactions. Our firm does not share in or receive a portion of these fees.
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Clients who make digital asset trades may incur maintenance fees associated with a cryptocurrency’s
trading platform, transaction fees, spreads, or other ongoing fees that may be incurred as a result of
investing in digital assets.
Neither our firm, nor any of its supervised persons accepts compensation for the sale of securities or
other investment products, including asset-based sales charges or services fees from the sale of
mutual funds.
Separately Managed Account Services
:
Depending on the service utilized, program fees for the SMA services may be up to 2.00%. To calculate
the SMA program fee, Schwab multiplies the actual daily balance of your account by the daily pro rata
portion of the annual rate and then adds together the fees for each day of the month. The program
fee is billed to your account monthly. Redwood Park Advisors’ asset management fee is separate,
charged pro-rata, quarterly in advance, based on the value of your account on the last day of the
Termination and Refunds
previous quarter.
:
Either party may terminate the Advisory Agreement signed with our firm for Asset Management or
Comprehensive Portfolio Management services in writing at any time. Upon notice of termination
our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in
advance.
Financial Planning & Consulting clients may terminate their Agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee in effect in the
Agreement. Clients will receive a pro-rata refund of unearned fees based on the time and effort
expended by our firm.
Either Party to a Retirement Plan Consulting Agreement may terminate at any time, by providing
written notice to the other party. Full refunds will only be made in cases where cancellation occurs
within five (5) business days of signing an agreement. After five (5) business days from initial signing,
either party must provide the other party 30 days written notice to terminate billing. Billing will
terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis,
which takes into account work completed by our firm on behalf of the client. Clients will incur charges
for bona fide advisory services rendered up to the point of termination (determined as 30 days from
receipt of said written notice) and such fees will be due and payable.
Item 6: Performance-Based Fees and Side-by-Side Management
Our firm does not charge performance-based fees.
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Item 7: Types of Clients and Account Requirements
Our firm has the following types of clients:
•
•
•
•
Individuals and High Net Worth Individuals;
Trusts, Estates, and Charitable Organizations;
Pension, De�ined Contribution Plans, and Pro�it Sharing Plans; and
Corporations, Limited Liability Companies, and/or Other Business Types
Our �irm does not impose requirements for opening and maintaining accounts or otherwise
engaging us. Our �irm has the right to deny any client on a case-by-case basis.
Item 8: Methods of Analysis, Investment Strategies, and Risk of
Loss
Methods of Analysis:
We may use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Fundamental Analysis
: The analysis of a business's �inancial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a security there are two basic approaches one can use: bottom up analysis and top down analysis. The
terms are used to distinguish such analysis from other types of investment analysis, such as
quantitative and technical. Fundamental analysis is performed on historical and present data, but
with the goal of making �inancial forecasts. There are several possible objectives: (a) conduct a
company valuation and predict its potential price movement; (b) make a projection on its business
performance; (c) calculate its credit risk; and (d) predict the intrinsic value of the security.
Qualitative Analysis
: A type of analysis that uses subjective judgment based on unquanti�iable
information, such as management expertise, industry cycles, strength of research and development,
and labor relations. Qualitative analysis contrasts with fundamental analysis, that focuses on
numbers that can be found on company’s �inancial reports such as balance sheets and income
statements. The two techniques, however, will often be used together in order to examine a
company's operations and evaluate its potential as an investment opportunity. Qualitative analysis
deals with intangible, inexact observations than the mathematical one. This approach attempts to
exploit the kind of intelligence that machines (currently) lack; things like positive associations with a
brand, management trustworthiness, customer satisfaction, competitive advantage, and cultural
shifts which can be dif�icult to capture with numerical analysis. A risk of using qualitative analysis is
that subjective judgment may prove incorrect.
Sector Analysis
: Sector analysis involves identi�ication and analysis of various industries or
economic sectors that are likely to exhibit superior performance. Academic studies indicate that the
health of a stock's sector is as important as the performance of the individual stock itself. In other
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words, even the best stock located in a weak sector will often perform poorly because that sector is
out of favor. Each industry has differences in terms of its customer base, market share among �irms,
industry growth, competition, regulation, and business cycles. Learning how the industry operates
provides a deeper understanding of a company's �inancial health. One method of analyzing a
company's growth potential is examining whether the number of customers in the overall market is
expected to grow.
Quantitative Analysis
: The use of models, or algorithms, and screens to evaluate assets for
investment. The process usually consists of searching databases for patterns, such as correlations
among liquid assets or price-movement patterns (trend following or mean reversion). The results of
the analysis are used in the decision to buy or sell securities, and in the management of portfolio
characteristics. A risk in using quantitative analysis is that the methods or models used may be based
on assumptions that prove to be incorrect.
Technical Analysis
: An analysis methodology for forecasting the direction of prices through the
study of historical market data, primarily price and volume. A core principle of technical analysis is
that a market's price re�lects all relevant information, so their analysis looks at the history of a
security's trading pattern rather than external drivers such as economic, fundamental, and news
events. Technical analysts believe that price action tends to repeat itself due to investors collectively
tending towards patterned behavior, hence technical analysis focuses on identi�iable trends and
conditions. Technical analysis is widely used in conjunction with other types of investment analysis.
The risk associated with this type of analysis is that analysts use subjective judgment to decide which
pattern(s) a particular instrument re�lects at a given time. The interpretation of those patterns could
ultimately be incorrect.
Investment Strategies We Use
:
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizon among other considerations.
Asset Allocation
: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, return goals, investment time frame, and constraints. Asset allocation is
based on the principle that different assets behave differently in different markets and economic
conditions. A fundamental justi�ication for asset allocation is the notion that different asset classes
offer returns that are not correlated. Diversi�ication potentially reduces the overall risk of a portfolio
in terms of the variability of returns for a given level of expected return and risk. Although risk may
be reduced if correlations are not perfect, it is typically a forecast (wholly or in part) based on
statistical relationships (such as correlation and variance) that existed over some past period.
Expectations for return are often derived in the same way.
An asset class is a group of investments sharing similar characteristics, such as riskiness and return,
and are subject to the same laws and regulations. There are many types of assets that may or may not
be included in an asset allocation strategy. The "traditional" asset classes are: (a) Equity (stocks) –
examples of equity types include: value, dividend, growth, or sector-speci�ic (or a "blend" of any two
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Assets
or more of the preceding); large-cap, mid-cap, small-cap, or micro-cap; domestic, international
developed, emerging or frontier markets; (b) Fixed Income (bonds – examples of �ixed income types
include: corporate investment-grade or junk (high-yield); corporate, government; short-term,
intermediate, long-term; domestic, foreign, emerging markets); (d) Real Assets - examples of real
assets include: real estate, precious metals, commodities, and other tangle type assets; and (d) Cash
and/or Cash Equivalents – and example of a cash equivalent is money markets funds. Allocation
among these four primary asset classes provides a starting point. Sometimes included are hybrid
instruments such as convertible bonds and preferred stocks, which combine the characteristics of
bonds and stocks. Alternative assets that may be considered include: commodities such as precious
metals, nonferrous metals, agriculture, energy, and other; commercial or residential real estate (also
REITs); private equity and distressed; hedge funds and hedge fund strategies; collectibles such as art,
coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life
insurance products, etc.); derivatives such as options, collateralized debt obligations, futures; and
such as cryptocurrencies may be recommended in
foreign currency strategies (FX).Digital
Financial Plans or Consultations at the client’s request. However, direct investments in digital assets
must be executed in accounts held away from our �irm by the client themselves at their sole discretion.
There are several types of asset allocation strategies based on investment goals, risk tolerance, time
frames, and diversi�ication. The most common forms of asset allocation are strategic, dynamic,
tactical, and core-satellite.
• Strategic Asset Allocation
• Dynamic Asset Allocation
: The primary goal of a strategic asset allocation is to create an
asset mix that seeks to provide the optimal balance between expected risk and return for a
long- term investment horizon. Strategic asset allocation strategies are agnostic to economic
environments, such as, they do not change their allocation postures relative to changing
market or economic conditions.
• Tactical Asset Allocation
: Dynamic asset allocation is similar to strategic asset allocation
in that portfolios are built by allocating to an asset mix that seeks to provide the optimal
balance between expected risk and return for a long-term investment horizon. Like strategic
allocation strategies, dynamic strategies largely retain exposure to their core asset classes;
however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their
allocations to changes in the economic environment.
• Core-Satellite Asset Allocation
: Tactical asset allocation is a strategy in which an investor takes a
more active approach that tries to position a portfolio into those assets, sectors, or individual
stocks that show the most potential for perceived gains. While an original asset mix is
formulated much like a strategic or dynamic allocation, tactical strategies often trade more
frequently and are free to move entirely in and out of their core asset classes.
: Core-Satellite allocation strategies generally contain a 'core'
strategic element making up the most signi�icant portion of the portfolio, while applying a
dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this
way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical
allocation strategies mentioned above.
Third-Party Money Manager Selection/Analysis
: The analysis of the experience, investment
philosophies, and past performance of independent third-party investment managers is an attempt
to determine if that manager has demonstrated an ability to persistently perform over various
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economic and market cycles. Analysis is completed by monitoring the manager’s underlying holdings,
strategies, concentrations, leverage, along with an overall periodic risk assessment. Additionally, as
part of the due-diligence process, the manager’s compliance and business enterprise risks are
surveyed and reviewed. A risk of investing with a third-party manager who has been successful in the
past, is that they may not be able to replicate that success in the future. Our �irm does not control the
underlying investments in a third-party manager’s portfolio, there is a risk that a manager may
deviate from the stated investment mandate or strategy of the portfolio (style drift), making it a less
suitable investment for our clients. Moreover, our �irm does not control the manager’s daily business
and compliance operations and our �irm may be unaware, or the lack of internal controls necessary
to prevent business, regulatory, and/or reputational de�iciencies.
Short-Term Purchases
: When utilizing this strategy, our �irm may also purchase securities with the
idea of selling them within a relatively short time (typically a year or less). Our �irm may do this in an
attempt to take advantage of conditions that our �irm believes will soon result in a price swing in the
securities our �irm purchases.
Long-Term Purchases
: Our �irm may buy securities for your account and hold them for a relatively
long-term (more than a year), in anticipation, that the security’s value will appreciate over a long-
term horizon. The risk of this strategy is that our �irm could miss out on potential short-term gains
that could have been captured for your account, or it’s possible that the security’s value may decline
sharply before our �irm makes a decision to sell.
Preferred Securities in Portfolios We Manage
:
We prefer to invest our advisory clients in the following securities, provided that such securities are
appropriate to the goals of the client and are consistent with the client's investment objectives, risk
tolerance, time horizons, and investment constraints.
Exchange Traded Funds (“ETFs”):
An ETF is a type of is a type of security that involves a collection
of securities, such as stocks, that often passively track an underlying index; although they can invest
in any number of industry sectors or use various active strategies. ETFs are in many ways similar to
mutual funds, however, they are listed on exchanges and ETF shares trade throughout the day just
like ordinary stock. Most ETFs are designed to track an index, so their performance is close to that of
an index mutual fund, but they are not exact duplicates. Tracking error, or the difference between the
returns of a fund and the returns of the index, can arise due to differences in composition,
management fees, expenses, and handling of dividends, among other factors. ETFs benefit from
continuous pricing; they can be bought and sold on a stock exchange throughout the trading day.
Because ETFs trade like stocks, you can place orders just like individual stocks, such as limit orders,
good-until-canceled orders, stop-loss orders, etc. Some ETFs can also be sold short. Traditional
mutual funds are bought and redeemed based on their net asset values (“NAV”) at the end of the day.
ETFs are bought and sold at the market prices on the exchanges, which try to track the underlying
net asset value (“NAV”) but can trade at a premium or discount to NAV.
Mutual Funds
: A mutual fund is a type of financial vehicle made up of a pool of money collected from
many investors to invest in securities like stocks, bonds, and other assets. Mutual funds are operated
by professional investment managers, who allocate the fund's assets and attempt to produce capital
gains or income for the fund's investors. A mutual fund's portfolio is structured and maintained to
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match the investment objectives stated in its prospectus. Mutual funds give small or individual
investors access to professionally managed portfolios of equities, bonds, and other securities. Each
shareholder, therefore, participates proportionally in the gains or losses of the fund. Mutual funds
invest in a vast number of securities, and performance is usually tracked as the change in the total
market cap of the fund—derived by the aggregating performance of the underlying investments. Each
share represents an investor’s ownership of the fund’s holdings and the income those holdings
generate. The price that investors pay for mutual fund shares are the fund’s per share net asset value
(“NAV”) plus any shareholder fees that the fund imposes at the time of purchase (such as sales loads).
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time, nor can
they directly influence which securities the fund manager buys and sells or the timing of those trades.
The price at which an investor purchases or redeems mutual fund shares will typically depend on the
fund’s NAV, which is calculated daily after the market closes.
The benefits of investing through mutual funds include: (a) mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds; (c) some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases; and (d) liquidity, mutual fund
investors can readily redeem their shares at the current NAV, less any fees and charges assessed on
redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) investors might
have to pay sales charges, high annual fees, and other expenses regardless of how the fund performs;
(b)depending on the timing of their investment, investors may also have to pay taxes on any capital
gains distributions they receive. This includes instances where the fund performed poorly after
purchasing shares; and (c) investors typically cannot ascertain the exact make-up of a fund’s portfolio
and exact pricing at any given time, nor can they directly influence which securities the fund manager
buys and sells or the timing of those trades. With a mutual fund, the price at which an investor
purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not
calculate until many hours after the investor placed the order. In general, mutual funds must calculate
their NAV at least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor sells and makes a profit. Mutual funds are different because
investors who own mutual fund shares will owe income tax on any ordinary dividends in the year
the fund receives or reinvests them. In addition to owing taxes on any personal capital gains when
the investor sells shares, the investor may have to pay taxes each year on the fund’s internal capital
gains. That is because the law requires mutual funds to distribute capital gains to shareholders if the
fund sell securities for a profit.
Cash & Cash Equivalents
: Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s,
commercial paper, and money market funds. Generally, these assets are considered nonproductive
and will be exposed to in�lation risk and considerable opportunity cost risk. Our �irm may recommend
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cash and cash equivalents as part of our clients’ asset allocation when deemed appropriate and in
their best interest. Our �irm considers cash and cash equivalents to be an asset class. Therefore, our
�irm assess an advisory fee on cash and cash equivalents unless otherwise indicated in writing.
Fixed Income
: Fixed income broadly refers to types of investment securities that pays investors �ixed
interest or dividend payments until its maturity date. At maturity, investors are repaid the principal
amount they had invested. Government, corporate, and municipal bonds are the most common types
of �ixed income securities. Unlike equities that may pay no cash �lows to investors, or variable-income
securities, where payments can change based on some underlying measure—such as short-term
interest rates—the payments of a �ixed income security are known in advance. Fixed income investors
are sometimes retired individuals who rely on their investments to provide a regular, stable income
stream. This demographic tends to invest heavily in �ixed-income investments because of the
potential reliable returns offered. Fixed income investors who live on a set amount or budget, face
the risk of in�lation eroding their spending power.
The primary risk associated with fixed income investments is credit risk, the borrower defaulting on
the payment. Other considerations include interest rate and re-investment rate risk for longer-dated
bonds, and exchange rate risk for international securities. Fixed income securities are recommended
for investors seeking a capital preservation component for the portfolio, however the percentage of
the portfolio dedicated to fixed income depends on each client’s specific situation and investment
preferences. There is also an opportunity to diversify the fixed income component of a portfolio.
Riskier fixed income products, such as high yield bonds and longer-dated products can be combined
with short dated securities and investment grade bonds to balance the overall allocation.
Individual Common Stock
: A common stock is a security that represents fractional equity
ownership in a corporation. Equity represents the potential value of the company that would be
returned to a company’s shareholders if all of the assets were sold and all of the company's debt was
paid off. However, in the event of bankruptcy or liquidation, common shareholders have rights to a
company's assets only after bondholders, preferred shareholders, and other creditors and
debtholders are paid in full. Holders of most common stock exercise ownership rights by electing a
board of directors and voting on corporate policy. Investing directly in individual common stock
provides investors with more control over the timing of the investment and concentration. Having
the ability to decide when to buy or sell helps us manage gains or losses. Common stocks, however,
bear a greater amount of risk when compared to fixed income securities (bonds). Stocks should be
considered an important part of any investor’s capital appreciation allocation. However, with the
greater risk comes the greater potential for reward.
Cryptocurrencies
: A Cryptocurrency is a digital currency in which encryption techniques are used
to regulate the generation of units of currency and verify the transfer of funds, operating
independently of a central bank. In order for a Cryptocurrency to be traded, it must meet the criteria
of a digital asset framework. The framework covers several key areas including technology, security,
governance, scalability, regulations, liquidity, and economy. Only Cryptocurrencies that meet the
criteria of the digital asset framework can be traded by our Firm. Cryptocurrencies currently do not
face the same regulatory oversight that traditional currencies do. Cryptocurrencies, therefore, carry
a higher level of risk than other currency investments. Security is also a concern for digital currency
investments which make them subject to the additional risk of theft. Only a limited number of clients
may be suitable for this type of investment.
Cryptocurrency Products
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: We may recommend investment in digital (crypto) currency products.
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These products are typically structured as a trust or exchange traded fund (“ETF”) which pool capital
together to purchase holdings of digital currencies or derivatives based on their value. Such products
are extremely volatile and are suitable only as a means of diversification for investors with high-risk
tolerances. Furthermore, these securities can include high internal expense ratios, and may use
derivatives to achieve leverage or exposure in lieu of direct cryptocurrency holdings. This can result
in tracking error and may sell at a premium or discount to the market value of their underlying
holdings.
Private Funds
: A private fund is an investment vehicle that pools capital from a number of investors
and invests in securities and other instruments. In almost all cases, a private fund is a private
investment vehicle that is typically not registered under federal or state securities laws. So that
private funds do not have to register under these laws, issuers make the funds available only to
certain sophisticated investors, Accredited Investors or Qualified Purchasers, and cannot be offered
or sold to the general public. Private funds are generally smaller than mutual funds because they are
often limited to a small number of investors and have a more limited number of eligible investors.
Many, but not all private funds, use leverage as part of their investment strategies. Private funds
management fees typically include a base management fee along with a performance component. In
many cases, the fund’s managers may become “partners” with their clients by making personal
investments of their own assets in the fund. Most private funds offer their securities by providing an
offering memorandum or private placement memorandum, known as “PPM” for short.
The PPM covers important information for investors and investors should review this document
carefully and should consider conducting additional due diligence before investing in the private
fund. The primary risks of private funds include the following: (a) private funds are not sold publicly
and are therefore illiquid and an investor may not be able to exit a private fund or sell its interests in
the fund before the fund terminates.; and (b) private funds are subject to various other risks,
including risks associated with the types of securities that the private fund purchases or the type of
business issuing the private placement.
Risk of Loss
:
Investing in securities involves the risk of loss that clients should be prepared to bear. While markets
and investments may increase and the account(s) could enjoy a gain, it is also possible that markets
and investments may decrease, and the account(s) could suffer a loss. It is important that clients
understand the risks associated with investing, and that their assets are appropriately diversified to
match their investment objectives (risk and return) and constraints. Clients are encouraged to ask
our firm any questions regarding their risk tolerance.
Capital Risk
: Capital risk is one of the most basic, fundamental risks of investing, it is the risk that
you may lose part or 100% of your money. All investments carry some form of risk and the loss of
capital is generally a risk for any investment.
Currency Risk
: Fluctuations in the value of the currency may affect the value of some of your
investments. All currency is subject to swings in valuation, regardless of the currency denomination
of any particular investment you own, currency risk is a realistic concern. Currency risk is generally
a factor for investment instruments denominated in currencies other than the investor’s domestic
currency.
Company Risk
: When investing in stock positions, there is always inherent company specific risk.
This is also sometimes referred to as unsystematic risk which can potentially be removed through
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diversification. There is the risk that the company will perform poorly or have its value reduced based
on factors specific to the company or its industry. For example, if a company’s employees go on strike
or the company receives unfavorable media attention for its actions, the value of the company may
be reduced.
Economic Risk
: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are more economically sensitive and carry a
higher amount of economic risk. If an investment is issued by a party located in a country that
experiences large swings, from an economic standpoint, or in situations where certain elements of
an investment instrument are dependent on such countries, the investment instrument will generally
be subject to a higher level of economic risk.
ETF & Mutual Fund Risk
: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s expenses, including the potential
duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks
of owning the underlying securities the ETF or mutual fund holds.
Fixed Income Securities Risk
: Typically, the values of fixed-income securities move inversely to
changes in interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that the value will decline as interest rates rise, which may cause your account value
to decrease, and vice versa. How specific fixed income securities may react to changes in interest
rates will depend on the specific characteristics of each security. Fixed-income securities are also
subject to credit risk, prepayment risk, valuation risk, re-investment risk, and liquidity risk. Credit
risk is the chance that a bond issuer will fail to pay interest and/or principal as scheduled, or that
negative perceptions of the issuer’s ability to make such payments will cause the price of a bond to
decline.
Interest Rate Risk
: Certain investments involve the payment of a �ixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (�ixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
�ixed rate of interest will go down. The reverse is generally true as well.
Reinvestment Risk
: Some investments require reinvestment of interest or earnings. Reinvestment
risk is the possibility that cash �lows from an investment are unable to be reinvested at a rate equal
to the original investment’s potential rate of return. Reinvestment risk is most common in bond
investing, but any investment that generates cash �lows is exposed to this risk.
Cryptocurrency Risk
: When investing in cryptocurrencies, there is always a certain level of volatility
risk as a result of a decentralized currency. Different factors effect different cryptocurrencies and the
allocation of assets across different cryptocurrencies can hold a variety of risks. To mitigate these
risks, our �irm will always consider risks when selecting which cryptocurrency to purchase, and client
authorization is always required.
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Digital Asset Risk
: It is possible that many Digital Assets are never broadly accepted in the retail
marketplace, and thus investment may result in losing all of the asset’s value. In addition, the security
of trading and storing digital assets remains uncertain. Clients should be aware of the security risks
that surround purchasing or investing in digital assets.
Description of Material, Signi�icant or Unusual Risk
:
Our �irm generally invests client cash balances in money market funds, FDIC Insured Certi�icates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
�irm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in cash so
that our �irm may debit advisory fees for our services related to our Asset Management and
Comprehensive Portfolio Management services, as applicable.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Neither our �irm, nor any of its management persons have been subject to any criminal or civil actions,
administrative proceedings, or self-regulatory organization (SRO) proceedings.
Item 10: Other Financial Activities and Af�iliations
Neither our �irm, nor any of its management persons are registered, or have an application pending
to register, as a broker-dealer, or a registered representative of a broker-dealer. In addition, neither
our �irm, nor any of its management persons are registered or have an application pending to register,
as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an
associated person of the foregoing entities.
Our �irm may select and utilize third party money managers to assist in the management of client
accounts. Our �irm will always act in the client’s best interest and will ensure that any selected third-
party managers are properly licensed and registered to provide investment advice prior to
recommending the third-party manager.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
As a �iduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all
material facts and to act solely in the best interest of each of our clients at all times. Our �iduciary duty
is the underlying principle for our �irm’s Code of Ethics, which includes procedures for personal
securities transaction and insider trading. Our �irm requires all representatives to conduct business
with the highest level of ethical standards and to comply with all federal and state securities laws at
all times. Upon employment with our �irm, and at least annually thereafter, all representatives of our
�irm will acknowledge receipt, understanding and compliance with our �irm’s Code of Ethics. Our �irm
and representatives must conduct business in an honest, ethical, and fair manner and avoid all
circumstances that might negatively affect or appear to affect our duty of complete loyalty to all
clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a
potential client wishes to review our Code of Ethics and amendments in its entirety, a copy will be
provided promptly upon request.
Our �irm recognizes that the personal investment transactions of our representatives, demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried
out in a way that does not endanger the interest of any client. At the same time, our �irm also believes
that if investment goals are similar for clients and for our representatives, it is logical, and even
desirable, that there be common ownership of some securities.
In order to prevent con�licts of interest, our �irm has established procedures for transactions effected
1
. To monitor compliance with our personal trading
by our representatives for their personal accounts
policy, our �irm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client. Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics and amendments, a copy of which is available upon request. Further, our related persons will
refrain from buying or selling the same securities prior to buying or selling for our clients in the same
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her
day unless included in a block trade.
spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c)
which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a
direct or indirect beneficial interest in.
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Item 12: Brokerage Practices
Custodian and Brokers Used
:
Our firm does not maintain custody of client assets (although our firm may be deemed to have
custody of client assets if given the authority to withdraw assets from client accounts. See Item 15
Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use the Schwab Advisor Services division
of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the
qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab.
Schwab will hold client assets in a brokerage account and buy and sell securities when instructed.
While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether
to do so and open an account with Schwab by entering into an account agreement directly with them.
Our firm does not open the account. Even though the account is maintained at Schwab, our firm can
still use other brokers to execute trades, as described in the next paragraph.
How Brokers/Custodians are Selected:
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
•
•
•
•
•
•
•
•
•
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody).
capability to execute, clear and settle trades (buy and sell securities for client accounts).
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.).
breadth of investment products made available (stocks, bonds, mutual funds, exchange traded
funds (ETFs), etc.).
availability of investment research and tools that assist 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 them.
reputation, �inancial strength and stability of the provider.
prior service to our �irm and our other clients.
availability of other products and services that bene�it our �irm, as discussed below
(see “Products & Services Available from Schwab”)
Custody and Brokerage Cost
:
Schwab generally does not charge a separate fee for custody services but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab
account. In addition to commissions or asset-based fees, Schwab charges a �lat dollar amount as a
“prime broker” or “trade away” fee for each trade that our �irm has executed by a different broker-
dealer but where the securities bought or the funds from the securities sold are deposited (settled)
into a Schwab account. These fees are in addition to the commissions or other compensation paid to
the executing broker-dealer. Because of this, in order to minimize client trading costs, our �irm has
Schwab execute most trades for client accounts.
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Products and services available from Schwab
:
Schwab Advisor Services is Schwab’s business serving independent investment advisory �irms like
our �irm. They provide our �irm and clients, both those enrolled and not enrolled in the Program, 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 manage or administer our client accounts while others help
manage and grow our business. Schwab’s support services are generally available on an unsolicited
basis (our �irm does not have to request them) and at no charge to our �irm. The availability of
Schwab’s products and services is not based on the provision of particular investment advice, such as
purchasing particular securities for clients. Here is a more detailed description of Schwab’s support
services:
Services that bene�it clients
:
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that may directly benefit clients:
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Schwab’s and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
•
•
•
•
•
provides access to client account data (such as duplicate trade con�irmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-of�ice functions, recordkeeping and client reporting.
Services that generally only benefit only firm:
Schwab also offers other services intended to help 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 bene�its providers, human capital consultants, and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party
vendors to provide the services to our �irm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our �irm with other
bene�its, such as occasional business entertainment for our personnel.
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Schwab has agreed that when the assets in our clients’ accounts maintained at Schwab total at least
$45 million, it will pay for certain research, technology and marketing products and services provided
to us by third parties. The availability of the services described above from Schwab bene�its us
because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so
long as we keep a total of at least $15 million of client assets in accounts at Schwab. In addition, we
don’t have to pay for certain third-party research, technology and marketing products, and services
once the total of our clients’ assets maintained in accounts at Schwab reaches $45 million. These
required amounts of client assets ($15 million and $45 million) may give us an incentive to require
that you maintain your account with Schwab based on our interest in receiving Schwab’s and the third
parties’ services that bene�it our business rather than based on your interest in receiving the best
value in custody services and the most favorable execution of your transactions. This is a potential
con�lict of interest. We believe, however, that our selection of Schwab as custodian and broker is in
the best interests of our clients. It is primarily supported by the scope, quality, and price of Schwab’s
services and not Schwab’s or third parties’ services that bene�it only us or may only indirectly bene�it
you. We maintain more than $45 million in client assets under management, and do not believe that
maintaining at least $45 million of those assets at Schwab to avoid paying Schwab quarterly service
fees presents a material con�lict of interest.
Irrespective of direct or indirect bene�its to our client through Schwab, our �irm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our �irm or
associated persons.
Our Interest in Schwab’s Services
:
The availability of these services from Schwab bene�its our �irm because our �irm does not have to
produce or purchase them. Our �irm does not have to pay for these services, and they are not
contingent upon committing any speci�ic amount of business to Schwab in trading commissions or
assets in custody.
With respect to the Program, our firm does not pay Schwab Wealth Investment Advisory (“SWIA”)
fees for its services in the Program so long as our firm maintains $100 million in client assets in
accounts at Schwab that are not enrolled in the Program. Currently, our firm meets this asset
requirement. If our firm does not meet this condition, then our firm will pay SWIA an annual fee of
0.10% (10 basis points) on the value of our client assets in the Program. This fee arrangement gives
our firm an incentive to recommend or require that clients with accounts not enrolled in the Program
be maintained with Schwab.
In light of our arrangements with Schwab, a conflict of interest exists as our firm may have incentive
to require that clients maintain their accounts with Schwab based on our interest in receiving
Schwab’s services that benefit our firm rather than based on client interest in receiving the best value
in custody services and the most favorable execution of transactions. As part of our fiduciary duty to
our clients, our firm will always endeavor to put the interests of our clients first. Clients should be
aware, however, that the receipt of economic benefits by our firm or our related persons creates a
potential conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial
recommendation. Our firm examined this potential conflict of interest when our firm chose to
recommend Schwab and have determined that the recommendation is in the best interest of our firm’s
clients and satisfies our fiduciary obligations, including our duty to seek best execution.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
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Redwood Park Advisors LLC
Page 22 of 30
March 2026
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions. Our firm believes that the selection of Schwab as a custodian and broker is the best
interest of our clients. It is primarily supported by the scope, quality, and price of Schwab’s services,
and not Schwab’s services that only benefit our firm.
Soft Dollars
:
Our firm has not received any soft dollar compensation within the prior year.
Client Brokerage Commissions
:
Schwab does not make client brokerage commissions generated by client transactions available for
our firm’s use.
Brokerage for Client Referrals
:
Our firm does not receive brokerage for client referrals.
Directed Brokerage
:
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of Schwab’s order routing to different counter parties with whom orders for the
purchase or sale of securities are placed for execution, and the commission rates at which such
securities transactions are affected. Our firm routinely requests that clients direct us to execute
through a specified broker- dealer. Our firm recommends the use of Schwab. Each client will be
required to establish their account(s) with Schwab if not already done. Please note that not all advisers
have this requirement.
Special Considerations for ERISA Clients
:
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
:
Our firm does not allow client-directed brokerage outside our recommendations. Our firm currently
recommends Charles Schwab for client brokerage services.
Aggregation of Purchase or Sale
:
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the
same security for numerous accounts served by our firm, which involve accounts with similar
investment objectives. Although such concurrent authorizations potentially could be either
advantageous or disadvantageous to any one or more accounts, they are affected only when our firm
believes that to do so will be in the best interest of the effected accounts. When such concurrent
authorizations occur, the objective is to allocate the executions in a manner which is deemed
equitable to the accounts involved. In any given situation, our firm attempts to allocate trade
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Redwood Park Advisors LLC
Page 23 of 30
March 2026
executions in the most equitable manner possible, taking into consideration client objectives, current
asset allocation and availability of funds using price averaging, proration, and consistently non-
Item 13: Review of Accounts or Financial Plans
arbitrary methods of allocation.
The firm’s Chief Compliance Officer, Benjamin Pettigrew, or David Smith, Managing Partner, reviews
accounts on at least an annual basis for our Asset Management, Comprehensive Portfolio
Management, and Third-Party Money Management clients. The nature of these reviews is to learn
whether client accounts are in line with their investment objectives, appropriately positioned based
on market conditions, and investment policies, if applicable. Our firm does not provide written
reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis
when our Asset Management, Comprehensive Portfolio Management, and Third-Party Money
Management clients are contacted.
Our firm may review client accounts more frequently than described above. Among the factors which
may trigger an off-cycle review are major market or economic events, the client’s life events, requests
by the client, etc.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the
service. Our firm also provides ongoing services where clients are met with upon their request to
discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients
do not receive written or verbal updated reports regarding their plans unless they choose to engage
our firm for ongoing services.
Item 14: Client Referrals and Other Compensation
Client Referrals
:
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
Schwab
:
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
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Redwood Park Advisors LLC
March 2026
Item 15: Custody
Deduction of Advisory Fees
:
While our �irm does not maintain physical custody of client assets (which are maintained by a
quali�ied custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to deduct advisory fees from client accounts in addition to “Third Party Money
Movements”, as further described below. All of our clients receive account statements directly from
their quali�ied custodian(s) at least quarterly upon opening of an account. We urge our clients to
carefully review these statements. Additionally, if our �irm decides to send its own account statements
to clients, such statements will include a legend that recommends the client compare the account
statements received from the quali�ied custodian with those received from our �irm. Clients are
encouraged to raise any questions with us about the custody, safety or security of their assets and our
custodial recommendations.
Third Party Money Movements
:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clari�ied that an adviser who has the power to disburse client
funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As
such, our �irm has adopted the following safeguards in conjunction with our custodian:
•
•
•
•
•
•
•
The client provides an instruction to the quali�ied custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the quali�ied custodian’s
form or separately, to direct transfers to the third party either on a speci�ied schedule or from
time to time.
The client’s quali�ied custodian performs appropriate veri�ication of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a transfer
of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s quali�ied
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s quali�ied custodian sends the client, in writing, an initial notice con�irming the
instruction and an annual notice recon�irming the instruction.
Item 16: Investment Discretion
Clients have the option of providing our �irm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our �irm is
authorized to execute securities transactions, determine which securities are bought and sold, and
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Redwood Park Advisors LLC
Page 25 of 30
March 2026
the total amount to be bought and sold. Should clients grant our �irm non-discretionary authority, our
�irm would be required to obtain the client’s permission prior to effecting securities transactions.
Limitations may be imposed by the client in the form of speci�ic constraints on any of these areas of
discretion with our �irm’s written acknowledgement.
Item 17: Voting Client Securities
Our �irm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. If proxies are sent to our �irm, our
�irm will forward them to the appropriate client and ask the party who sent them to mail them directly
to the client in the future. Clients may call, write or email us to discuss questions they may have about
particular proxy votes or other solicitations, but the ultimate decision on voting the proxy remains
with the client.
Third-party money managers selected or recommended by our �irm may vote proxies for clients.
Therefore, except in the event a third-party money manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
bene�icially owned by the client shall be voted; and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Therefore (except for proxies that may be voted by a third-party money manager),
our �irm and/or the client shall instruct the quali�ied custodian to forward to copies of all proxies and
shareholder communications relating to the client’s investment assets.
Item 18: Financial Information
Inclusion of balance sheet
:
Our �irm does not require nor is prepayment solicited for more than $1,200 in fees per client, 6
months or more in advance. Therefore, our �irm has not included a balance sheet for our most recent
�iscal year.
Disclosure of �inancial condition
:
Our �irm has nothing to disclose in this regard.
Bankruptcy Petition
:
•
Our firm is not required to provide financial information in this Brochure because:
•
•
•
Our �irm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our �irm does not take custody of client funds or securities.
Our �irm does not have a �inancial condition or commitment that impairs our ability to meet
contractual and �iduciary obligations to clients.
Our �irm has never been the subject of a bankruptcy proceeding.
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Redwood Park Advisors LLC
March 2026
Appendix A: Privacy Policy - Redwood Park Advisors Privacy
Notice
PRIVACY NOTICE
Maintaining the trust and confidence of our clients is a high priority. That is why we want you to
understand how we protect your privacy when we collect and use information about you, and the
steps that we take to safeguard that information. This notice is provided to you on behalf of
Redwood Park Advisors, LLC (“RPA”).
Information We Collect: In connection with providing investment products, financial advice, or
other services, we obtain non-public personal information about you, including:
•
•
•
•
Information we receive from you on account applications, such as your address, date of birth,
Social Security Number, occupation, financial goals, assets and income;
Information about your transactions with us, our affiliates, or others;
Information about your visits to our website. We store records of the activities on our sites in our
web server logs, which automatically capture and save the information electronically. The
information we collect helps us administer the site, analyze its usage, protect the website and its
content from inappropriate use, and improve the user’s experience.
Information received from credit or service bureaus or other third parties, such as your credit
history or employment status.
Categories of Information We Disclose: We may only disclose information that we collect in accordance
with this policy. RPA does not sell customer lists and will not sell your name to telemarketers.
SMS Privacy Policy: No mobile information will be shared or collected with third parties/affiliates for
marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and
consent; this information will not be shared with any third parties.
Categories of Parties to Whom We Disclose: We will not disclose information regarding you or your
account at RPA, except under the following circumstances:
•
•
•
To entities that perform services for us or function on our behalf, including financial service
providers, such as a clearing broker-dealer, investment company, or insurance company, other
investment advisers;
To consumer reporting agencies,
To third parties who perform services or marketing, client resource management, or other parties
to help manage your account on our behalf;
To your attorney, trustee, or anyone else who represents you in a fiduciary capacity;
To our attorneys, accountants, or auditors; and
To government entities or other third parties in response to subpoenas or other legal processes as
•
•
•
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Redwood Park Advisors LLC
March 2026
required by law or to comply with regulatory inquiries.
How We Use Information: Information may be used among companies that perform support services for
us, such as data processors, client relationship management technology, technical systems consultants,
and programmers, or companies that help us market products and services to you for a number of
purposes, such as:
•
•
•
To protect your accounts/non-public information from unauthorized access or identity theft;
To process your requests such as securities purchases and sales;
To establish or maintain an account with an unaffiliated third party, such as a clearing broker-
dealer providing services to you and/or RPA;
To service your accounts, such as by issuing checks and account statements;
To comply with Federal, State, and Self-Regulatory Organization requirements;
To keep you informed about financial services of interest to you.
•
•
•
Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using
eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential
marketing use of that information has been clearly, conspicuously, and concisely disclosed to the
consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt
out of receiving the marketing solicitations; and (3) the consumer has not opted out. RPA does not receive
information regarding marketing eligibility from affiliates to make solicitations.
Our Security Policy: We restrict access to nonpublic personal information about you to those individuals
who need to know that information to provide products or services to you and perform their respective
duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client
information.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity
theft. We have developed an ITPP to adequately identify and detect potential red-flags to prevent and
mitigate identity theft.
Investor Information Security Incident Notification. In addition to the safeguards described above,
Redwood Park Advisors maintains policies and procedures designed to identify, respond to, and mitigate
any incident involving unauthorized access to or use of investors’ nonpublic personal information. If
Redwood Park Advisors determines that sensitive investor information has been, or is reasonably likely to
have been, accessed or used without authorization, we will provide notice to affected investors as soon
as practicable, but no later than thirty (30) days after becoming aware of the incident, in accordance
with applicable federal regulations. We may also provide notice to regulators, law enforcement, or other
third parties as required or permitted by law.
Cyber Security: Internal policies and procedures are in place to address cyber security. A copy of this policy
is available upon request.
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Redwood Park Advisors LLC
March 2026
Departing Investment Adviser Representatives (“IARs”):
If your IAR’s affiliation with RPA ends and he or she joins a non-affiliated securities broker-dealer or
registered investment adviser, RPA will permit the IAR to use certain client contact information to solicit
clients to join the IAR's new financial services provider. The client contact information that the IAR may use
is limited to your name, address, email address, phone number and account title.
Certain states have adopted a requirement for you to approve the sharing of information in advance,
otherwise known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts,
Maine, Alaska, North Dakota or Vermont), then RPA will require your consent to share your information with
unaffiliated third parties who are not servicing your account. State requirements vary and may change
without notice.
Succession Planning: In the event that the owner(s) of RPA retire, become incapacitated, or perish
unexpectedly, your information would be disclosed to an unaffiliated third party for the purposes of
facilitating a business succession plan. A change in control of ownership of RPA would require your
consent, as dictated by your signed agreement with RPA, in order to continue providing services to you.
Your Right to Opt Out: Federal privacy laws give you the right to restrict us from sharing your personal
financial information. These laws balance your right to privacy with RPA’ need to provide information for
normal business purposes. You have the right to opt out of sharing certain information with affiliated and
unaffiliated companies of our firm. Choosing to restrict the sharing of your personal financial information
will not apply to (1) your information that we may share with companies that help promote and market our
own products or products offered under a joint agreement with another company; (2) records of your
transactions such as your loan payments, credit card or debit card purchases, and checking and savings
account statements to firms that provide data processing and mailing services for our firm; (3) information
about you in response to a court order; and (4) your payment history on loans and credit cards to credit
bureaus. If you opt out, you limit the extent to which RPA can provide your personal financial information to
non-affiliated companies. You may opt out of the disclosure of nonpublic personal financial information to
non-affiliates by contacting RPA at (866) 579 - 8808.
Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our
Privacy Policy will continue to apply to you.
Complaint Notification: Please direct complaints to: Benjamin Pettigrew or Dave Smith at Redwood Park
Advisors, LLC, 3 Twin Dolphin Drive, Suite 210 Redwood City, CA 94065; (866) 579 - 8808.
Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate
confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please
contact us at: Redwood Park Advisors, LLC, 3 Twin Dolphin Drive, Suite 210 Redwood City, CA 94065;
(866) 579 - 8808.
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Redwood Park Advisors LLC
March 2026
Appendix B: ERISA 408b-2 Disclosures - March 11, 2026
ERISA 408(b)(2) Disclosure
Redwood Park Advisors
March 11, 2026
This disclosure is being provided to you in accordance with the United States Department of
Labor's final regulation under Section 408(b)(2) of the Employee Retirement Income Security
Act of 1974 (ERISA). As a fiduciary under ERISA and as a SEC registered investment adviser,
this disclosure describes the services that we provide to your retirement plan and the fees
and other compensation that we receive for those services.
•
Services Provided
We provide the following services to your retirement plan:
Investment advisory services: We provide
investment advice to your plan's
fiduciaries, including recommendations on asset allocation, investment selection,
and portfolio rebalancing.
• Portfolio management services: We implement the investment recommendations
that we make to your plan's fiduciaries. This includes placing trades, monitoring
investments, and rebalancing the portfolio as needed.
Fees and Compensation
We receive the following fees and compensation for the services that we provide to your
retirement plan:
•
Investment advisory fee: We charge an annual investment advisory fee reflected in
your Client Agreement, Schedule A, and is charged as a percentage of the plan's
assets under management. Redwood Park Advisor’s management fee will not exceed
1.00%.
Additional Information
For more information about the services that we provide to your retirement plan and the fees
and compensation that we receive, please refer to your plan's investment management
agreement and our Form ADV Part 2A.
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Redwood Park Advisors LLC