Overview
- Headquarters
- Atlanta, GA
- Average Client Assets
- $2.5 million
- SEC CRD Number
- 309672
Fee Structure
Primary Fee Schedule (REGIMEN WEALTH PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.65% |
| $10,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $49,500 | 0.99% |
| $10 million | $82,000 | 0.82% |
| $50 million | $282,000 | 0.56% |
| $100 million | $532,000 | 0.53% |
Clients
- HNW Share of Firm Assets
- 88.38%
- Total Client Accounts
- 738
- Discretionary Accounts
- 738
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
Additional Brochure: REGIMEN WEALTH PART 2A BROCHURE (2026-04-10)
View Document Text
Disclosure Brochure
April 2026
REGIMEN WEALTH, LLC
ADV Part 2A
3300 Riverwood Pkwy, Suite 1030
Atlanta, GA 30339
(770) 738-8200
www.regimenwealth.com
This brochure provides information about the qualifications and business practices of Regimen Wealth, LLC
(hereinafter “Regimen Wealth” or the “Firm”). If you have any questions about the contents of this brochure,
please contact the Firm at the telephone number listed above. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities
authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov.
Regimen Wealth is a registered investment adviser. Registration does not imply any level of skill or training.
Disclosure Brochure
Item 2. Material Changes
In this Item, Regimen Wealth is required to discuss any material changes that have been made to the brochure
since the last annual amendment. Following is a summary of material changes to Regimen Wealth’s Form ADV
Part 2A (the “Brochure”) since the last annual update filing on March 12, 2026:
Item 4 – Removed ERISA disclosure for retirement planning
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Disclosure Brochure
Item 3. Table of Contents
Item 2. Material Changes ............................................................................................................................................. 2
Item 3. Table of Contents ............................................................................................................................................. 3
Item 4. Advisory Business ........................................................................................................................................... 4
Item 5. Fees and Compensation ................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ............................................................................... 9
Item 7. Types of Clients ............................................................................................................................................... 9
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 9
Item 9. Disciplinary Information................................................................................................................................ 13
Item 10. Other Financial Industry Activities and Affiliations ................................................................................... 13
Item 11. Code of Ethics .............................................................................................................................................. 13
Item 12. Brokerage Practices ..................................................................................................................................... 14
Item 13. Review of Accounts ..................................................................................................................................... 17
Item 14. Client Referrals and Other Compensation ................................................................................................... 17
Item 15. Custody ........................................................................................................................................................ 17
Item 16. Investment Discretion .................................................................................................................................. 18
Item 17. Voting Client Securities ............................................................................................................................... 18
Item 18. Financial Information .................................................................................................................................. 18
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Disclosure Brochure
Item 4. Advisory Business
Regimen Wealth offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to Regimen Wealth rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with Regimen Wealth setting forth the
relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
Regimen Wealth filed for registration as an investment adviser in June 2020 and is owned by Ian Alexandre
Weinstein and Aiki Altmets. As of December 31, 2025 Regimen Wealth had $365,160,462 in assets under
management, all of which were managed on a discretionary basis. While this brochure generally describes the
business of Regimen Wealth, certain sections also discuss the activities of its Supervised Persons, which refer
to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar
functions), employees or other persons who provide investment advice on Regimen Wealth’s behalf and are
subject to the Firm’s supervision or control.
Financial Planning and Consulting Services
Regimen Wealth offers clients a broad range of financial planning and consulting services, which include
any or all of the following functions:
•
Debt Management
•
Cash Flow Analysis and
Planning
•
Pension Strategies
•
Goal Planning
•
Protection
Planning
•
Estate Planning
Strategies
•
Social Security
Analysis
•
Compensation Package
Analysis
•
Employee Benefit
Analysis
•
Stock Option Planning
•
Retirement Planning
•
Tax Planning Strategies
•
Education Planning
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Disclosure Brochure
While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, Regimen Wealth is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized
to rely on such information. Regimen Wealth recommends certain clients engage the Firm for additional
related services and/or other professionals to implement its insurance recommendations (e.g. term life and
disability insurance). Clients are advised that a conflict of interest exists for the Firm to recommend that
clients engage Regimen Wealth or its affiliates to provide (or continue to provide) additional services for
compensation, including investment management services and insurance products. Clients retain absolute
discretion over all decisions regarding implementation and are under no obligation to act upon any of the
recommendations made by Regimen Wealth under a financial planning or consulting engagement. Clients
are advised that it remains their responsibility to promptly notify the Firm of any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or revising Regimen Wealth’s
recommendations and/or services.
Investment and Wealth Management Services
Regimen Wealth manages client investment portfolios on a discretionary basis. Regimen Wealth frequently
provides clients with wealth management services which include a broad range of financial planning and
consulting services as well as discretionary management of investment portfolios.
The securities utilized by Regimen Wealth for investment in client accounts primarily consist of exchange
traded funds (ETFs), but we may also invest in equity securities mutual funds, corporate bonds, REITS, fixed
and variable annuities, insurance products, and private investment vehicles, among others, if we determine
such investments fit within a client’s objectives and are in the best interest of our clients. Regimen Wealth
may also utilize independent investment managers who have specialized expertise in certain disciplines when
appropriate for the client (“Independent Managers”).
Where appropriate, the Firm also provides advice about any type of legacy position or other investment held
in client portfolios, but clients should not assume that these assets are being continuously monitored or
otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Regimen Wealth to
manage and/or advise on certain investment products that are not maintained at their primary custodian, such
as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and
qualified tuition plans (i.e. 529 plans). In these situations, Regimen Wealth directs or recommends the
allocation of client assets among the various investment options available with the product. These assets are
generally maintained at the underwriting insurance company or the custodian designated by the product’s
provider.
Regimen Wealth tailors its advisory services to meet the needs of its individual clients and seeks to ensure,
on a continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. Regimen Wealth consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints, and other related factors relevant to the management of their
portfolios. Clients are advised to promptly notify Regimen Wealth if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios. Clients can impose
reasonable restrictions or mandates on the management of their accounts if Regimen Wealth determines, in
its sole discretion, the conditions would not materially impact the performance of a management strategy or
prove overly burdensome to the Firm’s management efforts.
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Disclosure Brochure
When providing investment management services to retirement plans, Regimen Wealth may be providing
the services as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written
description of Regimen Wealth’s fiduciary status, the specific services to be rendered and all direct and
indirect compensation the Firm reasonably expects under the engagement.
Use of Independent Managers
As mentioned above, Regimen Wealth selects certain Independent Managers to actively manage a portion of
its clients’ assets. The specific terms and conditions under which a Regimen Wealth engages an Independent
Manager are set forth in a separate written agreement with the designated Independent Manager. That
agreement is between the Firm and the Independent Manager (often called a subadvisor or separate account
manager). In addition to this brochure, clients will also receive the written disclosure documents of the
respective Independent Managers engaged to manage their assets.
Regimen Wealth evaluates a variety of information about Independent Managers, which includes the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to
assess the Independent Managers’ investment strategies, past performance and risk results in relation to its
clients’ individual portfolio allocations and risk exposure. Regimen Wealth also takes into consideration each
Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
research capabilities, among other factors.
Regimen Wealth continues to provide services relative to the discretionary selection of the Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by
Independent Managers. Regimen Wealth seeks to ensure the Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives and overall best interests.
Item 5. Fees and Compensation
Regimen Wealth offers services on a fee basis, which includes fixed fees, as well as fees based upon assets
under management.
Financial Planning and Consulting Fees
Regimen Wealth charges a fixed fee for financial planning and consulting projects under a stand-alone
engagement. These fees are negotiable, but range from $3,000 to $100,000, depending upon the scope and
complexity of the services and the professional rendering the financial planning and/or the consulting
services. The fee can be for a defined project, such as the delivery of a plan, or for ongoing services. If the
client engages the Firm for additional investment advisory services, Regimen Wealth can offset all or a
portion of its fees for those services based upon the amount paid for the financial planning and/or consulting
services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory
Agreement. For project-based engagements, Regimen Wealth requires the full fee payable upon execution
of the Advisory Agreement for the financial planning or consulting project. All project-based engagements
will be completed within six months. Ongoing engagements are charged a fixed annual fee billed monthly.
Payments start with the execution of the Advisory Agreement. Clients can choose the method of payment,
either the fee is charged to a credit card or ACH.
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Disclosure Brochure
Investment Management Fees
Regimen Wealth offers investment management services for an annual fee based on the amount of assets
under the Firm’s management. This management fee varies with breakpoints in accordance with the
following schedule. The specific fee will be agreed upon with the client and will depend upon a number of
factors, including the size and composition of a client’s portfolio, the type and amount of services rendered
and the individual(s) providing the services.
PORTFOLIO VALUE
BASE FEE
1.25%
First $1,000,000
1.00%
Next $1,000,001 - $3,000,000
Next $3,000,001 - $5,000,000
0.85%
Next $5,000,001 - $10,000,000 0.65%
Above $10,000,000
0.50%
$$10,000$10,000,000
Unless stated otherwise, Regimen’s policy is to include all related client accounts, specifically the accounts
of direct family members sharing the same residence address, for purposes of determining a client’s Portfolio
Value of assets.
Clients with $3,250,000 or more in assets under management have the option to receive Wealth Management
services which will include comprehensive financial planning, while those with less will pay a separate fee
for financial planning and consulting services. The assets under management for financial planning purposes
will be evaluated annually during the client’s service renewal month. The annual fee is prorated and charged
monthly, in advance, based upon the market value of the assets being managed by Regimen Wealth on the
last day of the previous month as determined by a party independent from the Firm (including the client’s
custodian or another third-party). Insurance products billed as part of fees based upon assets under
management will be charged either quarterly in advance or quarterly in arrears based on the individual
insurance carrier. The fee is based upon the market value of the assets being managed by Regimen Wealth
on the last day of the previous quarter. If assets are deposited into or withdrawn from an account after the
inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim
change in portfolio value as related to the deposit/withdrawal and billed or charged not later than at the time
of the next billing.
For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory
agreement is terminated, the fee for the final billing period is prorated through the effective date of the
termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as
appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), Regimen Wealth can negotiate a
fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the
Firm to recommend that clients engage Regimen Wealth for additional services for compensation, including
rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute
discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the
recommendations.
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Disclosure Brochure
Retirement Plan Consulting Fees
Regimen Wealth charges an asset-based fee to provide clients with retirement plan consulting services. Each
engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor,
as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered and
the amount of assets to be advised on.
Fee Discretion
Regimen Wealth may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such
as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account retention,
pro bono activities, or competitive purposes.
Additional Fees and Expenses
In connection with Regimen Wealth’s management of an account, a client may incur fees and/or expenses
separate from and in addition to Regimen Wealth’s advisory fee. These additional fees may include
transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate
independent manager (and the manager’s platform manager, if any), limited partnership, or other advisor,
transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges,
taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where
applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related
costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account.
The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding
brokerage practices.
Direct Fee Debit
Clients provide Regimen Wealth and/or certain Independent Managers with the authority to directly debit
their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified
custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed
to send statements to clients not less than quarterly detailing all account transactions, including any amounts
paid to Regimen Wealth.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to Regimen Wealth’s
right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right
to liquidate any transferred securities or declines to accept particular securities into a client’s account.
Clients can withdraw account assets on notice to Regimen Wealth, subject to the usual and customary
securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. Regimen Wealth may
consult with its clients about the options and implications of transferring securities. Clients are advised that
when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption
fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
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Disclosure Brochure
Outside Compensation for the Sale of Securities or Other Investment Products to Clients
Regimen Wealth does not buy or sell securities and does not receive any compensation for securities
transactions in any client account, other than the investment advisory fees noted above. As described in
Item 4, in limited situations the Firm receives commission-based compensation for the implementation of
fixed insurance products (e.g. term life or disability insurance) stemming from financial planning and
consulting recommendations. This practice presents a conflict of interest because the Firm has an incentive
to recommend fixed insurance products to clients for the purpose of generating additional revenue rather
than solely based on a client’s needs. The Firm addresses this conflict by requiring its supervised persons
to act in the best interests of its clients when making such recommendations (e.g. insurance coverage gap
identified). However, clients are under no obligation to purchase insurance products through our Firm and
affiliated personnel.
Item 6. Performance-Based Fees and Side-by-Side Management
Regimen Wealth does not provide any services for a performance-based fee (i.e., a fee based on a share of
capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
Regimen Wealth offers services primarily to individuals and high net worth individuals, but may also
provide services to corporations and other business entities, and profit sharing plans.
Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss
Methods of Analysis
Regimen Wealth utilizes a combination of fundamental, technical, cyclical, and behavioral finance methods
of analysis.
Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position
of a particular fund or issuer. For Regimen Wealth, this process typically involves an analysis of an issuer’s
management team, investment strategies, style drift, past performance, reputation, and financial strength in
relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A
substantial risk in relying upon fundamental analysis is that while the overall health and position of a
company may be good, evolving market conditions may negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information in
determining the recommendations made to clients. Technical analysis may involve the use of mathematical
based indicators and charts, such as moving averages and price correlations, to identify market patterns and
trends which may be based on investor sentiment rather than the fundamentals of the company. A substantial
risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in
the future. Even if the trend will eventually reoccur, there is no guarantee that Regimen Wealth will be able
to accurately predict such a reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a
macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall
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Disclosure Brochure
fundamental analysis of the health of the particular company that Regimen Wealth is recommending. The
risks with cyclical analysis are similar to those of technical analysis.
Behavioral finance analysis involves an examination of conventional economics as well as behavioral and
cognitive psychological factors. Behavioral finance methodology seeks to combine a qualitative and
quantitative approach to provide explanations for why individuals may, at times, make irrational financial
decisions. Where conventional financial theories have failed to explain certain patterns, the behavioral
finance methodology investigates the underlying reasons and biases that cause some people to behave against
their best interests. The risks relating to behavior finance analysis are that it relies on spotting trends in human
behavior that may not predict future trends.
Investment Strategies
Regimen Wealth develops portfolio allocations from regular consultations with clients, and understanding
their individual risk profile and goals, before implementing mutually agreed upon solutions tailored to their
objectives. Depending on the client’s needs, this process may include preparing a financial plan, supported
by extensive quantitative and qualitative analysis.
Regimen Wealth follows a rigorous process to identify, monitor, and leverage quality investment products
while employing a combination of fundamental, technical, cyclical and quantitative analysis.
Risk of Loss
The following list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved with respect to the Firm’s investment management activities. Clients should consult with their legal,
tax, and other advisors before engaging the Firm to provide investment management services on their behalf.
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of Regimen Wealth’s recommendations and/or
investment decisions may depend to a great extent upon correctly assessing the future course of price
movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by
financial markets and economic conditions throughout the world. There can be no assurance that Regimen
Wealth will be able to predict these price movements accurately or capitalize on any such assumptions.
Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other things,
interest rates, general economic conditions, the condition of the financial markets, the financial condition of
the issuers of such assets, changing supply and demand relationships, and programs and policies of
governments.
Cash Management Risks
The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of
investments, during which time an advisory account may be prevented from achieving its investment
objective.
Equity-Related Securities and Instruments
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Disclosure Brochure
The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national
securities exchanges and over-the-counter markets. The value of equity securities varies in response to many
factors. These factors include, without limitation, factors specific to an issuer, and factors specific to the
industry in which the issuer participates. Individual companies may report poor results or be negatively
affected by industry and/or economic trends and developments, and the stock prices of such companies may
suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that
stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced
periods of substantial price volatility in the past and may do so again in the future. In addition, investments
in small-capitalization, midcapitalization, and financially distressed companies may be subject to more
abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face
greater business risks.
Fixed Income Securities
While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond
portfolios, clients who invest in this product can lose money, including losing a portion of their original
investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any
particular level of performance. Below is a representative list of the types of risks clients should consider
before investing in this product.
•
Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically,
a rise in interest rates will negatively affect bond prices. The longer the duration and average maturity of a
portfolio, the greater the likely reaction to interest rate moves.
• Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or
principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of
the issuer deteriorates.
• Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there
is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value.
In such a market, bond prices may fall.
• Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an
issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield.
During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased
volatility.
• Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be prepaid. These
prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield.
• Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of
mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s
duration and average maturity and increase its sensitivity to rising rates and its potential for price declines.
Interest Rate Risks
In addition to interest rate risks inherent with fixed income securities, as described above, there are similar
risks with other securities or instruments held by clients. Interest rates may fluctuate significantly, causing
price volatility.
Mutual Funds and ETFs
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Disclosure Brochure
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per
share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees).
The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV
fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual
fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors,
lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Use of Independent Managers
As stated above, Regimen Wealth selects certain Independent Managers to manage a portion of its clients’
assets. In these situations, Regimen Wealth continues to conduct ongoing due diligence of such managers,
but such recommendations rely to a great extent on the Independent Managers’ ability to successfully
implement their investment strategies. In addition, Regimen Wealth does not have the ability to supervise
the Independent Managers on a day-to-day basis.
Real Estate Investment Trusts (REITs)
Regimen Wealth recommends an investment in, or allocate assets among, various real estate investment
trusts (“REITs”), the shares of which exist in the form of either publicly traded or privately placed securities.
REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage
related holdings. Many REITs hold heavy concentrations of investments tied to commercial and/or
residential developments, which inherently subject REIT investors to the risks associated with a downturn
in the real estate market. Investments linked to certain regions that experience greater volatility in the local
real estate market may give rise to large fluctuations in the value of the vehicle’s shares. Mortgage related
holdings may give rise to additional concerns pertaining to interest rates, inflation, liquidity, and
counterparty risk.
Currency Risks
An advisory account that holds investments denominated in currencies other than the currency in which the
advisory account is denominated may be adversely affected by the volatility of currency exchange rates.
Cybersecurity Risks
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Disclosure Brochure
The computer systems, networks, and devices used by Regimen Wealth and service providers to us and our clients
to carry out routine business operations employ a variety of protections designed to prevent damage or interruption
from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized
persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially
can be breached. Clients could be negatively impacted as a result of a cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer
viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations,
business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact
business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us
and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines,
penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well
as the inadvertent release of confidential information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a
client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks,
brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by
these entities in order to prevent any cybersecurity breaches in the future.
Item 9. Disciplinary Information
Regimen Wealth has not been involved in any legal or disciplinary events that are material to a client’s evaluation
of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
Regimen Wealth does not have any financial industry activities and affiliations to disclose under this
Item.
Item 11. Code of Ethics
Regimen Wealth has adopted a code of ethics in compliance with applicable securities laws (“Code of
Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Regimen Wealth’s Code
of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use
of material non-public information by the Firm or any of its Supervised Persons and the trading by the same
of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of Regimen Wealth’s personnel to report their personal securities
holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently
broad markets to permit transactions by certain personnel to be completed without any appreciable impact
on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the
policies stated below.
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When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised
Person with access to this information may knowingly affect for themselves or for their immediate family
(i.e., spouse, minor children and adults living in the same household) a transaction in that security unless:
•
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end
mutual funds.
Clients and prospective clients may contact Regimen Wealth to request a copy of its Code of Ethics by
contacting the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
Regimen Wealth recommends that clients utilize the custody, brokerage and clearing services of National
Financial Services LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity”) for
investment management accounts which is a “qualified custodian” as that term is described in Rule 206(4)-
2 of the Advisers Act. The final decision to custody assets with Fidelity is at the discretion of the client,
including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as
either the plan sponsor or IRA accountholder. Regimen Wealth is independently owned and operated and
not affiliated with Fidelity. Fidelity provides Regimen Wealth with Fidelity's "platform" services. The
platform services include, among others, brokerage, custodial, administrative support, record keeping and
related services that are intended to support intermediaries like the Firm in conducting business and in
serving the best interests of their clients but that may benefit Registrant. If your accounts are custodied at
Fidelity, Fidelity will hold your assets in a brokerage account and buy and sell securities when we instruct
them to. Clients may pay fees to Fidelity for custody and the execution of securities transactions in their
accounts.
Factors which Regimen Wealth considers in recommending Fidelity or any other broker-dealer to clients
include their respective financial strength, reputation, execution, pricing, research, and service. Fidelity
enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal
transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower
than those charged by other Financial Institutions. Client should expect that they will pay exit fees associated
with moving accounts to Fidelity and those fees will not be reimbursed by Fidelity or the Firm.
The commissions paid by Regimen Wealth’s clients to Fidelity comply with the Firm’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institution might
charge to effect the same transaction where Regimen Wealth determines that the commissions are
reasonable in relation to the value of the brokerage and research services received. In seeking best execution,
the determinative factor is not the lowest possible cost, but whether the transaction represents the best
qualitative execution, taking into consideration the full range of a Financial Institution’s services, including
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Disclosure Brochure
among others, the value of research provided, execution capability, commission rates, and responsiveness.
Regimen Wealth seeks competitive rates but may not necessarily obtain the lowest possible commission
rates for client transactions.
Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in
return for investment research products and/or services which assist Regimen Wealth in its investment
decision-making process. Such research will be used to service all of the Firm’s clients, but brokerage
commissions paid by one client may be used to pay for research that is not used in managing that client’s
portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit
of such investment research products and/or services poses a conflict of interest because Regimen Wealth
does not have to produce or pay for the products or services.
Regimen Wealth periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Regimen Wealth receives without cost from Fidelity administrative support, computer software, related
systems support, as well as other third-party support as further described below (together "Support") which
allow Regimen Wealth to better monitor client accounts maintained at Fidelity and otherwise conduct its
business. Regimen Wealth receives the Support without cost because the Firm renders investment
management services to clients that maintain assets at Fidelity. The Support is not provided in connection
with securities transactions of clients (i.e., not “soft dollars”). The Support benefits Regimen Wealth, but not
its clients directly. Clients should be aware that Regimen Wealth’s receipt of economic benefits such as the
Support from a broker-dealer creates a conflict of interest since these benefits will influence the Firm’s choice
of broker-dealer over another that does not furnish similar software, systems support, or services. In fulfilling
its duties to its clients, Regimen Wealth endeavors at all times to put the interests of its clients first and has
determined that the recommendation of Fidelity is in the best interest of clients and satisfies the Firm's duty
to seek best execution.
Specifically, Regimen Wealth receives the following benefits from Fidelity: i) receipt of duplicate client
confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its
institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions
and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication
network for client order entry and account information.
As part of the arrangement, Fidelity also makes available to Regimen Wealth, at no additional charge to the
Firm, certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies, as selected by Regimen Wealth (within specified parameters). These
research and brokerage services are used by Regimen Wealth to manage accounts for it has investment
discretion. Regimen Wealth may also receive additional services. Without this arrangement, Regimen
Wealth might be compelled to purchase the same or similar services at its own expense.
The services from Fidelity are generally available to independent investment advisors on an unsolicited basis,
at no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts
at Fidelity. Fidelity’s services include brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and access to
mutual funds and other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment.
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For client accounts maintained in its custody, Fidelity generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts.
Fidelity also makes available to the Firm other products and services that benefit the Firm but may not benefit
its clients’ accounts. These benefits may include national, regional, or Firm specific educational events
organized and/or sponsored by Fidelity. Other of these products and services assist Regimen Wealth in
managing and administering clients’ accounts. These include software and other technology (and related
technological training) that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts),
provide research, pricing information and other market data, facilitate payment of the Firm's fees from its
clients’ accounts, and assist with back-office training and support functions, recordkeeping and client
reporting. Many of these services generally may be used to service all or some substantial number of the
Firm’s accounts, including accounts not maintained at Fidelity. Fidelity also makes available to Regimen
Wealth other services intended to help the Firm manage and further develop its business enterprise. These
services may include professional compliance, legal and business consulting, publications and conferences on
practice management, information technology, business succession, regulatory compliance, employee benefits
providers, human capital consultants, insurance, and marketing.
While, as a fiduciary, Regimen Wealth endeavors to act in its clients’ best interests, the Firm's
recommendation that clients maintain their assets in accounts at Fidelity may be based in part on the benefits
received and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity,
which creates a conflict of interest.
Brokerage for Client Referrals
Regimen Wealth does not consider, in selecting or recommending broker-dealers, whether the Firm
receives client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct Regimen Wealth in writing to use a particular Financial Institution to execute some or
all transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by Regimen Wealth (as described above). As a result,
the client may pay higher commissions or other transaction costs, greater spreads or may receive less
favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of
best execution, Regimen Wealth may decline a client’s request to direct brokerage if, in the Firm’s sole
discretion, such directed brokerage arrangements would result in additional operational difficulties.
Trade Aggregation
Transactions for each client will be effected independently, unless Regimen Wealth decides to purchase or
sell the same securities for several clients at approximately the same time. Regimen Wealth may (but is not
obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable
commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or
other transaction costs that might not have been obtained had such orders been placed independently. Under
this procedure, transactions will be averaged as to price and allocated among Regimen Wealth’s clients pro
rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm
determines to aggregate client orders for the purchase or sale of securities, including securities in which
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Disclosure Brochure
Regimen Wealth’s Supervised Persons may invest, the Firm does so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and
Exchange Commission. Regimen Wealth does not receive any additional compensation or remuneration as
a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only
a small percentage of the order is executed, shares may be allocated to the account with the smallest order
or the smallest position or to an account that is out of line with respect to security or sector weightings
relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one
account has limitations in its investment guidelines which prohibit it from purchasing other securities which
are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account
reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv)
with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro
rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the
Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
Regimen Wealth monitors client portfolios on a continuous and ongoing basis and regular account reviews
are conducted on at least an annual basis. Such reviews are conducted by the IAR assigned to the client. All
investment advisory clients are encouraged to discuss their needs, goals, and objectives with Regimen Wealth
and to keep the Firm informed of any changes thereto.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. On a monthly basis, or as
otherwise requested, clients will also receive written or electronic reports from Regimen Wealth and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements they
receive from their custodian with any documents or reports they receive from Regimen Wealth or an
outside service provider.
Item 14. Client Referrals and Other Compensation
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
Item 15. Custody
Regimen Wealth is deemed to have custody of client funds and securities because the Firm is given the ability
to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained
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Disclosure Brochure
at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such
qualified custodians will send account statements to clients at least once per calendar quarter that typically
detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, Regimen Wealth will also send, or otherwise make available, periodic
supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial
Institutions and compare them to those received from Regimen Wealth. Any other custody disclosures can
be found in the Firm’s Form ADV Part 1.
Item 16. Investment Discretion
Regimen Wealth is given the authority to exercise discretion on behalf of clients. Regimen Wealth is
considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions
in client accounts without first seeking their consent. Regimen Wealth is given this authority through a
power-of-attorney included in the agreement between Regimen Wealth and the client. Clients may request a
limitation on this authority (such as certain securities not to be bought or sold). Regimen Wealth takes
discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Regimen Wealth does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf.
Clients receive proxies directly from the Financial Institutions where their assets are custodied and may
contact the Firm at the contact information on the cover of this brochure with questions about any such issuer
solicitations.
Item 18. Financial Information
Regimen Wealth is not required to disclose any financial information listed in the instructions to Item 18
because:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance
of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual
commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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