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Item 1 – Cover Page
Form ADV Part 2A
Relevant Wealth Advisors, LLC
2 Belvedere Place, Suite 350
Mill Valley, California 94941
(415) 925-4000
March 3, 2025
relevantwealth.com
This Form ADV, Part 2A (“Brochure”), provides information about the qualifications and
business practices of Relevant Wealth Advisors, LLC (“Relevant Wealth Advisors”). If you
have any questions about the contents of this Brochure, please contact us at (415) 925-4000.
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 Relevant Wealth Advisors also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Relevant Wealth Advisors is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training. The oral and written communications of
an adviser provide you with information about which you determine to hire or retain an
adviser.
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Item 2 – Material Changes
Since the last annual amendment on March 5, 2024, there have been no material changes to
the information provided in the Brochure.
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Item 3 -Table of Contents
Item 1 – Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 -Table of Contents ............................................................................................................................. 3
Item 4 – Advisory Business ........................................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................................. 5
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 7
Item 7 – Types of Clients ............................................................................................................................... 7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 7
Item 9 – Disciplinary Information ................................................................................................................. 7
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 8
Item 11 – Code of Ethics ............................................................................................................................... 8
Item 12 – Brokerage Practices .................................................................................................................... 11
Item 13 – Review of Accounts ..................................................................................................................... 14
Item 14 – Client Referrals and Other Compensation .................................................................................. 14
Item 15 – Custody ....................................................................................................................................... 14
Item 16 – Investment Discretion ................................................................................................................ 15
Item 17 – Voting Client Securities (i.e., Proxy Voting) ................................................................................ 15
Item 18 – Financial Information .................................................................................................................. 16
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Item 4 – Advisory Business
A.
Description of Advisory Firm
Relevant Wealth Advisors provides portfolio management and wealth management services
directly to individuals and institutions. Relevant Wealth Advisors is also the sponsor and
portfolio manager of a wrap-fee program in which most of its advisory clients are invested.
The wrap-fee program is further described below and in a separate Wrap Fee Program
Brochure. Relevant Wealth Advisors was formed in 1962 and has been a registered
investment adviser with the SEC since 1999. The principal owner is Bruce Jon Raabe, 100%
owner and Managing Member. Mr. Raabe, Chartered Financial Analyst, is also the President,
Chief Investment Officer, Chief Financial Officer, and Chief Compliance Officer. As of
December 31, 2024, Relevant Wealth Advisors managed approximately $681,532,553 of
advisory client assets on a discretionary basis.
B.
Advisory Services
Relevant Wealth Advisors provides investment advisory services to its clients based on the
individual needs of each client. Advisory services include consulting with each client about
their financial needs and objectives; providing advice regarding investment strategy and
asset allocation; selecting, purchasing and selling securities for clients; monitoring
securities; and providing appropriate reports as to asset holdings and valuation.
Relevant Wealth Advisors also recommends portfolios of securities managed by
Independent Managers (private fund managers in this scenario). Relevant Wealth Advisors
selects a portfolio of fund managers and creates a fund-of-funds that its clients can invest in.
Relevant Wealth Advisors will continually monitor and evaluate each fund manager.
liability management,
family giving and
Relevant Wealth Advisors develops a personalized investment policy for each client and
creates and manages a portfolio based on that policy. Relevant Wealth Advisors also
provides certain clients with wealth management services, which may include advice on
personal assets, professional relationships, charitable giving, retirement plans, taxes,
investment policy
business succession,
development.
Clients may impose restrictions on their investments upon request. These restrictions may
include prohibitions or limits on individual securities, security types, asset classes,
allocation, liquidity, credit quality and income.
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Relevant Wealth Advisors offers referrals to Trust & Will, a third-party digital estate
planning service, for Clients who have the need for estate planning review, creation, or
updates. Generally, Clients referred will receive a 10% discount, and any and all fees paid by
the Client for outside referred services will be paid to those service providers directly. There
may be instances, however, where there is no separate fee for the estate planning services.
Relevant Wealth Advisors does not receive any economic benefit from this arrangement.
Clients are not required to utilize any third-party products, services, or referrals that we may
recommend and can select the service provider of their choice.
C.
Wrap Fee Program
Relevant Wealth Advisors is the sponsor and portfolio manager of a wrap-fee program,
which is described in detail in the Wrap Fee Program Brochure. More than 95% of Relevant
Wealth Advisors’ advisory clients are invested in the Wrap Fee Program. Clients invested in
the Wrap Fee Program pay a single, all-inclusive fee, based on the amount of assets under
management, to Relevant Wealth Advisors for portfolio management, trade execution, and
custodial services.
Item 5 – Fees and Compensation
A.
Advisory Fees paid by Wrap-Fee Clients
Clients invested in the Strategic Asset Management Program are charged a single, all-
inclusive fee for portfolio management, brokerage, custodial, recordkeeping and other
services associated with managing the account. Relevant Wealth Advisors generally
charges a flat percentage rate that ranges from 0.5% to 1.5%. Fees may be negotiable. See
Wrap Fee Program Brochure for additional details about the fees paid by clients invested in
the wrap fee program.
B.
Fees Paid by Advisory Clients Not Invested in the Wrap Fee Program
For clients who chose to open accounts outside of the wrap fee program, Relevant Wealth
Advisors generally charges a flat percentage rate. The annual flat rate ranges from 0.5% to
1.5% of assets under management and is specified in each client’s Investment Management
Agreement. A minimum of $10,000,000 of assets under management is generally required.
This minimum amount may be negotiable. In some cases, a flat quarterly fee may be
negotiated.
Advisory fees are payable in arrears in quarterly installments at the end of each calendar
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quarter based on the average daily balance of the entire account. Accounts opened between
billing periods will be billed on a prorated amount based on the number of days the account
was opened during that quarter. If the agreement is terminated prior to the last day of a
calendar quarter, the fees will be adjusted according to the number of days the account was
open on a pro rata basis. All prepaid but unearned advisory fees are refunded to the Client
upon termination of an account. Account closing fees may apply.
C.
Additional Mutual Fund Fees
Relevant Wealth Advisors’ fees for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds and ETFs to shareholders. Clients
invested in mutual funds or ETFs will pay advisory fees to Relevant Wealth Advisors for its
services and will pay additional fees as a shareholder of the applicable mutual fund or ETF.
These mutual fund or ETF fees and expenses are described in each fund’s prospectus. These
fees will generally include a management fee, other fund expenses, and a possible
distribution fee. Relevant Wealth Advisors generally does not invest in mutual funds that
require clients to pay front-load or deferred sales charges. A client could invest in a mutual
fund or ETF directly, without the services of Relevant Wealth Advisors. In that case, the client
would not receive the services provided by Relevant Wealth Advisors which are designed,
among other things, to assist the client in determining which mutual fund or ETFs are most
appropriate to each client’s specific financial condition and objectives. Accordingly, the client
should review the mutual fund or ETF fees charged by such funds and fees charged by
Relevant Wealth Advisors to fully understand the total amount of fees paid by the client and
to thereby evaluate the advisory services being provided.
D.
Additional Money Market Fund Fees
Relevant Wealth Advisors places client funds into a money market fund. Clients invested in
money market funds will incur additional fees that will be described in the prospectus.
E. Additional Compensation
Relevant Wealth Advisors generally does not receive payments from mutual funds, ETFs and
their sponsors in return for investing client assets in mutual funds or ETFs.
Relevant Wealth Advisors fees do not include the fees charged by Independent Managers.
Clients should review the Independent Manager’s ADV 2 Brochure and their subscription
agreements regarding fee schedules, other fees charged by Independent Managers and
applicable billing methods.
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Item 6 – Performance-Based Fees and Side-By-Side Management
Relevant Wealth Advisors does not charge any performance-based fees (fees based on a
share of capital gains on or capital appreciation of the assets of a client).
Item 7 – Types of Clients
Relevant Wealth Advisors provides portfolio management services to individuals, high net
worth individuals, businesses, pension plans and charitable institutions. A minimum of
$10,000,000 of assets under management is generally required, although this amount may
be negotiable.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
Relevant Wealth Advisors’ advice is primarily based upon long term investment strategies
that incorporate the principles of modern portfolio theory. Relevant Wealth Advisors’
investment approach is firmly rooted in the belief that markets are “efficient,” and that
investors’ returns are determined principally by asset allocation decisions, not market
Relevant Wealth Advisors offers advice on the following types of
timing or stock picking.
securities: (1) equities (exchange listed, over-the-counter and foreign issues); (2) warrants;
(3) corporate debt securities; (4) municipal securities; (5) United States government
securities; (6) options contracts on securities; (7) mutual funds; and (8) private fund-of-
funds. These investments bear the risk of loss at any time due to unforeseen market,
economic, interest rate or other risks.
When appropriate to the needs of the client, Relevant Wealth Advisors may recommend the
use of short-term trading (securities sold within 30 days), margin transactions or option
writing as investment strategies. Because these investment strategies may involve increased
risk of losses, they are only recommended when consistent with the client’s stated tolerance
for risk.
Item 9 – Disciplinary Information
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Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of Relevant Wealth Advisors
or the integrity of Relevant Wealth Advisors’ management. Relevant Wealth Advisors has no
information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Currently, no employees of Relevant Wealth Advisors are registered representatives of a
broker-dealer. Neither Relevant Wealth Advisors nor any of its management persons are
registered, or have an application pending to register, as a futures commission merchant,
commodity pool operator, commodity trading adviser or as an associated person of a
Relevant Wealth Advisors entity. Relevant Wealth Advisors does not receive any
compensation for the recommendation of other investment advisers to its clients.
Item 11 – Code of Ethics
Relevant Wealth Advisors has adopted a Code of Ethics for all supervised persons of the firm
(e.g., employees) describing its high standard of business conduct and fiduciary duty to its
clients. The purpose of this Code of Ethics is to require Relevant Wealth Advisors to act in
the best interests of its clients at all times and to address potential conflicts of interest
between Relevant Wealth Advisors and its employees and advisory clients. Relevant Wealth
Advisors’ clients or prospective clients may request a copy of the Code of Ethics, which is
summarized below, by contacting Bruce Raabe at (415) 925-4000.
A. Description of Code of Ethics
This Code of Ethics is based on the principle that all employees and certain other persons
have a fiduciary duty to place the interest of clients ahead of their own interest and the
interests of Relevant Wealth Advisors. The Code of Ethics applies to all “Access Persons” (i.e.
employees and certain other persons with access to confidential information regarding
client investments). Access Persons must avoid activities, interests and relationships that
might interfere with making decisions in the best interest of advisory clients.
As fiduciaries, all Access Persons must, at all times: (1) Place the interests of advisory clients
first. For example, a supervisor or employee would violate the Code of Ethics by causing an
advisory client to purchase a security he or she owned for the purpose of increasing the price
of that security; (2) Avoid taking inappropriate advantage of their position. For example,
Access Persons may not use their knowledge of portfolio transactions to profit by the market
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effect of such transactions; and (3) Conduct all personal securities transactions in full
compliance with the Code of Ethics, including pre-clearance of personal trades and the
reporting of personal securities holdings and trades on an ongoing basis. These pre-
clearance and reporting requirements ensure that Access Persons do not place their
personal interests ahead of clients’ interests when making their personal securities
transactions, particularly with respect to personal investments in securities owned by
clients.
Access Persons are also subject to other requirements and oversight by Relevant Wealth
Advisors, including the following:
Confidentiality. Access persons are prohibited from revealing information relating to the
investment intentions, activities, or portfolio of advisory clients, except to persons whose
responsibilities require knowledge of the information;
Gifts. The following provisions on gifts apply to Access Persons:
Accepting Gifts. On occasion, because of their position with the Company, Access
Persons may be offered or may receive, without notice, gifts from clients, brokers,
vendors, or other persons. Relevant Wealth Advisors prohibits Access Persons from
accepting extraordinary or extravagant gifts. Any such gifts must be declined and
returned to protect the reputation and integrity of Relevant Wealth Advisors. Gifts
of nominal value (i.e., a gift whose reasonable value, alone or in the aggregate, is not
more than $500 in any twelve-month period), customary business meals,
entertainment (e.g., sporting events), and promotional items (e.g., pens, mugs, T-
shirts) may be accepted without preapproval from the Chief Compliance Officer
(“CCO”). All gifts that exceed $500 must be preapproved by the CCO.
Solicitation of Gifts. Access Persons are prohibited from soliciting gifts of any size
under any circumstances.
Company Opportunities. Access Persons may not take personal advantage of any
opportunity properly belonging to any advisory client or Relevant Wealth Advisors.
This includes, but is not limited to, acquiring Reportable Securities for one’s own
account that would otherwise be acquired for an advisory client.
Undue Influence. Access Persons shall not cause or attempt to cause any Advisory
Client to purchase, sell or hold any security in a manner calculated to create any
personal benefit to such Access Person. If an Access Person stands to materially
benefit from an investment decision for an advisory client that the Access Person is
recommending or participating in, the Access Person must disclose to those persons
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with authority to make investment decisions for the advisory client the full nature of
the beneficial interest that the Access Person has in that security, any derivative
security of that security or the security issuer, where the decision could create a
material benefit to the Access Person or the appearance of impropriety. The person
to whom the Access Person reports the interest, in consultation with the CCO, must
determine whether or not the Access Person will be restricted in making investment
decisions with respect to the subject security.
Reporting, Review and Recordkeeping. All Access Persons must report all violations
of the Code of Ethics promptly to the CCO. The CCO shall periodically review Access
Persons’ personal trading reports and take additional reasonable steps to monitor
compliance with and enforce this Code of Ethics. The CCO shall maintain in the files
of Relevant Wealth Advisors: (i) a current copy of the Code of Ethics; (ii) records of
violations and actions taken as a result of the violations, (iii) copies of all Access
Persons’ written acknowledgement of receipt of the Code of Ethics, and (iv) copies of
the quarterly and annual compliance reports required by the Code of Ethics.
Sanctions. If the CCO determines that an Access Person has committed a violation of
the Code of Ethics, Relevant Wealth Advisors may impose sanctions and take other
actions as it deems appropriate, including a letter of caution or warning, suspension
of personal trading privileges, suspension or termination of employment, fine, civil
referral to the SEC and, in certain cases, criminal referral. Relevant Wealth Advisors
may also require the offending Access Person to reverse the trades in question, forfeit
any profit or absorb any loss derived therefrom; and such forfeiture shall be disposed
of in a manner that shall be determined by Relevant Wealth Advisors in its sole
discretion. Failure to abide by directions to reverse a trade or forfeit profits may
result in the imposition of additional sanctions.
Exceptions. Exceptions to the Code of Ethics will rarely, if ever, be granted. However,
the CCO may grant an occasional exception on a case-by-case basis when the
proposed conduct involves negligible opportunities for abuse. All exceptions shall be
solicited and issued in writing. No reports shall be required under this Code of Ethics
for: (i) transactions effected pursuant to an automatic investment plan and (ii)
securities held in accounts over which the access person has no direct control.
B.
Principal Trades and Cross-Trades
Relevant Wealth Advisors generally does not act in the capacity of a principal in executing
advisory clients’ securities transactions (e.g., own securities bought or sold by clients).
Relevant Wealth Advisors generally does not engage in cross-trades among advisory clients
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(e.g., causing one advisory client to buy or sell a security to or from another advisory client).
Relevant Wealth Advisors generally does not execute agency-cross transactions (e.g.,
Relevant Wealth Advisors acts as an investment advisor on behalf of one client to buy or sell
a security while acting as the broker for the other party to the same transaction.
Item 12 – Brokerage Practices
Relevant Wealth Advisors does not receive cash compensation for referring clients to third-
party brokers, and does not receive soft dollars (i.e., non-cash compensation).
We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-
dealer, member SIPC, as the qualified custodian. Relevant Wealth Advisors is independently
owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a
brokerage account and buy and sell securities when we instruct them to. While we
recommend that you use Schwab as custodian/broker, you will decide whether to do so and
will open your account with Schwab by entering into an account agreement directly with
them. We do not open the account for you, although we may assist you in doing so. Even
though your account is maintained at Schwab, and we anticipate that most trades will be
executed through Schwab, we can still use other brokers to execute trades for your account
as described below.
As mentioned above, we recommend Schwab, a custodian/broker that will hold your assets
and execute transactions. When considering whether the terms that Schwab provides are,
overall, most advantageous to you when compared with other available providers and their
services, we take into account a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], etc.)
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate the prices
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• Reputation, financial strength, security, and stability
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory
firms like Relevant Wealth Advisors. They provide us and our clients with access to their
institutional brokerage services (trading, custody, reporting, and related services), many of
which are not typically available to Schwab retail customers. However, certain retail
investors may be able to get institutional brokerage services from Schwab without going
through us. Schwab also makes available various support services. Some of those services
help us manage or administer our clients’ accounts, while others help us manage and grow
our business. Schwab’s support services are generally available on an unsolicited basis (we
don’t have to request them) and at no charge to us. Following is a more detailed description
of Schwab’s support services:
Services that benefit you include access to a broad range of investment products, execution
of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which we might not otherwise have access or that would
require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Schwab also provides other products and services that Schwab makes available to us that
benefit us but do not directly benefit you or your account. These products and services assist
us in managing and administering our clients’ accounts and operating our firm. They include
investment research, both Schwab’s own and that of third parties, and software and other
technology.
Schwab also offers other services intended to help us manage and further develop our
business enterprise. These services include educational conferences and events, consulting
on technology and business needs, consulting on legal and related compliance needs,
publications and conferences on practice management and business succession, access to
employee benefits providers, human capital consultants, and insurance providers and
marketing consulting and support. Schwab provides some of these services itself. In other
cases, it will arrange for third-party vendors to provide the services to us. Schwab also
discounts or waives its fees for some of these services or pays all or a part of a third party’s
fees. Schwab also provides us with other benefits, such as occasional business entertainment
of our personnel. If you did not maintain your account with Schwab, we would be required
to pay for these services from our own resources.
The availability of these services from Schwab benefits us because we do not have to produce
or purchase them. We do not have to pay for Schwab’s services. The fact that we receive these
benefits from Schwab is an incentive for us to recommend the use of Schwab rather than
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making such a decision based exclusively on your interest in receiving the best value in
custody services and the most favorable execution of your transactions. This is a conflict of
interest. We believe, however, that taken in the aggregate, our recommendation of Schwab
as custodian and broker is in the best interests of our clients. Our selection is primarily
supported by the scope, quality, and price of Schwab’s and not Schwab’s services that benefit
only us.
As part of our fiduciary duty and to help further ensure that brokerage firms recommended
by Relevant Wealth Advisors are conducting overall best qualitative execution, it will
periodically (and no less often than annually) evaluate such brokers. The evaluation will
consider the factors outlined above, along with the full range of brokerage services offered
by the brokers, which may include, but are not limited to price, commission, timing, research,
capable floor brokers or traders, capital strength and stability, reliable and accurate
communications, settlement processing, and administrative ability.
Clients may direct Relevant Wealth Advisors to use a particular broker or dealer to execute
some or all transactions for their accounts. In that case, clients will negotiate terms and
arrangements with that broker or dealer, and Relevant Wealth Advisors or the third-party
manager will not seek better execution services or prices from other brokers or dealers or
be able to “batch” or aggregate client transactions for execution with other accounts
managed by Relevant Wealth Advisors or a third-party manager. As a result, clients may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable
net prices, on transactions for the client’s account than would otherwise be the case.
For certain accounts, Relevant Wealth Advisors may determine the broker or dealer to effect
a transaction. Considerations in choice of a broker may include price, execution, size, and
timeliness. Relevant Wealth Advisors will negotiate commission rates based upon a good
faith effort to ensure competitive rates and timely execution. Consideration may be given to
benefits provided by the broker or dealer to the client, which may include reporting services
or research.
In the interest of better trade execution, Relevant Wealth Advisors may, but is not required
to, aggregate orders for a client’s account with orders of other clients. Consistent with its
duty to seek best execution for its advisory clients, Relevant Wealth Advisors may aggregate
securities sale and purchase orders for advisory clients with similar orders being made
contemporaneous for other accounts managed by a third-party manager. In such event,
clients will receive the average price of the securities purchased or sold in the aggregated
transaction. As a result, however, Relevant Wealth Advisors’ advisory clients may receive a
more or less favorable price from the aggregated trade versus a non-aggregated trade.
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Item 13 – Review of Accounts
Bruce Raabe, President and Managing Member, and Justin Burt, Senior Portfolio Manager,
perform monthly reviews of advisory client accounts they manage directly. The underlying
securities in client accounts are reviewed on a daily basis. More frequent reviews may be
triggered by changes in variables such as the market, political or economic circumstances, or
changes in the client’s individual circumstances. Mr. Raabe and Mr. Burt generally conduct
meetings with their clients two to four times per year to review their investment objectives
and financial situation to determine the suitability of investments and investment strategy.
Advisory clients generally receive quarterly reports from Relevant Wealth Advisors, which
include performance results prepared in accordance with Global Investment Performance
Standards. Advisory clients also receive monthly or quarterly brokerage and custodial
statements directly from the client’s custodian, which will generally be Schwab.
Item 14 – Client Referrals and Other Compensation
We receive an economic benefit from Schwab in the form of the support products and
services it makes available to us and other independent investment advisors whose clients
maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as
a result of these arrangements. However, we benefit from the referral arrangement because
the cost of these services would otherwise be borne directly by us. You should consider these
conflicts of interest when selecting a custodian. The products and services provided by
Schwab, how they benefit us, and the related conflicts of interest are described above (see
Item 12—Brokerage Practices).
Relevant Wealth Advisors generally does not compensate any person for client referrals. In
the event Relevant Wealth Advisors pays compensation for client referrals in the future, the
details of this agreement will be disclosed to the client in writing in accordance with
applicable requirements under Rule 206(4)-1 under the Investment Advisers Act of 1940.
Item 15 – Custody
Advisory client assets are generally held by Schwab. Under government regulations, we are
deemed to have custody of your assets if, for example, you authorize us to instruct Schwab
to deduct our advisory fees directly from your account. Schwab maintains actual custody of
your assets. You will receive account statements directly from Schwab at least quarterly.
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They will be sent to the email or postal mailing address you provided to Schwab. You should
carefully review those statements promptly when you receive them. We also urge you to
compare Schwab’s account statements with the periodic reports you receive from us.
Item 16 – Investment Discretion
Relevant Wealth Advisors generally provides discretionary advisory services to its clients in
accordance with investment guidelines and restrictions determined in consultation with
clients. Discretionary services mean that Relevant Wealth Advisors will purchase and sell
securities without prior client permission in accordance with a limited power of attorney.
The limited power of attorney generally prohibits Relevant Wealth Advisors from
withdrawing funds from the clients’ custodial and brokerage accounts. For non-
discretionary services, Relevant Wealth Advisors obtains specific client consent prior to the
purchase or sale of a security.
Item 17 – Voting Client Securities (i.e., Proxy Voting)
Relevant Wealth Advisors may or may not have authority for voting client securities (proxy
voting), depending on the terms of the applicable client’s Investment Management
Agreement. For those client accounts where Relevant Wealth Advisors has accepted proxy
voting authority, Relevant Wealth Advisors will be responsible for the voting of all proxies
related to securities held in those client accounts. Relevant Wealth Advisors uses a third-
party proxy voting service, Institutional Shareholder Services (ISS) to vote client proxies in
accordance with its standard proxy voting guidelines.
Conflicts may arise when any employees have any financial, business or personal
relationship with the issuer of a proxy proposal for a security held in a client’s account. To
avoid potential conflicts of interest, Relevant Wealth Advisors votes proxies in accordance
with predetermined guidelines. In limited situations, Relevant Wealth Advisors may
consider voting under our own initiative for a particular issue, if we believe that it is in the
best interest of the client. Before we reclaim proxy voting authority from ISS, Relevant
Wealth Advisors will determine and confirm that no potential conflict of interest exists.
Relevant Wealth Advisors will abstain from voting proxies when the Firm believes that it is
appropriate and in the best interest of the client.
Relevant Wealth Advisors maintains records in accordance with Rule 204 under the Advisers
Act relating to proxy voting for securities in client accounts. Such records include:
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•
A copy of related policies and procedures;
•
Proxy statements received regarding client securities, which were satisfied by relying
on the third-party vendor contracted to provide voting services;
•
A record of each vote cast, which the third-party vendor maintains on our behalf; and
•
Each written client request for proxy voting records and our written response.
A client may obtain the following information by submitting a verbal request by calling the
firm or a written request to the firm’s mailing address.
•
A copy of the Standard ISS Proxy Voting Manuals, which detail the policies and
procedures for casting proxy votes; and
•
Information about how the client’s proxies were voted.
Relevant Wealth Advisors takes reasonable steps to ensure ISS votes consistently with the
best interest, care, and loyalty of the client. Relevant Wealth Advisors will review, on a
quarterly basis, that each proxy was voted consistent with both Relevant Wealth Advisors’
and ISS’ benchmarking voting policy. In accordance with its Third-Party Service Provider
policies, on an annual basis, Relevant Wealth Advisors will 1) evaluate the services of ISS,
including evaluating any material changes in services or operations by ISS; 2) review the
methodology used by ISS to formulate its voting recommendations; and 3) remediate the
effects of any factual errors, incompleteness, or methodological weaknesses in providing its
services.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain
financial information or disclosures regarding any financial conditions that may impair their
ability to meet contractual commitments to clients. Relevant Wealth Advisors has no
financial conditions that impairs its ability to meet contractual and fiduciary commitments
to clients and has not been the subject of a bankruptcy proceeding.
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