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Relevé Financial Group
9375 E Shea Blvd Suite 100
Scottsdale, AZ 85260
612-801-5440
relevefinancialgroup.com
Wrap Fee Program Brochure
July 2025
ITEM 1: COVER PAGE
This wrap-fee program brochure provides information about the qualifications and business practices of
Relevé Financial Group, LLC (“RFG”). If you have any questions about the contents of this brochure, please
contact Kimberly Bannwarth at 612-801-0556 or kimberly@relevefinancialgroup.com. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission or by
any state securities authority.
Additional information about RFG, is available on the internet at www.adviserinfo.sec.gov. The Firm’s CRD
number is 285243.
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ITEM 2: MATERIAL CHANGES
Since the firm’s last Form ADV annual updating amendment filing in March 2025, the following material
change has occurred.
- Relevé Financial Group, LLC has moved its principal office and place of business to 9375 E Shea
Blvd Suite 100; Scottsdale, AZ 85260. The mailing address will remain at 724 Bielenberg Drive #2;
Woodbury, MN 55125. (Item 1 - Cover Page)
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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: SERVICES, FEES AND COMPENSATION ........................................................................................ 4
ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................................. 5
ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION .............................................................. 5
ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .............................................. 11
ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ..................................................................... 11
ITEM 9: ADDITIONAL INFORMATION .......................................................................................................... 11
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ITEM 4: SERVICES, FEES, AND COMPENSATION
Relevé Financial Group, LLC (“RFG” or “Firm”), is a registered investment adviser based in Scottsdale,
Ariozna. We are organized as a limited liability company under the laws of the State of Minnesota and were
established in 2016. Dawn Jurkovich is the sole owner. RFG is a full-service wealth management firm offering
a comprehensive suite of financial planning, consulting, and investment portfolio management services.
RFG offers Wealth Management services through the RFG Wrap Fee Program (“Program”) where it serves
as the Program’s sponsor and sole Portfolio Manager. RFG will offer Clients ongoing asset management
services through determining individual investment goals, time horizons, objectives, and risk tolerance.
Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment
program will be based on the above factors.
This is a wrap fee program, providing clients the ability to trade in specific investment products while not taking
on separate brokerage commissions or transaction charges. Wrap fee programs are any arrangements in
which the clients receive investment advisory services (including portfolio management or advice on other
investments) as well as execution of client transactions (for a fee) if they are not based upon existing account
transactions.
RFG will manage their client’s investment portfolios on either a discretionary or non-discretionary basis
according to the Wealth Management Agreement. RFG does so by apportioning the client’s assets among
the various investment products available with the Program.
Under the Program, RFG also offers clients a variety of planning and consulting services, which are customized
to accommodate the needs of each individual client. This may include:
Cash Flow & Budgeting
Business Planning
Tax Planning
Succession Planning
Tax Preparation
Educational Funding
Retirement Planning
Employee Benefits
Executive Compensation
Estate Planning
Protection Planning
Charitable Planning Financial Reporting
RFG is not required to verify any information received from the client or from the client’s other professionals
(e.g., attorneys, accountants, etc.) to perform these services, and is expressly authorized to rely on such
information.
RFG charges an annual investment advisory fee based on the total assets under management. This fee will
not exceed a 2% annualized fee.
Fees are billed quarterly in advance based on the amount of assets managed as of the close of business on
the last business day of the previous billing period. If margin is utilized, the fees will be billed based on the net
asset value of the account. Lastly, please note that RFG may group certain related Client accounts, often
known as “householding,” for the purposes of achieving the minimum account size and determining the
annualized fee.
Our advisory fee is negotiable, depending on individual client circumstances. RFG, in its sole discretion, may
charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be
managed, related accounts, account composition, negotiations with Clients, etc.).
For all services, Clients may terminate their engagement with RFG within five (5) business days of signing an
Agreement with no obligation and without penalty. After the initial (5) business days, the Agreement may be
terminated by RFG with thirty (30) days written notice to Client and by the Client at any time with written notice
to RFG. For accounts opened or closed mid-billing period, fees will be prorated based on the days services
are provided during the given period. All unpaid earned fees will be due to RFG and all unearned fees will be
refunded to the Client. Any increase in fees will be acknowledged in writing by both parties before any increase
in said fees occurs.
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Fee Comparison
Clients may be able to purchase services similar to those offered under the Program from other service
providers either separately or as part of a similar wrap fee program. These services or programs may cost
more or less than our Program, depending on the fees charged by such other service providers. A wrap fee
is not based directly on the number of transactions in your account. Various factors influence the relative cost
of our wrap fee program to you, including the cost of investment advice, custody, and brokerage services if
you purchased them separately, the types of investments held in your account, and the frequency, type, and
size of trades in your account. The program could cost you more or less than purchasing our investment
advice and custody/brokerage services separately.
For example, the Program Fee, which is fixed regardless of the number of transactions occurring in the
account, may be more or less than paying for execution on a per-transaction basis.
Fees We Pay Schwab:
In addition to compensating RFG for advisory services, the wrap fee you pay RFG allows us to pay for
brokerage and execution services provided by Schwab. RFG does not charge our clients higher advisory fees
based on their trading activity.
Additional Fees
RFG pays all custodian fees and transaction fees for all accounts under this Program. However, custodians
may charge other related costs on the purchases or sales of mutual funds, equities, bonds, options, margin
interest, and mark-ups, markdowns, or spreads paid to market makers. Mutual funds, money market funds,
and exchange-traded funds may also charge internal management fees, which are disclosed in the fund’s
prospectus. RFG does not directly receive any compensation from these fees.
Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed
directly by a mutual fund, index fund, or exchange-traded fund, which shall be disclosed in the fund’s
prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid
to market makers, fees (such as a commission or markup) for trades executed away from Schwab, at another
broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions.
RFG does not receive any compensation from these fees. All of these fees are in addition to the management
fee you pay to RFG.
Additional Compensation
RFG nor its employees receive compensation, other than the portfolio management fee, for the
recommendation to the Client or the Client’s participation in the Program.
ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
We offer investment advisory services to individuals, trusts, estates, charitable organizations, corporations,
business owners, and other business entities. Client relationships vary in scope and length of service.
There is no minimum account size and Clients are not required to have a certain amount of investment
experience or sophistication.
ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION
Portfolio Manager Selection and Evaluation
RFG is the sole Portfolio Manager and Advisor for the Program. RFG develops each portfolio strategy around
each Client’s unique financial goals. The portfolio development process includes:
• Determining the timing targets of the Clients goals
• Analyzing the individual risk/return comfort level
• Developing specific investment strategies using a variety of investment methods (shown below) to
match the clients total situation
• Monitoring the investments mix in an ongoing manner
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• Providing ongoing meaningful communication between the advisor and the Client, assuring the
investment plan is in concert with the total financial and family situations as they are now and as they
evolve.
The following industry standards may be used to evaluate the Portfolio Manager’s performance in security
selection:
• Morningstar Risk Rating (the holding’s measure should be equal to or better than its return rating; a
risk rating of average or lower is better than high; favorable example: low risk rating and average
return rating)
• Morningstar Return Rating (the investment’s rating should be equal to or better than its risk rating; a
return rating of average or higher is better than low; unfavorable example: high risk rating and
average return rating)
• Alpha (how an investment’s return compares with the returns of its peer group); the investment’s 3-
year alpha should show no difference or a positive difference between its total return and the return
of its peer group.
• Sharpe Ratio (evaluates a Mutual Fund’s or Exchange Traded Fund’s risk adjusted performance);
The Sharpe Ratio is calculated by taking the excess return of a portfolio, relative to the risk-free rate,
and dividing it by the Standard Deviation of the portfolio’s excess returns (Standard Deviation is a
statistical measure of volatility over a period of time). The higher a portfolio’s Sharpe Ratio, the better
its risk-adjusted performance.
• Morningstar Category (this identifies the investment’s general investment category; stocks have nine
categories: large company, mid-cap company and small company for each of the growth, core, and
value stock styles; bonds also have nine categories: short, intermediate, and long maturities for each
of the high, medium, and low-quality ratings) The investment should be in the same category it was
selected to fulfill in the portfolio’s allocation strategy.
There is a natural potential conflict of interest with the Portfolio Manager conducting the ongoing review of the
standards by which the Portfolio Manager’s selection and management have been acceptable. The fact that
the measures are completely objective, are provided by Morningstar, a well-known investment data provider,
and not subject to manipulation act to mitigate this potential conflict.
Related Persons as Program Managers
RFG is the only Portfolio Manager for the Program. We do not offer access to additional Portfolio Managers
but offer one fee to our Clients in order to eliminate concerns regarding variable transaction costs. To the
extent that we receive the Program Fee as a result of recommending itself, we are in a conflict of interest with
our Clients.
Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are created
that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities
or types of securities. These restrictions may, however, prohibit engagement with RFG.
Differences between Wrap vs Non-Wrap Management
RFG offers Asset Management services through the RFG Wrap Fee Program. RFG is both sponsor and
portfolio manager of the program. In a Wrap Fee account, clients are charged a single bundled fee as a
percentage of the assets managed in the wrap fee program that can include advisory fees, and other expenses
related to the wrap fee program.
There is no significant difference between how the Firm manages wrap fee accounts versus non-wrap fee
accounts. However, as stated above, if a client determines to engage RFG on a wrap fee basis the client will
pay a single fee for investment management and other fees. The services included in a wrap fee agreement
will depend upon each client’s particular need.
When managing a client’s account on a wrap fee basis, RFG shall receive, as payment for its investment
advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee have been
deducted.
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Performance-based fees and Side-by-Side Management
RFG does not accept performance-based fees or participate in side-by-side management. Our fees are
calculated as described in the Fees and Compensation section in this brochure and are not charged on the
basis of a share of capital gains upon, or capital appreciation of, the funds in your accounts.
Methods of Analysis and Investment Strategies
Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a
guarantee of future returns. Security analysis methods may include:
Fundamental analysis concentrates on factors that determine a company’s value and expected future
earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced
below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived
value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then a
prediction can be made. The risk is that markets do not always follow patterns and relying solely on this
method may not take into account new patterns that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and short-term
performance or market trends. The risk involved in using this method is that only past performance data is
considered without using other methods to crosscheck data. Using charting analysis without other methods
of analysis would be making the assumption that past performance will be indicative of future performance.
This may not be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged
to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical
patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these
investors are trying to exploit.
Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as
the character of management or the state of employee morale, such as the value of assets, the cost of capital,
historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a
given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by
carefully choosing the proportions of various assets.
In developing a financial plan for a Client, RFG’s analysis may include cash flow analysis, investment planning,
risk management, tax planning and estate planning. Based on the information gathered, a detailed strategy
is tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines, annual reports, prospectuses,
and filings with the SEC.
Investment Strategies
The investment strategy for a specific Client is based upon the objectives stated by the Client during
consultations. The Client may change these objectives at any time by providing notice to RFG, as the Firm
maintains Client documentation of each Client’s objectives and their desired investment strategy.
Risks of Investments and Strategies Utilized
Investing in securities involves risk of loss that Clients should be prepared to bear. RFG’s investment approach
constantly keeps the risk of loss in mind. Investors may face the following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial instruments
using strategies and investment techniques with significant risk characteristics. The investment program
utilizes such investment techniques as option transactions, margin transactions, short sales, leverage, and
derivatives trading, the use of which can, in certain circumstances, maximize the adverse impact to which a
Client may be subject.
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Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, when
interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar next year,
because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments may have to be reinvested at a
potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally, assets are more
liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid,
while real estate properties are not.
Management Risk. The advisor’s investment approach may fail to produce the intended results. If the
advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the
expected time frame, the overall performance of the Client’s portfolio may suffer.
Cybersecurity Risk. RFG and its service providers may be subject to operational and information security
risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data
maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential
information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting RFG and its
service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing
of transactions, cause the release of private information about Clients, impede trading, subject RFG to
regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are
also present for issuers of securities in which Clients may invest in, qualified custodians, governmental and
other regulatory authorities, exchange and other financial market operators, or other financial institutions.
Cybersecurity incidents could ultimately cause those parties to incur losses, including for example financial
losses, cost and reputational damages, and loss from damage or interruption of systems. Although RFG has
established its systems to reduce the risk of these incidents from coming to fruition, there is no guarantee that
these efforts will always be successful, especially considering that RFG does not directly control the
cybersecurity measures and policies employed by third party service providers.
Options Trading. The risks involved with trading options are that they are very time sensitive investments.
An options contract is generally for a few months. The buyer of an option could lose his or her entire investment
even with a correct prediction about the direction and magnitude of a particular price change if the price
change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are
less tangible than some other investments. An option is a “book-entry” only investment without a paper
certificate of ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has been invested. In
a margin account, risk includes the amount of money invested plus the amount that has been loaned. As
market conditions fluctuate, the value of marginable securities will also fluctuate, causing a change in the
overall account balance and debt ratio. As a result, if the value of the securities held in a margin account
depreciates, the Client will be required to deposit additional cash or make full payment of the margin loan to
bring the account back up to maintenance levels. Clients who cannot comply with such a margin call may be
sold out or bought in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks
of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track,
although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that
increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices may not
correlate perfectly with changes in the underlying reference units; and (ii) the risk of possible trading halts due
to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would
make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long periods. A
mutual fund’s share price and total return are expected to fluctuate within a wide range, like the fluctuations
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of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common stock. Prices
of common stock react to the economic condition of the company that issued the security, industry and market
conditions, and other factors which may fluctuate widely. Investments related to the value of stocks may rise
and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for
takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities,
including preferred stock, warrants, and options may also vary widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-cap issuers.
Securities of small-cap issuers may present greater risks than those of large-cap issuers. For example, some
small- and mid-cap issuers often have limited product lines, markets, or financial resources. They may be
subject to high volatility in revenues, expenses, and earnings. Their securities may be thinly traded, may be
followed by fewer investment research analysts, and may be subject to wider price swings and thus may
create a greater chance of loss than when investing in securities of larger-cap issuers. The market prices of
securities of small- and mid-cap issuers generally are more sensitive to changes in earnings expectations, to
corporate developments, and to market rumors than are the market prices of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold commodities,
commodities contracts, and/or derivative instruments, including futures, options, and swap agreements. The
prices of commodities contracts and derivative instruments, including futures and options, are highly volatile.
Payments made pursuant to swap agreements may also be highly volatile. Price movements of commodities,
futures and options contracts, and payments pursuant to swap agreements are influenced by, among other
things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control
programs and policies of governments, and national and international political and economic events and
policies. The value of futures, options, and swap agreements also depends upon the price of the commodities
underlying them. In addition, Client assets are subject to the risk of the failure of any of the exchanges on
which its positions trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of
forward and other derivative contracts are influenced by, among other things, interest rates, changing supply
and demand relationships, trade, fiscal, monetary and exchange control programs and policies of
governments, and national and international political and economic events and policies. Clients are also
subject to the risk of failure of any of the exchanges on which their positions trade or of its clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers. Investments in
securities of non-U.S. issuers pose a range of potential risks which could include expropriation, confiscatory
taxation, imposition of withholding or other taxes on dividends, interest, capital gains or other income, political
or social instability, illiquidity, price volatility, and market manipulation. In addition, less information may be
available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting,
auditing and financial reporting standards, and requirements comparable to or as uniform as those of U.S.
issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets issuers. In addition
to the risks associated with investments outside of the United States, investments in emerging markets (i.e.,
the developing countries) may involve additional risks. Emerging markets generally are not as efficient as
those in developed countries. In some cases, a market for the security may not exist locally, and transactions
will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower
than in developed countries. When seeking to sell emerging market securities, little or no market may exist
for the securities. In addition, issuers based in emerging markets are not generally subject to uniform
accounting and financial reporting standards, practices, and requirements comparable to those applicable to
issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive
practices.
Capitalization Risks. Investing in Companies within the same market capitalization category carries the risk
that the category may be out of favor due to current market conditions or investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect the Companies,
which could have an adverse effect on each of them. If the securities of the Companies experience poor
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liquidity, investors may be unable to transact at advantageous times or prices, which may decrease the
Company’s returns. In addition, there is a risk that policy changes by central governments and governmental
agencies, including the Federal Reserve or the European Central Bank, which could include increasing
interest rates, could cause increased volatility in financial markets, which could have a negative impact on the
Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the spread of
infectious illness or other public health issues, recessions, or other events could have a significant impact on
the Companies. For example, the rapid and global spread of a highly contagious novel coronavirus respiratory
disease, designated COVID-19, has resulted in extreme volatility in the financial markets and severe losses;
reduced liquidity of many Companies’ securities; restrictions on international and, in some cases, local travel;
significant disruptions to business operations (including business closures); strained healthcare systems;
disruptions to supply chains, consumer demand and employee availability; and widespread uncertainty
regarding the duration and long-term effects of this pandemic. Some sectors of the economy and individual
issuers have experienced particularly large losses. In addition, the COVID-19 pandemic may result in a
sustained economic downturn or a global recession, domestic and foreign political and social instability,
damage to diplomatic and international trade relations and increased volatility and/or decreased liquidity in
the securities markets. The Companies’ values could decline over short periods due to short-term market
movements and over longer periods during market downturns.
Inverse and Leveraged Products. RFG may recommend and engage in trading with leveraged and inverse
products. These products are aggressive in nature and carry unusual and significant risk. They are not
appropriate for inexperienced investors. These products are intended to be used/traded daily. Most leveraged
and inverse ETFs reset on a daily basis and have published prospectuses that state (I) they're designed to
achieve their stated objective within one day, (2) clients can lose all of their investment potentially in one day,
and (3) holding these securities for periods longer than one day could lead to losses even if the underlying
index moves in the anticipated direction. Regulatory organizations, such as FINRA & SEC, have released
alerts stating that inverse and leveraged ETFs that reset daily typically are not suitable for retail investors who
plan to hold them longer than one day. Managers may hold these products in client accounts for periods of
time significantly greater than one day. Investors with holding periods longer than a day expose themselves
to substantial risk as the holding period returns will deviate from the returns to a leveraged or inverse
investment in the index. It is possible for an investor in a leveraged ETF to experience negative returns even
when the underlying index has positive returns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that are not traded
on an exchange. Penny Stocks typically trade over-the-counter, such as on the OTC Bulletin Board or Pink
Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC reporting requirements or the listing
standards of stock exchanges. Because of this, information about the Penny Stock companies can be difficult
to find and verify. Penny Stocks also have lower liquidity as they are traded less frequently. This also leads to
higher volatility. For these reasons, Penny Stocks are considered to be speculative investments and Clients
who trade in penny stocks should be prepared for the possibility that they may lose their entire investment, or
an amount in excess of their investment if they purchased Penny Stocks on margin.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer (typically an
insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate
payment of a lump sum (single-payment annuity) or a series of regular payments (regular-payment annuity).
The payment stream from the issuer to the annuitant has an unknown duration based principally upon the
date of death of the annuitant. At this point, the contract will terminate, and the remainder of the funds
accumulated are forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be
purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts
or in amounts that increase by a fixed percentage, variable annuities pay amounts that vary according to the
performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities
typically impose asset-based sales charges or surrender charges for withdrawals within a specified period.
Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges,
such as mortality and expense risk charges; administrative fees; underlying fund expenses; and charges for
special features, all of which can reduce the return. Earnings in a variable annuity do not provide all the tax
advantages of 401(k)s and other before-tax retirement plans. Once the investor starts withdrawing money
from their variable annuity, earnings are taxed at the ordinary income rate, rather than at the lower capital
gains rates applied to other non-tax-deferred vehicles which are held for more than one year. Proceeds of
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most variable annuities do not receive a "step-up" in cost basis when the owner dies like stocks, bonds and
mutual funds do. Some variable annuities offer "bonus credits." These are usually not free. In order to fund
them, insurance companies typically impose mortality and expense charges and surrender charge periods. In
an exchange of an existing annuity for a new annuity (so-called 1035 exchanges), the new variable annuity
may have a lower contract value and a smaller death benefit; may impose new surrender charges or increase
the period of time for which the surrender charge applies; may have higher annual fees; and provide another
commission for the broker
Alternative Investments. When appropriate for a Client’s objective, risk tolerance and qualifications, RFG
recommends the client participate in private issues, such as single purpose vehicles, funds of funds, private
equity, and hedge funds. These are usually structured as limited partnerships with differing minimum
investments, liquidity, fees, and carries.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the
risks involved in an investment with RFG.
Voting of Client Securities
If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder.
We will not vote proxies on behalf of your advisory accounts. In most cases, you will receive proxy materials
directly from the account custodian.
ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
Clients understand and grant RFG the authority to discuss certain private information with hired Independent
Managers or third-party affiliates hired to manage their accounts on an initial and continuum bases. Our firm
would be authorized to disclose personal client information including, but not limited to, names, account
numbers, social security numbers, tax identification numbers, phone numbers, financial allocations, and
investment goals. This private information would be shared to ensure Independent Mangers’ or third-party
affiliates that investment decisions remain aligned with our clients’ financial objectives and best interests.
ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS
Clients have the right to correspond with RFG’s Portfolio or Independent Managers. This can be facilitated by
providing the Firm with written request and identification of the questions or issues to be discussed with the
Independent Managers. After receiving a written request, RFG may contact the Independent Managers on
behalf of the client or arrange for direct contact between the Independent Managers and the client.
ITEM 9: ADDITIONAL INFORMATION
Disciplinary Information
RFG 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 management.
Other Financial Industry Activities or Affiliations
Neither RFG nor its management persons are registered as a broker-dealer, broker-dealer representative,
futures commission merchant, commodity pool operator, or a commodity trading advisor.
Some Investment Advisor Representatives of RFG receive external compensation from sales of investment-
related services as Insurance Agents. This represents a conflict of interest because it gives an incentive to
recommend services based on the fee amount received. This conflict is mitigated by disclosures, procedures,
and RFG’s fiduciary obligation to place the best interest of the Client first. Moreover, Clients are not required
to engage either Insurance Agent or Agency if they do not wish to. More information on this can be found in
the respective Investment Advisor Representative’s Form U4 and ADV 2B.
Code of Ethics
The affiliated persons (affiliated persons include employees and/or independent contractors) of RFG have
committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected
of RFG affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for
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affiliated persons of RFG. The Code reflects RFG and its supervised persons’ responsibility to act in the best
interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their personal
accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons
to use non-public material information for their personal profit or to use internal research for their personal
benefit in conflict with the benefit to our Clients.
RFG’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information.
No advisory representative or other affiliated person, officer or director of RFG may recommend any
transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for
a security or its derivatives if the advisory representative possesses material, non-public information regarding
the security.
RFG’s Code is based on the guiding principle that the interests of the Client are our top priority. RFG’s officers,
directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform
that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation
to put the Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public
information regarding any Clients' purchase or sale of securities, or non-public information regarding the
portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients,
or who have access to such recommendations that are non-public.
RFG will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
Recommendations Involving Material Financial Interests
Neither RFG nor its related persons recommend to Clients, or buys or sells for Client accounts, securities in
which RFG or a related person has a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
RFG and its affiliated persons may invest in the same securities (or related securities, e.g., warrants, options,
or futures) that RFG or an affiliated person recommends to Clients. In order to mitigate conflicts of interest,
such as frontrunning, RFG’s Chief Compliance Officer, or their designee, will no less than quarterly, review
firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal trading of
affiliated persons does not disadvantage Clients of RFG.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and
Conflicts of Interest
RFG and its affiliated persons may recommend securities, or buy or sell securities for Clients accounts, at or
about the same time, that they also buy or sell the same securities in their own account(s). RFG, for instance,
will place trades in an account in an attempt to earn better than money market rates. In order to mitigate
conflicts of interest, such as frontrunning, RFG’s Chief Compliance Officer, or their designee, will no less than
quarterly, review firm and/or personal holdings of its affiliated persons. These reviews ensure that the personal
trading of affiliated persons does not disadvantage Clients of RFG.
Review of Account
Frequency and Nature of Periodic Review and Who Makes Those Reviews
RFG monitors its clients’ investment portfolios on an ongoing basis and conducts account reviews annually.
Reviews are conducted by the client’s Financial Advisor. Investments are reviewed annually by the Investment
Committee, which includes the Firm’s Principals. All investment advisory clients are responsible for discussing
their needs and objectives with RFG and to notify the Firm of any material changes. RFG will contact
investment advisory clients at a minimum annually to review previous advice and recommendations and to
discuss any updates or changes to the clients’ financial situation and/or investment objectives.
Financial plans are updated as requested by the Client and pursuant to a new or amended agreement, RFG
suggests updating at least annually.
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Factors That Will Trigger a Non-Periodic Review of Client Accounts
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment
information, and changes in a Client's own situation.
Content and Frequency of Regular Reports
Clients receive written account statements no less than quarterly for managed accounts. Account statements
are issued by the Client’s custodian. Client receives confirmations of each transaction in account from
Custodian and an additional statement during any month in which a transaction occurs. RFG may also send
periodic or other event-inspired reports based on market or portfolio activity. Reports will generally be provided
in electronic format.
Client Referrals and Other Compensation
Compensation to Non-Advisory Personnel for Client Referrals
RFG does not receive any economic benefits from external sources.
Compensation to Non-Advisory Personnel for Client Referrals
RFG does not compensate for Client referrals.
Financial Information
RFG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to
Clients and has not been the subject of a bankruptcy petition.
RFG does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in
advance.
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