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Rilex Capital, LLC
a New Jersey Registered Investment Adviser
2520 Highway 35 Suite 103
Manasquan, NJ 08736
Tel: 732 223 5600
APRIL 2026
This brochure provides information about the qualifications and business practices of
Rilex Capital LLC (“Rilex Capital”). If you have any questions about the content of this
brochure, please contact us at 732 223 5600. 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 Rilex Capital is also available on the SEC’s website at
www.adviserinfo.sec.gov.
SEC and/or state registration does not imply a certain level of skill or training.
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Material Changes
In 2025, Rilex Capital’s principal terminated his insurance producer license and no longer offers
insurance products to clients. Rilex Capital has not had any other material changes to its advisory
activities or personnel since the filing of its 2025 Annual ADV Amendment.
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TABLE OF CONTENTS
Item 4. Advisory Business ......................................................................................................... 4
Item 5. Fees and Compensation ................................................................................................ 4
Item 6. Performance Based Fees and Side by Side Management ............................................ 6
Item 7. Types of Clients ............................................................................................................ 6
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss..................................... 6
Item 9. Disciplinary Information .............................................................................................. 7
Item 10. Other Financial Industry Activities and Affiliations ................................................... 8
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................................... 8
Item 12. Brokerage Practices ..................................................................................................... 8
Item 13. Review of Accounts ................................................................................................... 10
Item 14. Client Referrals and Other Compensation ................................................................ 10
Item 15. Custody ...................................................................................................................... 10
Item 16. Investment Discretion ................................................................................................ 11
Item 17. Voting Client Securities .............................................................................................. 11
Item 18. Financial Information ................................................................................................. 11
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Item 4. Advisory Business
Rilex Capital offers wealth management services to individual and high-net-worth clients as well as
small businesses. The firm prides itself on its investment strategies, client service, and ongoing
commitment to bringing innovative solutions to its clients’ financial lives. Rilex Capital was founded
in June 2020 and is owned by Peter Maldjian.
This Disclosure Brochure describes the business of Rilex Capital. Certain sections will also describe
the activities of Supervised Persons. Supervised Persons are any of Rilex Capital’s officers, partners, directors
(or other persons occupying a similar status or performing similar functions), or employees, or any
other person who provides investment advice on Rilex Capital’s behalf and is subject to Rilex Capital’s
supervision or control.
Financial Planning Services:
In limited situations, Rilex Capital may provide financial planning and consultation services on a
standalone basis that does not include investment management services. (e.g., review of goals and
objectives, analysis and recommendations for cash flow planning, asset allocation/investment
planning, income tax planning, insurance planning, estate planning, retirement planning, education
planning, real estate/mortgage planning, etc.).
Wealth Management Services:
Rilex Capital provides investment management services primarily on a discretionary basis according
to the investment objectives of the client and in accordance with the terms and conditions of the
Investment Advisory Agreement between the Rilex Capital and the client. Based upon the client’s
stated investment objectives, Rilex Capital’s investment management focuses on providing
investment returns consistent with clients’ investment goals and objectives. Based upon a particular
Model Portfolio, Rilex Capital will invest client’s accounts in certain percentages amongst numerous
asset classes (e.g. stocks, corporate and government bonds and ETFs) in order to maximize client’s
investment returns while achieving lower volatility within pre-determined risk parameters.
As of December 2025, Rilex Capital manages approximately $124 million in assets under
management, primarily on a discretionary basis.
Item 5. Fees and Compensation
Rilex Capital offers its services on a fee basis, which may include fixed fees, as well as fees based.
upon assets under management. Additionally, certain of Rilex Capital’s Supervised Persons, in their
individual capacities, may offer insurance products under a commission arrangement. For all services,
Rilex Capital’s annual fee is exclusive of, and in addition to brokerage commissions, transaction fees,
and other related costs and expenses which are incurred by the client. Rilex Capital does not, however,
receive any portion of these commissions, fees, and costs.
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Investment Management Fees:
Rilex Capital’s investment management fee schedule (“Advisory Fees”) for accounts managed by Rilex
Capital is based on a percentage of assets (generally net of any debit balances) and is set forth below.
The Advisory Fees represent the highest fee that may be charged absent special circumstances:
Advisory Assets Annual Fee
$50,000 to $100,000
$100,000 to $250,000
$250,00 to 1,000,000
$1,000,000 to 5,000,000
$5,000,000 to 20,000,000
$20,000,000 to 100,000,000
1.75%
1.50%
1.20%
.90%
.50%
.20%
Rilex Capital’s Advisory Fees shall also be prorated and paid monthly, in arrears, based upon the
market value of the assets on the last business day of the previous quarter. Rilex Capital’s actual fees
may be negotiated, and a client may pay more or less than similar clients depending on the particular
circumstances of the client, which may include considerations related to the size of the client’s account,
additional and/or differing levels of service or as negotiated. Clients that negotiate fees may end up
paying a higher fee than that set forth in the fee schedules above as a result of fluctuations in the
client’s assets under management and/or account performance.
Fees Charged by Financial Institutions
Rilex Capital generally recommends that clients utilize the brokerage and clearing services of Charles
Schwab & Co., Inc., member FINRA/SIPC (“Schwab”) for investment management accounts.
Rilex Capital may only implement its investment management recommendations after the client has
arranged for and furnished Rilex Capital with all information and authorization regarding accounts
with appropriate financial institutions. Clients may incur certain charges imposed by the Financial
Institutions and other third parties such as fees charged by Independent Managers , custodial fees,
charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on
brokerage accounts and securities transactions.
Additionally, clients may incur brokerage commissions and transaction fees. Such charges, fees and
commissions are exclusive of and in addition to Rilex Capital’s fee. Rilex Capital’s Agreement and the
separate agreement with any Financial Institutions may authorize Rilex Capital or Independent
Managers to debit the client’s account for the amount of Rilex Capital’s fee and to directly remit that
management fee to Rilex Capital or the Independent Managers. Any Financial Institutions
recommended by Rilex Capital have agreed to send a statement to the client, at least quarterly,
indicating all amounts disbursed from the account including the amount of management fees paid
directly to Rilex Capital. Alternatively, clients may elect to have Rilex Capital send an invoice for
payment.
Fees for Management During Partial Monthly Service
For the initial period of investment management services, the fees are calculated on a pro rata basis.
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The Agreement between Rilex Capital and the client will continue in effect until terminated by either
party pursuant to the terms of the Agreement. Rilex Capital’s fees are charged in arrears so that any
termination date shall be prorated and deducted from any remaining balance charged to the client.
Clients may make additions to and withdrawals from their account at any time, subject to Rilex
Capital’s right to terminate an account. Additions may be in cash or securities provided that Rilex
Capital reserves the right to liquidate any transferred securities or decline to accept particular securities
into a client’s account.
Clients may withdraw account assets on notice to Rilex Capital, subject to the usual and customary
securities settlement procedures. However, Rilex Capital designs its portfolios as long-term
investments, and the withdrawal of assets may impair the achievement of a client’s investment
objectives. Rilex Capital may consult with its clients about the options and ramifications of transferring
securities. However, clients are advised that when transferred securities are liquidated, they are subject
to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or
tax ramifications.
Financial Planning Fees:
In very limited situations where Rilex Capital engaged solely for Financial Planning/Consulting, our
fees are negotiable, but generally are set at $300 per hour, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s). Prior to engaging Rilex Capital to
provide financial planning or consulting services, clients will be required to enter into a Financial
Planning Agreement with Rilex Capital setting forth the terms and conditions of the engagement,
describing the scope of the services to be provided.
Item 6. Performance-Based Fees and Side-by-Side Management
Rilex Capital does not charge a performance-based fee.
Item 7. Types of Clients
Rilex Capital provides its services to individuals, trusts, estates, and business entities.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Rilex Capital’s primary methods of analysis are fundamental and technical:
Fundamental analysis involves the fundamental financial condition and competitive position of a
Company or asset class. Rilex Capital may analyze the financial condition, capabilities of management,
earnings, new products, and services, as well as the company’s or asset class’s markets and position
amongst its competitors in order to determine the recommendations made to clients. The primary risk
in using fundamental analysis is that while the overall health and position of a company or asset class
may be good, market conditions may negatively impact the security.
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts
to identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical
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patterns may not help to predict such patterns in the future. Even if the pattern will eventually reoccur,
there is no guarantee that Rilex Capital will be able to accurately predict such a recurrence.
Investment Strategies
Rilex Capital customizes its asset management strategies based on the individual needs and concerns
of their clients. While Rilex Capital offers each of the services described in Item 4 (above), the main
focus of the firm is its diversified portfolio management. For its diversified portfolio management,
Rilex Capital selects securities for the portfolio based on asset allocation decisions and what suits the
client’s needs and goals most appropriately. Specifically, Rilex Capital tries to determine the mix of
stock, bonds, ETFs and other investments that it feels offers the best combination of potential return
and risk. At any given time, Rilex Capital may allocate all, a portion, or none of the portfolio’s assets
to various areas of the stock, bonds, or ETFs.
Risks of Loss
Market Risks
The profitability of a significant portion of Rilex Capital’s recommendations may depend to a great
extent upon correctly assessing the future course of price movements of stocks and bonds. There can
be no assurance that Rilex Capital will be able to predict those price movements accurately.
Management Through Similarly Managed Accounts
For certain clients, Rilex Capital may manage portfolios by allocating portfolio assets among various
securities on a discretionary basis using one or more of its proprietary investment strategies
(collectively referred to as “investment strategy”). In so doing, Rilex Capital buys, sells, exchanges and/or
transfers securities based upon the investment strategy. Rilex Capital’s management, using the investment
strategy, complies with the requirements of Rule 3a- 4 of the Investment Company Act of 1940, as
amended. Rule 3a-4 provides similarly managed accounts, such as the investment strategy, with a safe
harbor from the definition of an investment company. Securities in the investment strategy are usually
exchanged and/or transferred without regard to a client’s individual tax ramifications. Certain
investment opportunities that become available to Rilex Capital’s clients may be limited. As further
discussed in response to Item 12B (below), Rilex Capital allocates investment opportunities among its
clients on a fair and equitable basis.
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear such losses.
Item 9. Disciplinary Information
Rilex Capital is required to disclose the facts of any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of management. Rilex Capital does not have
any required disclosures regarding this Item.
Item 10. Other Financial Industry Activities and Affiliations
Rilex Capital is required to disclose any relationship or arrangement that is material to its advisory
business or to its clients with certain related persons. Rilex Capital has described such relationships
and arrangements below.
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Maldjian & Citta P&C – Accounting Firm
Peter Maldjian is a CPA and principal of Maldjian & Citta, PC, a tax and accounting firm. The firm
provides tax services for family-owned businesses, trusts, estates, foundations, and individuals. A
conflict of interest exists when Mr. Maldjian provides additional tax services to Rilex Capital for
clients. In this instance, any such conflict is fully disclosed to the client.
Item 11. Code of Ethics
Rilex Capital and persons associated with Rilex Capital (“Associated Persons”) are permitted to buy
or sell securities that it also recommends to clients consistent with Rilex Capital’s policies and
procedures. Rilex Capital has adopted a code of ethics that sets forth the standards of conduct
expected of its associated persons and requires compliance with applicable securities laws (“Code of
Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the “Advisers
Act”), its Code of Ethics contains written policies reasonably designed to prevent the unlawful use of
material non-public information by Rilex Capital or any of its associated persons. The Code of Ethics
also requires that certain of Rilex Capital’s personnel (called “Access Persons”) report their personal
securities holdings and transactions and obtain pre-approval of certain investments such as initial
public offerings and limited offerings.
Unless specifically permitted in Rilex Capital’s Code of Ethics, none of Rilex Capital’s Access Persons may
effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in
the same household as the Access Person) any transactions in a security which is being actively purchased
or sold or is being considered as such on behalf of Rilex Capital’s clients. When Rilex Capital is
purchasing or considering for purchase any security on behalf of a client, no Access Person may effect
a transaction in that security prior to the completion of the purchase or until a decision has been made
not to purchase such security. Similarly, when Rilex Capital is selling or considering the sale of any
security on behalf of a client, no Access Person may effect a transaction in that security prior to the
completion of the sale or until a decision has been made not to sell such security.
Clients and prospective clients may contact Rilex Capital to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
As discussed above, in Item 5, Rilex Capital generally recommends that clients utilize the brokerage
and clearing services of Schwab. Factors which Rilex Capital considers in recommending Custodians
or any other broker-dealer to clients include their respective financial strength, reputation, execution,
pricing, research, and service. Schwab enables Rilex Capital to obtain many mutual funds without
transaction charges and other securities at nominal transaction charges. The commissions and/or
transaction fees charged may be higher or lower than those charged by other Financial Institutions.
The commissions paid by Rilex Capital’s clients comply with Rilex Capital’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institutions
might charge to effect the same transaction where Rilex Capital 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 among others, the value of research provided, execution capability,
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commission rates, and responsiveness. Rilex Capital seeks competitive rates but may not necessarily
obtain the lowest possible commission rates for client transactions.
Rilex Capital periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions in light of its duty to obtain best execution. The client may
direct Rilex Capital 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 Rilex Capital 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 Rilex Capital. As a result, the client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net prices,
on transactions for the account than would otherwise be the case. Subject to its duty of best execution,
Rilex Capital may decline a client’s request to direct brokerage if, in Rilex Capital’s sole discretion,
such directed brokerage arrangements would result in additional operational difficulties or violate
restrictions imposed by other broker-dealers (as further discussed below). Transactions for each client
generally will be effected independently, unless Rilex Capital decides to purchase or sell the same
securities for several clients at approximately the same time. Rilex Capital 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 Rilex Capital’s clients.
To the extent that Rilex Capital determines to aggregate client orders for the purchase or sale of
securities, including securities in which Rilex Capital’s Supervised Persons may invest, Rilex Capital
generally 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. Rilex Capital
does not receive any additional compensation or remuneration as a result of the aggregation. In the
event that Rilex Capital determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may 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, Rilex Capital 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.
Software and Support Provided by Financial Institutions
Rilex Capital may receive from Schwab, without cost, computer software and related systems support,
which allows Rilex Capital to better monitor client accounts maintained at Schwab. Rilex Capital may
receive software and related support without cost because Rilex Capital renders investment
management services to clients that maintain assets at Schwab. The software and related systems
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support may benefit Rilex Capital, but not its clients directly. In fulfilling its duties to its clients, Rilex
Capital endeavors at all times to put the interests of its clients first. Clients should be aware, however,
that Rilex Capital’s influence Rilex Capital’s choice of broker-dealer over another broker-dealer that
does not furnish similar software, systems support, or services. Additionally, Rilex Capital may receive
the following benefits from Schwab through their respective investment adviser divisions: receipt of
duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services its investment adviser participants; access to block trading which provides the
ability to aggregate securities transactions and then allocate the appropriate shares to client accounts;
and access to an electronic communication network for client order entry and account information.
13. Review of Accounts
For those clients to whom Rilex Capital provides wealth management services, Rilex Capital monitors
those portfolios as part of an ongoing process while regular account reviews are conducted on at least
an annual basis. All investment advisory clients are encouraged to discuss their needs, goals, and
objectives with Rilex Capital and to keep Rilex Capital informed of any changes thereto. Rilex Capital
contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations and to discuss the impact resulting from any changes in the client’s financial
situation and/or investment objectives. Unless otherwise agreed upon, clients are provided with
transaction confirmation notices and regular summary account statements directly from the broker-
dealer or custodian for the client accounts.
Item 14. Client Referrals and Other Compensation
Rilex Capital does not have a referral arrangement in which it pays compensation to a third party for
client referrals.
Item 15. Custody
Rilex Capital does not maintain physical custody of client assets. Rilex Capital engages several
qualified, nationally recognized SEC registered broker-dealers to custody and safe keep client assets.
Rilex Capital’s Agreement and/or the separate agreement with any Financial Institution may authorize
Rilex Capital through such Financial Institution to debit the client’s account for the amount of Rilex
Capital’s fee and to directly remit that management fee to Rilex Capital in accordance with applicable
custody rules. The Financial Institutions recommended by Rilex Capital have agreed to send a statement
to the client, at least quarterly, indicating all amounts disbursed from the account.
Rilex Capital effects third party asset transfers in client accounts using a Standing Letter of
Authorization (“SLOA”). Pursuant to the SEC No Action Letter, Rilex Capital is deemed to have
Custody over these accounts. Accordingly, Rilex Capital has instituted procedures and controls such
that it can comply with the seven representations noted in the SEC No-Action letter and avoid the
annual surprise audit requirement. Additionally, since many of the seven representations involve the
qualified custodian’s operations, Rilex Capital is in close collaboration to ensure compliance with the
SEC guidance.
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Item 16. Investment Discretion
Rilex Capital generally is granted the authority to exercise discretion on behalf of its clients. Rilex
Capital is considered to exercise investment discretion over a client’s account if it can affect
transactions for the client without first having to seek the client’s consent. Rilex Capital is given this
authority through a power-of-attorney included in the agreement between Rilex Capital and the client.
Clients may request a limitation on this authority (such as certain securities not to be bought or sold).
Item 17. Voting Client Securities
Rilex Capital votes proxies for clients who have given formal permission to their custodians for this
service. Proxies are generally voted according to management’s recommendations except in cases
where a proposal clearly conflicts with clients’ interests in the view of Rilex Capital. In that instance,
Rilex Capital will notify the client for their approval.
With respect to shareholder class action litigation and similar matters, Rilex Capital generally will not
make any filings in connection with any shareholder class action lawsuits involving securities currently
or previously held in clients’ accounts but will forward these notices to clients when received. Rilex
Capital recommends that its clients promptly review such materials, as they identify important
deadlines and may require action on the client’s part. Rilex Capital will not be required to notify third
party custodians or clients who utilize third party custodians of shareholder class action lawsuits and
similar matters.
Item 18. Financial Information
Rilex Capital does not require or solicit prepayment of more than $1,200 in fees six months or more
in advance. In addition, Rilex Capital is required to disclose any financial condition that is reasonably
likely to impair its ability to meet contractual commitments to clients. Rilex Capital has no disclosures
pursuant to this Item.