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Form ADV Part 2A Brochure
Cover Page - Item 1
Riverbend Wealth Management, LLC
1341 44th Avenue North, Suite 102
Myrtle Beach, SC 29577
Tel: (843) 970-1049
Email: roxanne@riverbendwm.com
Website: https://riverbendwealthmanagement.com
July 28, 2025
Riverbend Wealth Management, LLC is a registered investment adviser. An "investment adviser" means any person
who, for compensation, engages in the business of advising others, either directly or through publications or writings,
as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for
compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities.
Registration with the SEC or any state securities authority does not imply a certain level of skill or training.
This brochure provides information about the qualifications and business practices of Riverbend Wealth
Management, LLC. If you have any questions about the contents of this brochure, please contact us at (843) 970-
1049. 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 Riverbend Wealth Management, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov. Our firm’s CRD number is 302031.
Riverbend Wealth Management, LLC
Form ADV Part 2A
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure.
On February 10, 2025, we filed our annual updating amendment for fiscal year end 2024. There are no material
changes.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (843) 970-1049 or at roxanne@riverbendwm.com.
Riverbend Wealth Management, LLC
Form ADV Part 2A
Page 3
Table of Contents - Item 3
Contents
Form ADV Part 2A Brochure ..................................................................................................................... 1
Cover Page - Item 1 ................................................................................................................................... 1
Material Changes - Item 2 ......................................................................................................................... 2
Table of Contents - Item 3 ........................................................................................................................ 3
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 6
Performance-Based Fees and Side-By-Side Management - Item 6 .......................................................... 8
Types of Clients - Item 7............................................................................................................................ 8
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ..................................................... 8
Disciplinary Information - Item 9 ............................................................................................................ 16
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 16
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 16
Brokerage Practices - Item 12 ................................................................................................................. 17
Review of Accounts - Item 13 ................................................................................................................. 18
Client Referrals and Other Compensation - Item 14 .............................................................................. 19
Custody - Item 15 .................................................................................................................................... 20
Investment Discretion - Item 16 ............................................................................................................. 20
Voting Client Securities - Item 17 ........................................................................................................... 20
Financial Information - Item 18 .............................................................................................................. 20
Requirements of State-Registered Advisers - Item 19 ............................................................................ 21
Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure ............................................................... 22
Cover Page - Item 1 ................................................................................................................................. 22
Material Changes - Item 2 ....................................................................................................................... 23
Table of Contents - Item 3 ...................................................................................................................... 24
Services Fees and Compensation - Item 4 .............................................................................................. 25
Account Requirements and Types of Clients - Item 5 ............................................................................. 29
Portfolio Manager Selection and Evaluation - Item 6 ............................................................................. 29
Client Information Provided to Portfolio Managers - Item 7 .................................................................. 31
Client Contact with Portfolio Managers - Item 8 .................................................................................... 31
Additional Information - Item 9 .............................................................................................................. 31
Requirements for State-Registered Advisers - Item 10 .......................................................................... 32
Riverbend Wealth Management, LLC dba Riverbend Wealth Management, LLC Privacy Notice .......... 32
Riverbend Wealth Management, LLC
Form ADV Part 2A
Page 4
Advisory Business - Item 4
Riverbend Wealth Management, LLC (hereinafter “RWM” or the “firm”) is a registered investment adviser based
in Myrtle Beach, SC. We are a limited liability company, organized under the laws of the State of South Carolina.
We have been providing investment advisory services since 2024. Jeremy Morris Finger is the principal owner of
RWM.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of
our firm. Where required, such persons are properly registered as investment adviser representatives.
Currently, we offer the following investment advisory services, personalized for each individual client:
•
Financial Planning Services
• Portfolio Management Services
• Retirement Plan referral services
Financial Planning Services
RWM offers various financial planning related services, which assist clients in the management of their financial
resources. Financial planning services are based upon an analysis of the client’s individual needs beginning with
one or more information gathering consultations. Once the firm has collected and analysed all documentation
gathered during these consultations, RWM provides a written financial plan designed to achieve the client’s
financial goals and objectives. RWM then assists clients in developing a strategy for the successful management
of income, assets, and liabilities. In general, financial planning services may include any one or all of the following:
Retirement Planning: RWM’s retirement planning services typically include projections of your likelihood of
achieving your financial goals, typically focusing on financial independence as the primary objective. For situations
where projections show less than the desired results, we may make recommendations, including those that may
impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less,
taking more risk with investments). If you are near retirement or already retired, advice may be given on
appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter
spending during your retirement years.
Risk Management: A risk management review includes an analysis of your exposure to major risks that could have
a significantly adverse effect on your financial picture, such as premature death, disability, property and casualty
losses, or the need for long‐term care planning. Advice may be provided on ways to minimize such risks and about
weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not
purchasing insurance (“self‐insuring”).
Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your
overall financial planning picture. For example, we may make recommendations on which type of account(s) or
specific investments should be owned based in part on their “tax efficiency,” with consideration that there is
always a possibility of future changes to federal, state or local tax laws and rates that may affect your situation.
We recommend that you consult with a qualified tax professional before initiating any tax planning strategy. If
you need to hire someone for such purposes, we can provide you with contact information for accountants or
attorneys who specialize in this area. We will participate in meetings or phone calls between you and your tax
professional with your approval.
Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan,
which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice
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also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate
planning strategies, such as the use of applicable trusts. We always recommend that you consult with a qualified
attorney when you initiate, update, or complete estate planning activities. We may provide you with contact
information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes.
From time to time, we will participate in meetings or phone calls between you and your attorney with your
approval or request.
Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify
what you plan to accomplish, what resources you will need to make it happen, how much time you will need to
reach the goal, and how much you should budget for your goal.
Insurance: Review of existing policies to ensure proper coverage for life, health, disability, long-term care, liability,
home, and automobile.
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and
risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options,
as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The
strategies and types of investments we may recommend are further discussed in Item 8 of this brochure.
Employee Benefits Optimization: We will provide recommendations as to whether you, as an employee, are
taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider
and/or recommend the various benefit programs that can be structured to meet both business and personal
retirement goals.
Business Planning: We provide consulting services for clients who currently operate their own business, are
considering starting a business, or are planning for an exit from their current business. Under this type of
engagement, we work with you to assess your current situation, identify your objectives, and develop a plan
aimed at achieving your goals.
Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your
current surplus or deficit, along with advice on prioritizing how any surplus should be used or how to reduce
expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors
such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe
to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with
a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts.
College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary
education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to
savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for
financial aid or the best way to contribute to grandchildren (if appropriate).
The recommendations and solutions are designed to achieve the client’s desired goals, subject to periodic
evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are
based on your financial situation based on the information provided to the firm. We should be notified promptly
of any change to your financial situation, goals, objectives, or needs.
Clients can also request financial planning services that cover a specific area, such as retirement or estate
planning, asset allocation analysis, manager due diligence, and 401(k) platform due diligence. Clients may choose
to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so by
engaging us for investment advisory services or by using any advisory, brokerage, or insurance provider you
choose.
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Important Note: Information related to tax and legal consequences that is provided as part of the financial plan is
for informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized advice.
Portfolio Management Services - Wrap Fee Program
RWM is the portfolio manager and sponsor of the Riverbend Wrap Fee Program. A wrap fee program combines
portfolio management and trade execution for a single fee. RWM and its Associated Persons are responsible for
determining the general portfolio allocation in the client's account using internally developed or external asset
allocation models. External portfolio managers are usually selected from Fidelity’s Managed Account Xchange
(FMAX) or Separate Account Network (SAN). However, other managers can be selected should the firm determine
the use of such managers is in the client’s best interest. The transactions in the client's account will be executed
by Fidelity Institutional Wealth Services and/or its affiliate, National Financial Services LLC (collectively “Fidelity”).
The client pays RWM an all-inclusive Wrap fee. RWM pays Fidelity a portion of this fee for trade execution
expenses. The external portfolio manager charges an additional fee to manage the portion of the client’s portfolio
that has been delegated to it. Detailed information about the Riverbend Wrap Fee Program and program fees is
provided in the Form ADV Part 2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A
Disclosure Brochure.
As part of our overall portfolio management services, we provide asset allocation review, rebalancing and
management services for accounts that are not held in custody of the qualified custodian(s) recommended by our
firm. These services are provided through an account aggregation service called Pontera. The service primarily
applies to ERISA and non-ERISA plan assets such as 401(k)s and 403(b)s, and other assets that must be held in
custody of the plan custodian(s). We regularly review the available investment options in these accounts, monitor
them, and periodically rebalance and implement our strategies using different tools as necessary. If you elect to
allow us to manage your assets through Pontera, you will be notified via email when we place trades through
Pontera.
Retirement Plan referral services
We recommend the services of third-party investment advisers to assist retirement plan sponsors and
participants with the management of their plan and investment lineup. All third-party investment advisers
recommended by our firm must either be registered as investment advisers or exempt from registration
requirements. Factors that we take into consideration when making our recommendations include, but are not
limited to, the following: the third-party investment adviser’s performance, methods of analysis, fees, your
financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the
third-party investment adviser’s performance to ensure its management and investment style remains aligned
with your investment goals and objectives.
Assets Under Management
As of January 22, 2025, RWM has $232,957,679 of discretionary and $0 of non-discretionary assets under
management.
Fees and Compensation - Item 5
Financial Planning Services Fees
RWM charges a negotiable hourly fee of up to $500.00 or a fixed fee of up to $10,000.00 for financial planning
services. Prior to engaging RWM to provide financial planning services, clients will be required to enter into a
written financial planning agreement. The financial planning agreement will set forth the terms and conditions of
the engagement and will describe the scope of the services to be provided.
50% of the financial planning fees is payable upon execution of the financial planning agreement with the balance
due and payable upon completion of contracted services. Fee payment arrangements may be negotiated with the
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Form ADV Part 2A
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client on a case-by-case basis and all such arrangements will be clearly set forth in the financial planning
agreement signed by the client and the firm.
Either party may terminate the financial planning agreement by written notice to the other. In the event the client
terminates RWM’s financial planning services, the balance of any prepaid, unearned fees (if any) will be promptly
refunded to the client. RWM does not require the prepayment of over $1,200, six or more months in advance.
Portfolio Management Services - Wrap Fee Program
Detailed information about the Riverbend Wrap Fee Program and program fees is provided in the Form ADV Part
2A, Appendix 1 (Wrap Brochure) that is attached to this Form ADV Part 2A Disclosure Brochure.
Retirement Plan referral services Fees
Advisory fees charged by third-party investment advisers are separate and apart from our advisory fees. Advisory
fees that you pay to third-party investment advisers are established and payable in accordance with the Form
ADV Brochure provided by each third-party investment adviser to whom you are referred. These fees may or may
not be negotiable. We will receive a share of the fee charged by the third-party investment adviser based on the
payout schedule we negotiate with each third-party investment adviser. Since our compensation may differ
depending upon our individual agreement with each third-party investment adviser, we have an incentive to
recommend one third-party investment adviser over another third-party investment adviser with whom we have
less favorable compensation arrangements. At all times RWM and its Associated Persons uphold their fiduciary
duty of fair dealing with clients.
You will be required to sign an agreement directly with the third-party investment adviser(s). You may terminate
your advisory relationship with the third-party investment adviser(s) according to the terms of your agreement
with the third-party investment adviser(s). You should review each adviser’s brochure for specific information on
how you may terminate your advisory relationship with the adviser and how you may receive a refund, if
applicable. You should contact the third-party investment adviser directly for questions regarding your advisory
agreement with the third-party investment adviser.
A complete description of the services provided by third-party investment advisers, the amount of total fees, the
payment structure, termination provisions and other aspects of the relationship are detailed and disclosed in the
third-party investment adviser’s Form ADV or other applicable disclosure documents. A copy of all relevant
disclosure documents of the third-party investment adviser and the individual servicing the client relationship will
be provided to anyone interested in these programs/managers.
Additional Information about Fees and Expenses
All fees paid to RWM for investment advisory services are separate and distinct from the fees and expenses
charged to shareholders by investment companies like unit investment trusts, mutual funds or exchange traded
funds. These fees and expenses are described in each fund's prospectus. These fees generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, you
may pay an initial or deferred sales charge.
You could invest in a mutual fund directly, without the services of RWM. In which case, you would not receive
ongoing planning and portfolio management services provided by RWM, which are designed, among other things,
to assist you in determining which mutual fund or funds are most appropriate for your financial condition and
objectives. Accordingly, you should review both the fees charged by the funds and the fees charged by RWM to
fully understand the total amount of fees to be paid by you to evaluate the advisory services being provided.
Although RWM uses its best efforts to purchase lower-cost mutual fund shares when available, some mutual fund
companies do not offer institutional classes to us or funds that do not pay 12b-1 distribution fees.
IRA Rollover Considerations
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Form ADV Part 2A
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As a normal extension of financial advice, we provide education or recommendations related to the rollover of an
employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice
offers advantages and disadvantages, depending on desired investment options and services, fees and expenses,
withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and
retirement plans. The complexity of these choices may lead an investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
(“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we
have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over
to an IRA and outlined ongoing services will be extended to these assets. We are fiduciaries under the Investment
Advisers Act of 1940. We have to act in your best interests and not put our interest ahead of yours. At the same
time, the way we make money creates some conflicts with your interests.
Compensation for the Sale of Investment Products
DPL Financial Partners, LLC (“DPL”): RWM is a member of the DPL Financial Partners network, for which we pay a
membership fee. Being part of this network gives us access to a variety of commission-free insurance and annuity
products. It is important for you to know that when we suggest you buy an insurance or annuity product through
DPL or move an existing annuity product to them, RWM and its Associated Persons do not receive any
commission-based compensation from DPL for making these recommendations. However, there are situations
where RWM will apply an Assets Under Management (AUM) fee to a fee-based annuity product, specifically when
it's considered a fee-based annuity. While DPL does earn compensation based on the sale of products, our
relationship with them is focused on providing you with access to commission-free options that best suit your
financial needs. We do not exclusively use DPL for insurance and annuity product recommendations.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets.
Side-by-side management refers to the practice of managing accounts that are charged performance-based fees
while at the same time managing accounts that are not charged performance-based fees. We do not accept
performance-based fees or participate in side-by-side management. Our fees are calculated as described in the
Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital
appreciation of, the funds in your advisory account(s).
Types of Clients - Item 7
We generally offer investment advisory services to individuals, pension and profit-sharing plans and participants,
trusts, estates, charitable organizations, corporations, and other business entities.
RWM requires a minimum of $500,000 to establish an advisory relationship. In our sole discretion, we may waive
this requirement. This requirement can be met by combining two or more accounts owned by you or related
family members.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
Methods of Analysis
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RWM will use various internal and external methods to determine an appropriate investment strategy. We seek
to recommend investment strategies or products that will give you a diversified portfolio consistent with your
investment objective. We do this by analyzing the various products, investment strategies, and external portfolio
managers to which we provide access. That analysis includes a review of the structure, cost, and investment
performance history of each manager. We also use research provided by third parties such as BlackRock in
determining the type of investments that should be held in client portfolios.
Asset allocation models used by portfolio managers and/or other third-party investment managers are developed
in accordance with investment programs developed by these entities. Clients should refer to the relevant portfolio
managers and/or other third-party investment manager’s Form ADV Part 2 Brochures or comparable disclosure
documents for more information about the methods of analysis and investment strategies used by those firms.
Investment Strategies
We may use one or more of the following investment strategies when advising you on investments:
Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over
a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally
assumes the financial markets will go up over time, which may not be the case. There is also the risk that the
segment of the market that you are invested in or perhaps just your particular investment will go down over time
even if the overall financial markets advance. Long-term investments may create an opportunity cost by "locking-
up" assets that may be better utilized in the short-term in other investments.
Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short
period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform
in the short term which may be very difficult and will incur a disproportionately higher amount of transaction
costs compared to long-term trading. There are many factors that can affect financial market performance in the
short term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a
smaller impact over longer periods of time.
Trading – securities are bought and sold within 30 days. The principal type of risk associated with trading is market
risk. There can be no assurance that a specific investment will achieve its investment objectives and past
performance should not be seen as a guide to future returns. The value of investments and the income derived
may fall as well as rise and investors may not recoup the original amount invested. Investments may also be
affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and government, economic or monetary policies. Additionally, trading is speculative.
Market movements are difficult to predict and are influenced by, among other things, government trade, fiscal,
monetary, and exchange control programs and policies; changing supply and demand relationships; national and
international political and economic events; changes in interest rates; and the inherent volatility of the
marketplace. In addition, from time to time governments intervene, directly and by regulation, in certain markets,
often with the intent to influence prices directly. The effects of governmental intervention may be particularly
significant at certain times in the financial instrument markets and such intervention (as well as other factors)
may cause these markets to move rapidly.
Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow on
securities already in their custodial account. Interest is charged on any borrowed funds for the period of time that
the loan is outstanding. When you purchase securities, you may pay for the securities in full or you may borrow
part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account,
you will be required to open a margin account, which will be carried by the broker-dealer of your account. The
securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a
margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a
brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your
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accounts, in order to maintain necessary level of equity in the account. It is important that you fully understand
the risks involved in trading securities on margin, which are applicable to any margin account that you may
maintain, including any margin account that may be established as a part of our advisory services and held by
your broker-dealer. These risks include the following:
•
•
•
•
•
•
You can lose more funds than you deposit in your margin account.
The broker-dealer can force the sale of securities or other assets in your account.
The broker-dealer can sell your securities or other assets without contacting you.
You may not be able to choose which securities or other assets in your margin account are liquidated or
sold to meet a margin call.
The broker-dealer may move securities held in your cash account to your margin account and pledge the
transferred securities.
You may not be entitled to an extension of time on a margin call.
Option Writing – an option is the right either to buy or sell a specified amount or value of a particular underlying
investment instrument at a fixed price (i.e., the “exercise price”) by exercising the option before its specified
expiration date. Options giving you the right to buy are called “call” options. Options giving you the right to sell
are called “put” options. When trading options on behalf of a client, we generally use covered options. Covered
options involve options trading when you own the underlying instrument on which the option is based.
Investments in options contracts have the risk of losing value in a relatively short period. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Risk of Loss
Clients should be aware that investing in securities involves a risk of loss that they should be prepared to bear.
Past performance is not indicative of future results. Therefore, you should never assume that future performance
of any specific investment or investment strategy will be profitable. Investing in securities (including stocks,
mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there
may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even
imply that our services and methods of analysis can or will predict future results, successfully identify market tops
or bottoms, or insulate you from losses due to market corrections or declines.
There are certain additional risks associated with investing in securities, as described below:
Recommendation of Particular Types of Securities: We provide advice on various types of securities and we do
not necessarily recommend one particular type of security over another since each client has different needs and
different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would
not be possible to list here all of the specific risks of every type of investment. Even within the same type of
investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an
investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
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be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Equity (stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and to volatile
increases and decreases in value as market confidence in and perceptions of their issuers change. If you held
common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk
than if you held preferred stocks and debt obligations of the issuer.
Company Risk: When investing in stock positions, there is always a certain level of company or industry specific
risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through
appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based
on factors specific to the company or its industry. For example, if a company’s employees go on strike or the
company receives unfavorable media attention for its actions, the value of the company may be reduced.
Fixed Income Risk: When investing in bonds, there is the risk that the issuer will default on the bond and be
unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the
risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face
the same inflation risk. In addition pricing risk if not held to maturity and interest rate move.
Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets
in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors,
certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times,
an account may, or may be advised to, hold a relatively small number of securities positions, each representing a
relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a
more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences
adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more
than it would if the portfolio’s investments were not so concentrated. A change in the value of a single investment
within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a
portfolio that holds more diversified investments.
Preferred Securities Risk: Preferred Securities have similar characteristics to bonds in that preferred securities
are designed to make fixed payments based on a percentage of their par value and are senior to common stock.
Like bonds, the market value of preferred securities is sensitive to changes in interest rates as well as changes in
issuer credit quality. Preferred securities, however, are junior to bonds with regard to the distribution of corporate
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earnings and liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock
also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board of directors,
whereas interest payments on bonds generally do not require action by the issuer’s board of directors, and
bondholders generally have protections that preferred stockholders do not have, such as indentures that are
designed to guarantee payments – subject to the credit quality of the issuer – with terms and conditions for the
benefit of bondholders. In contrast, preferred stocks generally pay dividends, not interest payments, which can
be deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another difference
is that preferred dividends are paid from the issue’s after-tax profits, while bond interest is paid before taxes.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments,
other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the
fund's investments in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant
degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different
types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition,
while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds
do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the risk of
capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these
securities are not guaranteed or insured by the FDIC or any other government agency.
Inverse Funds: Inverse mutual funds and ETFs, which are sometimes referred to as "short" funds, seek to provide
the opposite of the single-day performance of the index or benchmark they track. Inverse funds are often
marketed as a way to profit from, or hedge exposure to, downward moving markets. Some inverse funds also use
leverage, such that they seek to achieve a return that is a multiple of the opposite performance of the underlying
index or benchmark (i.e., -200%, -300%). In addition to leverage, these funds may also use derivative instruments
to accomplish their objectives. As such, inverse funds are highly volatile and provide the potential for significant
losses.
Management Risk: Your investment with our firm varies with the success and failure of our investment strategies,
research, analysis and determination of portfolio securities. If our investment strategies do not produce the
expected returns, the value of the investment will decrease.
Municipal Securities Risk: The value of municipal obligations can fluctuate over time, and may be affected by
adverse political, legislative and tax changes, as well as by financial developments that affect the municipal
issuers. Because many municipal obligations are issued to finance similar projects by municipalities (e.g., housing,
healthcare, water and sewer projects, etc.), conditions in the sector related to the project can affect the overall
municipal market. Payment of municipal obligations may depend on an issuer’s general unrestricted revenues,
revenue generated by a specific project, the operator of the project, or government appropriation or aid. There
is a greater risk if investors can look only to the revenue generated by the project. In addition, municipal bonds
generally are traded in the “over-the-counter” market among dealers and other large institutional investors. From
time to time, liquidity in the municipal bond market (the ability to buy and sell bonds readily) may be reduced in
response to overall economic conditions and credit tightening.
Foreign Securities Risk: Foreign securities are subject to additional risks not typically associated with investments
in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic,
regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have
the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less
government supervision, less publicly available information, limited trading markets and greater volatility. To the
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extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political
changes, changes in taxation, or currency controls that could adversely affect the values of these investments.
Emerging markets have been more volatile than the markets of developed countries with more mature
economies.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to manage all
or a portion of your assets, we will primarily rely on investment model portfolios and strategies developed by the
third-party investment adviser and their portfolio managers. If there is a significant deviation in characteristics or
performance from the stated strategy and/or benchmark, we may recommend changing models or replacing a
third-party investment adviser. The primary risks associated with investing with a third-party investment adviser
is that while a particular third-party investment adviser may have demonstrated a certain level of success in the
past; it may not be able to replicate that success in future markets. In addition, as we do not control the underlying
investments in third-party model portfolios, there is also a risk that a third-party may deviate from the stated
investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. To mitigate
this risk, we seek third parties with proven track records that have demonstrated a consistent level of
performance and success over time. A third-party’s past performance is not a guarantee of future results and
certain market and economic risks exist that may adversely affect an account’s performance that could result in
capital losses in your account.
Alternatives Risk: Non-traded REITs, business development companies, limited partnerships, and direct
alternatives are subject to various risks such as liquidity and property devaluation based on adverse economic
and real estate market conditions and may not be suitable for all investors. A prospectus that discloses all risks,
fees, and expenses may be obtained from your adviser. Read the prospectus carefully before investing. This is not
a solicitation or offering which can only be made in conjunction with a copy of the prospectus. Investors
considering an investment strategy utilizing alternative investments should understand that alternative
investments are generally considered speculative in nature and may involve a high degree of risk, particularly if
concentrating investments in one or few alternative investments.
Risks Associated with Investing in Private Funds: Private investment funds are not registered with the Securities
and Exchange Commission and may not be registered with any other regulatory authority. Accordingly, they are
not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little
public information available about their investments and performance. Moreover, as sales of shares of private
investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to
sell its shares of a private investment company at an advantageous price and time. Since shares of private
investment companies are not publicly traded, from time to time it may be difficult to establish a fair value for
the client’s investment in these companies.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
Illiquid securities: Illiquid securities involve the risk that investments may not be readily sold at the desired time
or price. Securities that are illiquid, that are not publicly traded and/or for which no market is currently available
may be difficult to purchase or sell, which may impact the price or timing of a transaction. An inability to sell
securities can adversely affect an account's value or prevent an account from taking advantage of other
investment opportunities. Lack of liquidity may cause the value of investments to decline and illiquid investments
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may also be difficult to value. A client may not be able to liquidate investment in the event of an emergency or
any other reason.
Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private equity and real
estate. Investment in an illiquid asset vehicle poses similar risks as direct investments in illiquid securities. In
addition, investment in an illiquid asset vehicle will be subject to the terms and conditions of the illiquid asset
vehicle’s investment policy and governing documents, which often include provisions that may involve investor
lock-in periods, mandatory capital calls, redemption restrictions, infrequent valuation of assets, etc. In addition,
investments in illiquid securities or vehicle may normally involve investment in non-marketable securities where
there is limited transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly
with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid securities or
vehicles may include restrictions on withdrawal rights and shares may not be freely transferable.
Structured Notes: Below are some specific risks related to the structured notes recommended by our firm:
•
Complexity: Structured notes are complex financial instruments. Clients should understand the reference
asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s)
or index(es) in calculating the note’s performance. This payoff calculation may include leverage
multiplied on the performance of the reference asset or index, protection from losses should the
reference asset or index produce negative returns, and fees. Structured notes may have complicated
payoff structures that can make it difficult for clients to accurately assess their value, risk, and potential
for growth through the term of the structured note. Determining the performance of each note can be
complex and this calculation can vary significantly from note to note depending on the structure. Notes
can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-
leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a
structured note to fully understand how the payoff on a note will be calculated and discuss these issues
with our firm.
•
•
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which is often
referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing
financial institution. Many structured notes do not offer this feature. For structured notes that do not
offer principal protection, the performance of the linked asset or index may cause clients to lose some,
or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the
structured note may include changes in equity or commodity prices, changes in interest rates or foreign
exchange rates, and/or market volatility.
Issuance price and note value: The price of a structured note at issuance will likely be higher than the fair
value of the structured note on the date of issuance. Issuers now generally disclose an estimated value
of the structured note on the cover page of the offering prospectus, allowing investors to gauge the
difference between the issuer’s estimated value of the note and the issuance price. The estimated value
of the notes is likely lower than the issuance price of the note to investors because issuers include the
costs for selling, structuring, and/or hedging the exposure on the note in the initial price of their notes.
After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value
given their complexity.
Liquidity: The ability to trade or sell structured notes in a secondary market is often very limited, as
structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on
securities exchanges. As a result, the only potential buyer for a structured note may be the issuing
financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In
addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes
they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk
selling the note at a discount to its value at the time of sale.
Credit risk: Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is
obligated to make payments on the notes as promised. These promises, including any principal
protection, are only as good as the financial health of the structured note issuer. If the structured note
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issuer defaults on these obligations, investors may lose some, or all, of the principal amount they
invested in the structured notes as well as any other payments that may be due on the structured notes.
Cybersecurity Risks: Our firm and our service providers, including any third-party service providers we may
recommend or require you to engage directly, are subject to risks associated with a breach in cybersecurity.
Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect
networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer users, and
to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or
misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional
events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of
transactions, affecting the ability to calculate net asset value, impeding or sabotaging trading or fraud. Clients
may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic
analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized
use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any
such breach could expose our firm and/or service providers to civil liability as well as regulatory inquiry and/or
action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal
information. While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have
not been identified. Similar types of cybersecurity risks are also present for issuers of securities, investment
companies, other investment advisers in which we invest, and service providers we use or recommend using,
which could result in material adverse consequences for such entities and may cause a client's investment in such
entities to lose value.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a
wide geographic area, crossing international boundaries, and causing significant economic, social, and political
disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety
of factors including the global response of regulators and governments to address and mitigate the worldwide
effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and
macroeconomic factors will negatively impact investment returns.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”, “digital
currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an emerging asset
class. There are thousands of cryptocurrencies, the most well-known of which is Bitcoin. Certain of the firm’s
clients may have exposure to bitcoin or another cryptocurrency, directly or indirectly through an investment such
as an ETF or other investment vehicles. Cryptocurrency operates without central authority or banks and is not
backed by any government. Cryptocurrencies may experience very high volatility and related investment vehicles
may be affected by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also
trade at a significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state, or
foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still
developing. The market price of many cryptocurrencies, including bitcoin, has been subject to extreme
fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience
losses if the value of the client’s investments declines. Similar to fiat currencies (i.e., a currency that is backed by
a central bank or a national, supra-national, or quasi-national organization), cryptocurrencies are susceptible to
theft, loss, and destruction. Cryptocurrency exchanges and other trading venues on which cryptocurrencies trade
are relatively new and, in most cases, largely unregulated and may therefore be more exposed to fraud and failure
than established, regulated exchanges for securities, derivatives, and other currencies. The SEC has issued a public
report stating U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical glitches,
hackers, or malware. Due to relatively recent launches, most cryptocurrencies have a limited trading history,
making it difficult for investors to evaluate investments. Generally, cryptocurrency transactions are irreversible
such that an improper transfer can only be undone by the receiver of the cryptocurrency agreeing to return the
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cryptocurrency to the original sender. Digital assets are highly dependent on their developers and there is no
guarantee that development will continue or that developers will not abandon a project with little or no notice.
Third parties may assert intellectual property claims relating to the holding and transfer of digital assets, including
cryptocurrencies, and their source code. Any threatened action that reduces confidence in a network’s long-term
ability to hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are uncertain
and an investment in cryptocurrency may produce income that is not treated as qualifying income for purposes
of the income test applicable to regulated investment companies. Certain cryptocurrency investments may be
treated as a grantor trust for U.S. federal income tax purposes, and an investment by the firm’s clients in such a
vehicle will generally be treated as a direct investment in cryptocurrency for tax purposes and “flow-through” to
the underlying investors.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or of the integrity of our management. Neither we nor our
management persons have a history of material legal or disciplinary events to report in this section.
Other Financial Industry Activities or Affiliations - Item 10
Neither RWM nor any of its management persons are registered as a futures commission merchant, an
introducing broker, a commodity trading adviser, or a commodity pool operator, nor do they have an application
pending or otherwise in process for the purpose of seeking registration as any of these types of firms. Further,
none of our management persons are registered as or currently seeking registration as associated persons of any
of these types of firms.
Recommendation of Other Advisers
In some cases, we recommend the services of a third-party investment adviser and we share in the compensation
received by the third-party investment adviser. As a result of these arrangements, we are incentivized to
recommend investment advisers from whom we receive solicitor/referral fees as opposed to another investment
adviser from whom we do not receive such fees. We continually monitor other investment advisers that we might
recommend under a referral arrangement. In the event that such investment advisers are not meeting the
standards that we believe meet your needs, we will seek other investment advisers that may be a better fit for
your specific management needs.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
RWM has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
Code includes RWM’s policies and procedures developed to protect client’s interests in relation to the following
topics:
▪
The duty at all times to place the interests of clients first;
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▪
▪
▪
▪
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the Code;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of RWM’s Code of Ethics is available upon request to our firm at (843) 970-1049 or at
roxanne@riverbendwm.com.
Participation or Interest in Client Transactions
Neither our firm nor any of our Associated Persons have any material financial interest in client securities
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
At times, RWM and/or its related persons take positions in the same securities as clients, which poses a conflict
of interest with clients. In an effort to uphold our fiduciary duties to clients, RWM and its related persons will
generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades.
Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (e.g.,
a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed
to be a conflict (e.g., a purchase or sale that is minimal in relation to the total outstanding value, and as such
would have negligible effect on the market price) would not be deemed a material conflict requiring disclosure at
the time of trading. Alternatively, Accounts owned by our firm or persons associated with our firm participate in
block trading with client accounts; however, they will not be given preferential treatment. Mutual fund purchases
are not subject to these policies because the transactions are executed at NAV at the end of the trading day.
Brokerage Practices - Item 12
We recommend the services of Fidelity Institutional Wealth Services and/or its affiliate, National Financial
Services LLC (collectively “Fidelity”). These firms are independent and unaffiliated SEC-registered broker-dealers
and members of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection
Corporation ("SIPC"). These firms offer us services that include custody of securities, trade execution, clearance,
and settlement of transactions.
We are independently owned and operated, and we are not affiliated with Fidelity. Fidelity will hold your assets
in a brokerage account and will buy and sell securities in your account(s) upon our instructions. While we
recommend that you use Fidelity as your account custodian/broker-dealer, you will open your account with
Fidelity by entering into an account agreement directly with them. We do not open an account for you.
Fidelity generally does not charge you separately for brokerage and custody services, but it is compensated by
charging an asset-based fee directly to our firm. The fee is indirectly passed on to the client through our wrap
program fee.
RFG understands its duty for best execution and considers all factors in making recommendations to clients. While
the quality of execution at the best price is an important determinant, best execution does not necessarily mean
the lowest price and it is not the sole consideration. The trading process of any broker-dealer suggested by RWM
must be efficient, seamless, and straightforward. Overall custodial support services, trade correction services, and
statement preparation are some of the other factors determined when suggesting a broker-dealer.
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Research and Other Soft Dollar Benefits Received from Fidelity
Although not considered soft dollars, Fidelity provide access to a broad range of investment products, execution
of securities transactions, and custody of client assets. The investment products available through Fidelity include
some to which we might not otherwise have access or that would require a significantly higher minimum initial
investment by our clients. Fidelity’s services described in this paragraph generally benefit you and your account.
Services that May Not Directly Benefit You: Fidelity also makes available to us other products and services that
benefit us but may not directly benefit you or your account. These products and services assist us in managing
and administering our clients’ accounts. They include limited-scope investment research. We may use this
research to service all or some substantial number of our clients’ accounts, including accounts not maintained at
Fidelity. In addition to investment research, Fidelity also makes available software and other technology that:
•
•
•
•
•
provide access to client account data (such as duplicate trade confirmations and account statements);
facilitate trade execution;
provide pricing and other market data;
facilitate payment of our fees from our clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Trade Aggregation
While individual client advice is provided to each account, client trades can be executed as block trades. The
executing broker will be informed that the trades are for the accounts of RWM’s clients and not for RWM itself.
No advisory account within the block trade will be favored over any other advisory account, and thus, each
account will participate in an aggregated order at the average share price. The aggregation should, on average,
slightly reduce the overall costs of execution. We will not aggregate a client’s order if, in a particular instance, we
believe that aggregation would cause the client’s cost of execution to be increased. The broker-dealer/custodian
will be notified of the amount of each trade for each account. RWM and/or its Associated Persons participate in
block trades with clients, and can also participate on a pro rata basis for partial fills, but only after the
determination has been made that clients will receive fair and equitable treatment.
Directed Brokerage
RWM allows clients to direct brokerage. RWM will be unable to achieve most favorable execution of client
transactions if clients choose to direct brokerage to a broker-dealer that does not have an existing relationship
with our firm. Directed brokerage arrangements can result in higher overall costs because, without the ability to
direct brokerage, RWM will not be able to aggregate orders to reduce transaction costs.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should
have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include
canceling the trade, adjusting an allocation, and/or reimbursing the account.
Review of Accounts - Item 13
Portfolio Management Account Reviews
RWM monitors client account holdings on a continuous basis and conducts a formal review of investment
allocations at least annually. Accounts are reviewed by the Associated Person assigned to the account.
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Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional
reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation
or investment objectives, or upon client request.
A financial plan is a snapshot in time and no ongoing reviews are conducted. We recommend clients
engage us on a periodic basis to update their financial plan.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis. RWM may
also provide performance reports upon client request.
Client Referrals and Other Compensation - Item 14
Custodian Compensation
As described in Item 12 above, we receive economic benefits from our custodial broker-dealer in the form of
support products and services they make available to us and other independent investment advisers whose clients
maintain their accounts at these custodial broker-dealers. The availability of custodial products and services is
not dependent upon or based on the specific investment advice we provide our clients, such as buying or selling
specific securities or specific types of securities for our clients. The products and services provided by the custodial
broker-dealer, how they benefit us, and the related conflicts of interest are described above (see Item 12 –
Brokerage Practices).
Economic Benefits Received from Vendors and Product Sponsors
Occasionally, our firm and our Associated Persons will receive additional compensation from vendors or product
sponsors. Compensation could include items such as gifts; an occasional dinner or ticket to a sporting event;
reimbursement in connection with educational meetings with an Associated Person, reimbursement for
consulting services, client workshops, or events; or marketing events or advertising initiatives, including services
for identifying prospective clients. Receipt of additional economic benefits creates a conflict of interest because
our firm and Associated Persons have an incentive to recommend and use vendors or specific products based on
the additional economic benefits obtained rather than solely on the client’s needs. We address this conflict of
interest by recommending and using vendors and products that we, in good faith, believe are appropriate for the
client’s particular needs. While clients are under no direct obligation to use any specific vendors we may
recommend, by engaging us for advisory services, the client agrees to our use of the service providers we select
to provide our services. Where clients engage us for discretionary services, clients grant us authorization to select
the investments, models, and providers for the management of their account(s) as we deem appropriate based
on their individual needs and circumstances, subject to any written guidelines or restrictions the client may
request.
Recommendation of Other Advisers
In some cases, we recommend the services of third-party investment advisers and we share in the compensation
received by third-party investment advisers. As a result of these arrangements, we are incentivized to recommend
investment advisers from whom we receive solicitor/referral fees as opposed to another investment adviser from
whom we do not receive such fees. We continually monitor other investment advisers that we might recommend
under a referral arrangement. In the event that such investment advisers are not meeting the standards that we
believe meet your needs, we will seek other investment advisers that may be a better fit for your specific
management needs.
Client Referrals
We do not compensate third parties for referring clients to our firm.
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Custody - Item 15
RWM is deemed to have custody of client funds because of the fee deduction authority granted by the client in
the Advisory Agreement. You will receive account statements at least quarterly from the broker-dealer or other
qualified custodian. The custodian will not verify the calculation of the advisory fees. You are urged to review
custodial account statements for accuracy.
With respect to third-party standing letters of authorization (“SLOA”) where a client grants us authority to direct
custodians to disburse funds to one or more third-party accounts, we are deemed to have custody pursuant to
Rule 206(4)-2 (the “Custody Rule”). In such cases, we will take steps to have controls and oversight in place to
comply with the no-action letter issued by the SEC on February 21, 2017 (the “SEC no-action letter”). Provided we
meet all of the conditions stipulated in the SEC no-action letter, we are not required to comply with the surprise
examination requirements of the Custody Rule. Where our firm acts pursuant to a third-party SLOA, we believe
we are making a good faith effort to comply with the representations noted in the SEC no-action letter.
Additionally, since many of the representations noted in the SEC no-action letter involve the qualified custodian’s
operations, we will collaborate closely with our custodian(s) to ensure that the representations are met.
Investment Discretion - Item 16
RWM offers Portfolio Management Services on a discretionary, and in limited cases, non-discretionary basis.
Clients must grant discretionary authority in the management agreement. Discretionary authority extends to the
types and amounts of securities to be bought and sold in client accounts. However, our firm does not retain
discretionary authority to select the broker-dealer used for transactions, or commission rates paid.
The client provides RWM discretionary authority via a limited power of attorney in the management agreement
and in the contract between the client and the custodian.
If you wish, you may limit our discretionary authority, for example, by setting a limit on the type of securities that
can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer
to the “Advisory Business” section in this Brochure for more information on our discretionary management
services.
Non-discretionary portfolio management service means that we must obtain your approval prior to making any
transactions in your account.
Voting Client Securities - Item 17
RWM does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials
directly from the custodian. Questions about proxies may be made via the contact information on the cover page.
Financial Information - Item 18
We are required in this Item to provide you with certain financial information or disclosures about RWM’s,
financial condition. RWM does not require the prepayment of over $1,200, six or more months in advance.
Riverbend Wealth Management, LLC
Form ADV Part 2A
Page 21
Additionally, RWM has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients, and it has not been the subject of a bankruptcy proceeding.
Requirements of State-Registered Advisers - Item 19
This section is not applicable because we are SEC registered
Form ADV Part 2A, Appendix 1: Wrap Fee Program Brochure
Cover Page - Item 1
Riverbend Wealth Management, LLC
1341 44th Avenue North, Suite 102
Myrtle Beach, SC 29577
Tel: (843) 970-1049
Email: roxanne@riverbendwm.com
Website: https://riverbendwealthmanagement.com
February 10, 2025
Riverbend Wealth Management, LLC is a registered investment adviser. An "investment adviser" means any person
who, for compensation, engages in the business of advising others, either directly or through publications or writings,
as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for
compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities.
Registration with the SEC or any state securities authority does not imply a certain level of skill or training.
This wrap fee program brochure provides information about the qualifications and business practices of Riverbend
Wealth Management, LLC If you have any questions about the contents of this brochure, please contact us at (843)
970-1049. 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 Riverbend Wealth Management, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov. Our firm’s CRD number is 302031.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 23
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this wrap fee
brochure.
On February 10, 2025, we filed our annual updating amendment for fiscal year end 2024. There are no material
changes.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (843) 970-1049 or at roxanne@riverbendwm.com.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 24
Table of Contents - Item 3
A table of contents is provided in Item 3 of the firm’s Form ADV Part 2A Disclosure Brochure above.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 25
Services Fees and Compensation - Item 4
Services
Riverbend Wealth Management, LLC (hereinafter “RWM”) offers a wrap fee program, the Riverbend Wrap Fee
Program, whereby RWM manages client accounts for a single, bundled fee that includes portfolio management
services, custodial services, and transaction/commission costs. Under the Riverbend Wrap Fee Program, RWM
offers discretionary, and in limited cases, non-discretionary investment advice designed to assist clients in
obtaining professional portfolio management for an inclusive “wrap fee.”
RWM and its Associated Persons are responsible for determining the general portfolio allocation in the client's
account using internally developed or external asset allocation models. External portfolio managers are usually
selected from Fidelity’s Managed Account Xchange (FMAX) or Separate Account Network (SAN). However, other
managers can be selected should the firm determine the use of such managers is in the client’s best interest. The
transactions in the client's account will be executed by Fidelity Institutional Wealth Services and/or its affiliate,
National Financial Services LLC (collectively “Fidelity”).
RWM receives a portion of the Wrap Fee for portfolio management services and Fidelity will receive a portion of
the fee for trade execution and custodial services. The terms and conditions under which a client participates in
the Riverbend Wrap Fee Program are set forth in the written agreement between the client and RWM. The overall
cost incurred from participation in the Riverbend Wrap Fee Program may be higher or lower than it would if the
services were purchased separately.
The portfolio management services for the Riverbend Wrap Fee Program are generally offered on a discretionary
basis. However, in limited cases, we may take on non-discretionary arrangements. Our investment advice is
tailored to meet our clients’ needs and investment objectives. Subject to any written guidelines that you may
provide, we will be granted discretionary authority to manage your account. Once the portfolio allocation has
been agreed upon, the ongoing supervision and management of the portfolio will be our responsibility.
Discretionary authorization is granted to us by you in a written agreement. This allows our firm to decide on
specific securities, the quantity of the securities and placing buy or sell orders for your account without obtaining
your approval for each transaction. This type of authorization is granted using either the investment advisory
agreement the client signs with our firm, a limited power of attorney agreement, or trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for
your account) by providing our firm with restrictions and guidelines in writing. Non-discretionary portfolio
management service means that we must obtain your approval prior to making any transactions in your account.
types of
investments
involve certain additional degrees of
risk,
Wrap accounts are managed to diversify clients’ investments and may include various types of securities such as
exchange listed equities, over the counter equities, foreign issues, American depository receipts, corporate debt
securities, commercial paper, certificates of deposit, municipal securities, investment company securities
(including mutual funds and exchange traded funds), US Government securities, options contracts on securities
and/or commodities, private equity instruments, alternative investments, structured notes, and interests in
partnership investing in real estate. Additionally, we will provide advice on existing investments you may hold at
the inception of the advisory relationship or on other types of investments for which you ask advice. Because
some
they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk,
liquidity and suitability.
Once the client portfolio is constructed, RWM provides continuous supervision of the portfolio as changes in the
market conditions and client circumstances may require. Investments and allocations are determined based upon
the clients’ predefined objectives, risk tolerance, time horizons, financial horizons, financial information, and
other various suitability factors. Further restrictions and guidelines imposed by clients may affect the composition
and performance of a client’s portfolio. For these reasons, performance of the portfolio might not be identical
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 26
with other clients of RWM. We review the clients’ financial circumstances and investment objectives on an
ongoing basis and make adjustments to clients’ portfolios or allocation models as may be necessary to achieve
the desired results.
In providing the contracted services, we are not required to verify any information we receive from you or from
your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the
information you provide. You must promptly notify our firm of any changes in your financial circumstances or
investment objectives that might affect the manner in which your accounts should be managed.
Fees
RWM charges a single negotiable asset-based fee for its management services, which includes the cost of our
portfolio management services, custodial services, and the execution of securities transactions. Clients should
note, however, that external portfolio managers will charge a separate fee that is in addition to our overall wrap
program fee. This additional fee will be disclosed to the client in the external portfolio manager’s Form ADV Part
2 Brochure or equivalent disclosure document. The external portfolio manager charges an additional fee of up to
0.70% of assets under management to manage the portion of the client’s portfolio that has been delegated to it.
Our fee is deducted from the client's account held at the custodian provided the client authorizes RWM to debit
the fee from the account. If insufficient cash is available to pay such fees, securities in an amount equal to the
balance of unpaid fees will be liquidated to pay for the unpaid balance.
On an annualized basis, our fees for portfolio management services, subject to negotiation, are based on the
following tiered fee schedule. Since the fee is negotiable, the exact fee paid by you will be stated in the advisory
agreement signed by you and us:
Billable Assets Under Management
Total Annual Fee
First $250,000
1.50%
Next $250,000
1.30%
Next $500,000
1.10%
Next $1,000,000
1.00%
Next $2,000,000
0.90%
Over $4,000,000
0.80%
The annual fee for the Riverbend Wrap Fee Program is billed quarterly, in advance, and is based on the daily
average balance of the account during the preceding quarter. Fees will be assessed pro rata in the event the
Agreement is executed at any time other than the first day of a billing period. We may deduct the fee from a
single, client-designated account to facilitate billing.
For example, a client with an average daily balance of $1,000,000 in assets under management during the first
quarter, will pay a fee of $3,125.00 on the first day of the second quarter. This fee is calculated using the following
methodology:
($250,000 x 1.50%) ÷ 4 = $3,750 ÷ 4 = $937.50
($250,000 x 1.30%) ÷ 4 = $3,250 ÷ 4 = $812.50
($500,000 x 1.10%) ÷ 4 = $5,500 ÷ 4 = $1,375.00
Total Fee: $3,125.00
For held-away assets managed through Pontera, Pontera does not offer us the ability to deduct fees from the
account. As such, fees for the management of held-away assets will either be paid directly by you or deducted
from another account that we manage for you at the qualified custodian(s) recommended by us. Please note that
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 27
all transaction fees (if any) associated with trades placed through Pontera will be borne by the client and not
RWM.
Other fee payment arrangements can be negotiated on a case-by-case basis. These arrangements will be listed in
the advisory agreement signed by the firm and the client.
We encourage you to carefully review the statements you receive from the qualified custodian. If you have
questions about your statements, or if you did not receive a statement from the qualified custodian, please call
our office number located on the cover page of this brochure.
Termination
At the inception of investment management services, the first pay period’s fees will be calculated on a pro-rata
basis. The management agreement between you and RWM will continue in effect until either party terminates
the management agreement in accordance with the terms of the management agreement. RWM’s annual fee
will be pro-rated through the date of termination. Any pre-paid, unearned fees will be promptly refunded to the
client.
Additional Fees and Expenses
The fees are charged as described above and are not based on a share of capital gains of the funds of an advisory
client.
The Riverbend Wrap Fee Program fees do not include mark-ups and mark-downs, dealer spreads or other costs
associated with the purchase or sale of securities, interest, taxes, or other costs, such as national securities
exchange fees, charges for transactions not executed through Fidelity, costs associated with exchanging
currencies, wire transfer fees, or other fees required by law or imposed by third parties. The client will be
responsible for these additional fees and expenses.
All fees paid to RWM for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds to their shareholders. These fees and expenses are described
in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible
distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge.
Each mutual fund, ETF, or variable annuity in which the Account may be invested will also charge a management
fee, other internal expenses, and a possible distribution fee. Certain mutual funds offered through the Riverbend
Wrap Fee Program may impose short-term trading charges (typically 1% - 2% of the amount originally invested)
for redemptions made within short periods of time. In the rare event an early redemption charge is assessed, the
charge would be offset by the advisory fee or paid by RWM.
Otherwise, all of the fees and expenses discussed above will be indirect expenses borne by the account, and will
be in addition to the Riverbend Wrap Fee Program fee. You should consider all of these fees and expenses
(including the Riverbend Wrap Fee Program fee) to fully understand the total amount of fees and expenses to be
paid by your account and to evaluate the advisory services being provided. The fees and expense related to mutual
funds, ETFs, or variable annuities are disclosed in their respective prospectuses or summary disclosure
documents.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1,200
more than six months in advance of services rendered.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in this brochure. As a result, the Associated Person servicing your
account may charge more or less for the same service than another Associated Person of our firm. Further, our
annual investment management fee may be higher than that charged by other investment advisors offering
similar services/programs.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 28
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including
margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory
fee. Clients should note that this practice will increase total assets under management used to calculate advisory
fees, which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest
in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the
firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to
restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may
negatively impact an account’s performance in a rising market.
Please refer to Item 5 of Form ADV Part 2A Brochure above for more information about Fees and Expenses.
Other Important Considerations
•
• Wrap fee programs are not suitable for all investment needs, and any decision to participate in a wrap fee
program should be based on your financial situation, investment objectives, tolerance for risk, and
investment time horizon, among other considerations. The wrap fee program fee may cost the client more
than it would if assets were held in a traditional brokerage account. In a brokerage account, a client is
charged a commission for each transaction, and the representative has no duty to provide ongoing advice
with respect to the account. If the client plans to follow a buy and hold strategy for the account or does
not wish to use RWM for ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a wrap fee program account.
The investment products available to be purchased in the wrap fee program can be purchased by clients
outside of a wrap fee program account, through broker-dealers or other investment firms not affiliated
with RWM. In such cases, our firm would not provide ongoing supervisory and management services for
the account.
• Our firm and our advisory representatives will receive compensation as a result of your participation in the
Riverbend Wrap Fee Program. In certain cases, this compensation will be more than the amount our firm
or the representative would receive if you paid separately for investment advice, brokerage, and other
services. Accordingly, a conflict of interest exists because our firm and our representatives have a financial
incentive to recommend the Riverbend Wrap Fee Program over other programs or services for which the
compensation arrangements are not as beneficial.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 29
• Due to the single fee charged to a Riverbend Wrap Fee Program account, we are regarded as having a
conflict of interest in that we can realize a greater profit on a Riverbend Wrap Fee Program account with a
relatively low rate of portfolio turnover compared to other types of accounts, assuming the same level of
fees.
Account Requirements and Types of Clients - Item 5
We generally offer investment advisory services to individuals, pension and profit-sharing plans and participants,
trusts, estates, charitable organizations, corporations, and other business entities.
RWM requires a minimum of $500,000 to establish an advisory relationship. In our sole discretion, we may waive
this requirement. This requirement can be met by combining two or more accounts owned by you or related
family members.
Portfolio Manager Selection and Evaluation - Item 6
Portfolio Managers
RWM is the sponsor of the Riverbend Wrap Fee Program. The Associated Person assigned to the client
relationship will manage the client’s account(s) using internally developed or external asset allocation models.
External portfolio managers are usually selected from Fidelity’s Managed Account Xchange (FMAX) or Separate
Account Network (SAN). However, other managers can be selected should the firm determine the use of such
managers is in the client’s best interest. RWM will maintain the discretionary authority to select the portfolio
model or models for the client and the discretionary authority to move the account for one model to another. A
complete description of the services provided by external portfolio manager(s), the amount of fees charged for
the management of the account, the payment structure, termination provisions and other aspects of the
relationship, including information about any materials conflicts of interest, are detailed and disclosed in the
third-party investment adviser’s Form ADV or other applicable disclosure documents. A copy of all relevant
disclosure documents of the external portfolio manager(s) will be provided to the client at the time of selection
of the portfolio manager. Clients will also receive a Form ADV Part 2B for the RWM Associated Person assigned
to their account.
Factors that are considered when recommending managers include but are not limited to:
• Client’s preference to work directly with the Associated Person assigned to their account without the
involvement of external portfolio manager(s);
• Client’s refusal to pay the additional fee charged by external portfolio manager(s);
•
Sizable unrealized capital gains in a taxable account which makes liquidating accounts to allocate to a
model managed by external portfolio manager(s) unfeasible;
Small accounts that do not meet the account minimums of external portfolio managers;
•
• Retirement plan accounts like solo 401k’s or Simple IRAs that external portfolio manager(s) cannot
manage.
RWM conducts a periodic due diligence review of external portfolio managers. Due diligence will consists of any
or all of the following:
1. A review of the external portfolio manager's Form ADV or other disclosure documents;
2. Review of the performance of model portfolios managed by the external portfolio manager using our
firm’s internal standards;
3. Periodic meetings with the external portfolio manager’s personnel;
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 30
Significant changes in the external portfolio manager’s business;
4. Periodically reassessment of the firm’s relationship with the external portfolio manager in light of:
• Changes in the external portfolio manager’s investment strategy or portfolio managers;
•
• Dramatic changes in market conditions; or
• Any other event that is likely to have a significant effect on the external portfolio manager’s
operations.
Occasionally, a client may prefer to work with their Associated Person directly without the involvement of an
external portfolio manager. Where required, Associated Persons responsible for the management of the account
are registered as investment adviser representatives. Clients should refer to each Associated Person’s Form ADV
Part 2B Supplement, provided to you along with the copy of our disclosure brochure, for more information about
their disciplinary, business and educational backgrounds. Please contact us at (843) 970-1049 or at
roxanne@riverbendwm.com with any questions you may have.
Clients will receive statements directly from their account custodian(s) at least quarterly. RWM will also provide
performance reports upon request.
Other Advisory Services
Please refer to Item 4 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about other
advisory services offered by RWM.
Performance-Based Fees and Side-By-Side Management
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets.
Side-by-side management refers to the practice of managing accounts that are charged performance-based fees
while at the same time managing accounts that are not charged performance-based fees. We do not accept
performance-based fees or participate in side-by-side management. Our fees are calculated as described in the
Services section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation
of, the funds in your advisory account(s).
Investment Strategies
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about RWM’s
investment strategies.
Methods of Analysis
Please refer to Item 8 of the firm’s Form ADV Part 2A Disclosure Brochure above for information about the
methods of analysis used by RWM.
Risk of Loss
Clients should be aware that investing in securities involves a risk of loss that they should be prepared to bear.
Past performance is not indicative of future results. Therefore, you should never assume that future performance
of any specific investment or investment strategy will be profitable. Investing in securities (including stocks,
mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there
may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even
imply that our services and methods of analysis can or will predict future results, successfully identify market tops
or bottoms, or insulate you from losses due to market corrections or declines. Please refer to Item 8 of our Form
ADV Part 2A Brochure above for a detailed discussion of the various risks associated with investing in securities.
Proxy Voting
RWM does not vote proxies. It is the client's responsibility to vote proxies. Clients will receive proxy materials
directly from the custodian. Questions about proxies may be made via the contact information on the cover page
of this wrap fee brochure.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 31
Client Information Provided to Portfolio Managers - Item 7
RWM is the sole sponsor of the Riverbend Wrap Fee Program and together with its Associated Persons and
internal portfolio managers has access to and is responsible for maintaining all information provided by clients.
Client information will be updated in our firm’s records upon notification of changes provided by clients and
during client review meetings. If an external portfolio manager has been selected to manage the clients account,
such information is promptly communicated to the external portfolio manager, so that the necessary
adjustments, if any, can be made to your portfolio allocation. Alternatively, the Associated Person will be able to
implement a change in the client’s allocation directly with the external portfolio manager.
Client Contact with Portfolio Managers - Item 8
the Riverbend Wrap Fee Program. We can be
reached at
RWM is the sole sponsor of the Riverbend Wrap Fee Program and is the primary party responsible for client
interaction. Clients are free to contact RWM or their designated Associated Person at any time with questions
regarding
(843) 970-1049 or at
roxanne@riverbendwm.com. Client will receive a Form ADV Part 2 Brochure for all external managers selected
to manage all or a portion of the client’s portfolio and clients are able to contact and consult with the external
portfolio manager using the contact information provided on the cover page of the external portfolio manager’s
Form ADV Part 2 Brochure.
Additional Information - Item 9
Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of us or of the integrity of our management. Neither we nor our
management persons have a history of material legal or disciplinary events to report in this section.
Other Financial Industry Activities or Affiliations
Please refer to Item 10 of our Form ADV Part 2A Brochure above for more information about our other financial
industry activities and/or affiliations.
Description of Our Code of Ethics
Please refer to Item 11 of our Form ADV Part 2A Brochure above for more information about our Code of Ethics.
Interest in Client Transactions
Neither our firm nor any of our Associated Persons have any material financial or sales interest in client securities
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Please refer to Item 11 of our Form ADV Part 2A Brochure above for more information about our Personal Trading
Practices.
Account Reviews, Statements and Reports
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 32
Please refer to Item 13 of our Form ADV Part 2A Brochure above for more information about Account Reviews,
Statements and Reports.
Brokerage Practices
Please refer to Item 12 of our Form ADV Part 2A Brochure above for more information about our Brokerage
Practices.
Client Referrals and Other Compensation
Please refer to Item 12 and Item 14 of our Form ADV Part 2A Brochure above for more information about the
receipt of additional benefits from broker-dealers.
Please refer to Item 14 of our Form ADV Part 2A Brochure above for more information about compensation paid
by our firm and/or Associated Persons for client referrals.
Financial Information
We are required in this Item to provide you with certain financial information or disclosures about RWM’s,
financial condition. RWM does not require the prepayment of over $1,200, six or more months in advance.
Additionally, RWM has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients, and it has not been the subject of a bankruptcy proceeding.
Requirements for State-Registered Advisers - Item 10
This section is not applicable because our firm is SEC registered
Riverbend Wealth Management, LLC dba Riverbend Wealth Management, LLC Privacy Notice
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule regarding
the privacy of consumer financial information (“Regulation S-P”). Please take the time to read and understand
the privacy policies and procedures that we have implemented to safeguard your nonpublic personal information.
•
•
•
Information We Collect
Riverbend Wealth Management, LLC (RWM) must collect certain personally identifiable financial information
about its customers to provide financial services and products. The personally identifiable financial information
that we gather during the normal course of doing business with you may include:
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
Information We Disclose
We do not disclose any nonpublic personal information about our customers or former customers to anyone,
except as permitted or required by law, or as necessary to provide services to you. In accordance with Section
248.13 of Regulation S-P, we may disclose all of the information we collect, as described above, to certain
nonaffiliated third parties such as our attorneys, accountants, auditors, and persons or entities that are assessing
our compliance with industry standards. We enter into contractual agreements with all nonaffiliated third parties
that prohibit such third parties from disclosing or using the information other than to carry out the purposes for
which we disclose the information.
Riverbend Wealth Management, LLC
Form ADV Part 2A, Appendix 1 (Wrap brochure)
Page 33
Regulation S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we receive
from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has
been clearly, conspicuously, and concisely disclosed to the consumer; (2) the consumer has been provided a
reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the
consumer has not opted out. We do not receive information regarding marketing eligibility from affiliates to make
solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (ITPP) that
controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from identity theft.
We have developed an ITPP to adequately identify and detect potential red flags to prevent and mitigate identity
theft.
Confidentiality And Security
We restrict access to nonpublic personal information about you to those Employees who need to know that
information to provide financial products or services to you. We maintain physical, electronic, and procedural
safeguards that comply with federal standards to guard your nonpublic personal information.
Accuracy
RWM strives to maintain accurate personal information in our client files at all times. However, as personal
situations, facts, and data change over time; we encourage our clients to provide feedback and updated
information to help us meet our goals.
Closed Or Inactive Accounts
If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply
to you.
Changes To This Privacy Policy
If we make any substantial changes in the way we use or disseminate confidential information, we will notify you.
If you have any questions concerning this Privacy Policy, please contact us.