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RiversEdge Advisors, LLC
dba
RiversEdge Advisors
Form ADV Part 2A – Disclosure Brochure
Effective: September 2, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of
RiversEdge Advisors, LLC dba RiversEdge Advisors (“RiversEdge Advisors” or the “Advisor”). If you have any
questions about the content of this Disclosure Brochure, please contact the Advisor at (302) 573-6864.
RiversEdge Advisors is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information through RiversEdge Advisors to assist you in determining whether to retain the
Advisor.
Additional information about RiversEdge Advisors and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 298390.
RiversEdge Advisors, LLC dba RiversEdge Advisors
600 N King St, Suite 200
Wilmington, DE 19801
Phone: (302) 573-6864
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplements").
The Disclosure Brochure provides information about a variety of topics relating to an advisor’s business practices and
conflicts of interest. The Brochure Supplements provide information about Advisory Persons of RiversEdge Advisors.
RiversEdge Advisors believes that communication and transparency are the foundation of its relationship with Clients
and will continually strive to provide its Clients with complete and accurate information at all times. RiversEdge
Advisors encourages all current and prospective Clients to read this Disclosure Brochure and discuss any questions
you may have with us. And of course, we always welcome your feedback.
Material Changes
The material changes in this brochure from the last annual updating amendment of RiversEdge Advisors on 01/28/2025
are described below. Material changes relate to RiversEdge Advisors’ policies, practices or conflicts of interests.
• RiversEdge Advisors may recommend that Clients utilize one or more unaffiliated investment managers or
investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. RiversEdge Advisors will be compensated via a fee
share from the advisors to which it directs those clients. – Items 4, 5 and 10
• RiversEdge Advisors compensates employees for referrals – Item 14
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the
business practices of RiversEdge Advisors.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 298390. You
may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (302) 573-6864.
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Item 3 – Table of Contents
Item 1 – Cover Page……………………………………………………………………………………………………………1
Item 2 – Material Changes .............................................................................................................................................2
Item 3 – Table of Contents ............................................................................................................................................3
Item 4 – Advisory Services ...........................................................................................................................................4
A. Firm Information .................................................................................................................................................................... 4
B. Advisory Services Offered .................................................................................................................................................... 4
C. Client Account Management ................................................................................................................................................. 6
D. Wrap Fee Programs.............................................................................................................................................................. 6
E. Assets Under Management .................................................................................................................................................. 6
Item 5 – Fees and Compensation .................................................................................................................................6
A. Fees for Advisory Services ................................................................................................................................................... 6
B. Fee Billing ............................................................................................................................................................................. 8
C. Other Fees and Expenses .................................................................................................................................................... 8
D. Payment of Fees and Termination ........................................................................................................................................ 9
E. Compensation for Sales of Securities ................................................................................................................................... 9
Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................................... 10
Item 7 – Types of Clients ............................................................................................................................................ 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 10
A. Methods of Analysis ............................................................................................................................................................ 10
B. Risk of Loss ........................................................................................................................................................................ 10
Item 9 – Disciplinary Information .............................................................................................................................. 12
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................... 13
A. Code of Ethics .................................................................................................................................................................... 13
B. Personal Trading with Material Interest ............................................................................................................................... 13
C. Personal Trading in Same Securities as Clients ................................................................................................................. 13
D. Personal Trading at Same Time as Client........................................................................................................................... 13
Item 12 – Brokerage Practices ................................................................................................................................... 13
A. Recommendation of Custodian[s] ....................................................................................................................................... 13
B. Aggregating and Allocating Trades ..................................................................................................................................... 14
Item 13 – Review of Accounts ................................................................................................................................... 14
A. Frequency of Reviews ........................................................................................................................................................ 14
B. Causes for Reviews ............................................................................................................................................................ 14
C. Review Reports .................................................................................................................................................................. 14
Item 14 – Client Referrals and Other Compensation ............................................................................................... 15
A. Compensation Received by RiversEdge Advisors .............................................................................................................. 15
B. Client Referrals from Solicitors ........................................................................................................................................... 16
Item 15 – Custody ....................................................................................................................................................... 16
Item 16 – Investment Discretion ................................................................................................................................ 16
Item 17 – Voting Client Securities ............................................................................................................................. 16
Item 18 – Financial Information ................................................................................................................................. 16
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Item 4 – Advisory Services
A. Firm Information
RiversEdge Advisors, LLC dba RiversEdge Advisors (“RiversEdge Advisors” or the “Advisor”) is a registered
investment advisor with the U.S. Securities and Exchange Commission (“SEC”). RiversEdge Advisors is organized
as a limited liability company under the laws of the State of Delaware. RiversEdge Advisors was founded in August
2018 and is owned and operated by Brian J. Carney, Jarrett F. Morris and Timothy J. Mihok. This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services provided
by RiversEdge Advisors. For questions regarding this Disclosure Brochure, please contact Jarrett Morris at (302)
573-6864.
B. Advisory Services Offered
RiversEdge Advisors offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses retirement plans and insurance companies (each referred to as a “Client”). RiversEdge Advisors
provides a comprehensive approach to its wealth advisory services. Services are tailored to the unique needs of
each Client.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. RiversEdge Advisors’ fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Investment Management Services
RiversEdge Advisors provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services. RiversEdge Advisors works closely with each Client to identify their
investment goals and objectives as well as risk tolerance and financial situation in order to create an investment
strategy. The Advisor may retain legacy investments based on portfolio fit and/or tax considerations.
The Advisor’s investment philosophy is based primarily on modern portfolio theory. The Advisor will develop a
strategic asset allocation for the Client based on the Client’s unique situation. The Advisor will then construct an
investment portfolio primarily utilizing exchange-traded funds (“ETFs”). The Advisor may also incorporate open-end
mutual funds, individual equity securities and/or individual fixed income securities in a Client’s portfolio. For mutual
funds, the Advisor primarily selects passive managers and will seek institutional share classes when available.
RiversEdge Advisors will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific
custodial and/or mutual fund company constraints, material tax consideration, and/or systematic investment plans,
RiversEdge Advisors will select, recommend and/or retain a mutual fund share class that does not have trading
costs, but do have higher internal expense ratios than institutional share classes. RiversEdge Advisors will seek to
select the lowest cost share class available that is in the best interest of each Client and will ensure the selection
aligns with the Client’s financial objectives and stated investment guidelines.
RiversEdge Advisors typically employs a long-term investment approach for Clients, but may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. RiversEdge Advisors will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by
the Advisor.
RiversEdge Advisors may also provide ongoing advice on assets held away at custodians with which RiversEdge
Advisors does not have a relationship. This includes direct management of 401ks, 403bs, 529 plans, and other
assets where RiversEdge Advisors has discretion and may leverage an Order Management System to implement
allocation or rebalancing strategies on behalf of the client. The client securely logs into the order management
system and allows RiversEdge Advisors to manage accounts without taking custody of assets. RiversEdge
Advisors regularly reviews the current holdings and available investment options in these accounts, monitors the
accounts, rebalances and implements RiversEdge Advisors’ strategies as necessary. In limited circumstances,
RiversEdge Advisors provides ongoing advice for non-discretionary, held-away accounts.
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Use of Independent Managers – RiversEdge Advisors may recommend that Clients utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to
authorize and enter into an agreement with the Independent Manager[s] that defines the terms in which the
Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due
diligence over each Independent Manager to ensure the strategy remains aligned with the Client’s investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with
an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure
(or a brochure that makes the appropriate disclosures).
Financial Planning Services
RiversEdge Advisors will typically provide to its Clients a variety of financial planning services. Financial planning
services may be included in an overall wealth management engagement or provided as a separate service,
pursuant to the terms of the agreement with the Client. Services may be provided in several areas of a Client’s
financial situation, depending on their goals and objectives. Planning may encompass one or more areas of need,
including, but not limited to investment planning, retirement planning, distributions, personal savings, education
savings, spending, insurance needs, estate planning, charitable strategies, and other areas of a Client’s financial
situation. RiversEdge Advisors may deliver specific planning modules to the Client or a comprehensive plan,
based on the needs of the Client.
In certain circumstances, RiversEdge Advisors may also refer Clients to an accountant, attorney or other specialist,
as appropriate for the Client’s unique situation. For certain financial planning engagements, the Advisor will
generally provide a written report that contains observations and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, a recommendation to engage the Advisor for investment management services or to increase
the level of investment assets with the Advisor would pose a conflict, as it would increase the amount of advisory
fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or
maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made
by the Advisor, the Client is under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
RiversEdge Advisors provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan and Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Oversight Services (ERISA 3(21))
Investment Management Services (ERISA 3(38))
• Vendor Analysis
• Plan Participant Enrollment and Education
•
•
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
RiversEdge Advisors may provide investment advisory services on behalf of the Plan and Plan Sponsor, which
may be in either a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary
investment management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select
the investments for the Plan and/or make investment decisions on behalf of Plan Participants.
These services are provided by RiversEdge Advisors serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the
Plan Sponsor is provided with a written description of RiversEdge Advisors’ fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
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UPTIQ Platform
The UPTIQ platform allows advisors to offer lending and cash management solutions that integrate with Orion’s
advisor and client portals. UPTIQ includes access to a range of securities-backed and insurance premium finance
lines of credit, commercial and business loans, and mortgages, as well as FDIC-insured deposit programs.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual retirement account,
we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates
some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest
and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Account Management
Prior to engaging RiversEdge Advisors to provide advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – RiversEdge Advisors will work with each Client to develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – RiversEdge Advisors will develop a strategic asset allocation that is targeted to meet
the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – RiversEdge Advisors will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
•
Investment Management and Supervision – RiversEdge Advisors will provide investment management
and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
RiversEdge Advisors does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2024, RiversEdge Advisors manages $708,414,018 in Client assets, $703,268,393 of which are
managed on a discretionary basis and $5,145,625 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor.
Each Client shall sign one or more agreements that detail the responsibilities of RiversEdge Advisors and the Client.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, at the end of each calendar quarter, pursuant to
the terms of the investment advisory agreement. Quarterly fees are calculated based on the daily average balance.
Our advisory fee is tailored to each client based on the services provided and relevant factors, typically as a
percentage of assets under management and/or advisement. The fee can range up to 2.50% per annum and applies
to all discretionary and non-discretionary assets under management and advisement, unless agreed otherwise with
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the client. Clients who receive financial planning and consulting services from us in addition to investment advisory
services may be subject to an extra fee, which may be added to the advisory fee or billed separately. For consulting
and reporting services, the structure and level of fees are determined based on the services provided and other
relevant factors. We may also agree to 'household' client accounts for fee calculation based on the client relationship
and services provided. All fee arrangements are negotiable, and the client's agreement outlines the applicable fees.
The investment advisory fee in the first month of service is prorated from the inception date of the Client’s account[s]
to the end of the first calendar quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees
will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by RiversEdge Advisors will be independently valued by the Custodian. RiversEdge Advisors will not have
the authority or responsibility to value portfolio securities.
Clients may make additions to and withdrawals from their account[s] at any time, subject to RiversEdge Advisors’ right
to terminate an account. Additions may be in cash or securities provided that RiversEdge Advisors reserves the right to
liquidate any transferred securities or decline to accept particular securities into a Client’s account[s]. Clients may
withdraw account assets on notice to RiversEdge Advisors, subject to the usual and customary securities settlement
procedures. However, RiversEdge Advisors designs its portfolios as long-term investments and the withdrawal of
assets may impair the achievement of a Client’s investment objectives. RiversEdge Advisors may consult with its
Clients about the options and ramifications of transferring securities. However, Clients are advised that when transferred
securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent
deferred sales charge) and/or tax ramifications.
The advisory fee explained above includes RiversEdge Advisors’ held-away account services through the Pontera online
platform for direct management of 401ks, 403bs, 529 plans, and other assets for which RiversEdge Advisors does not
have custody and are held at custodians other than Schwab. Client investment management fees for such held-away
accounts will be deducted from an account under RiversEdge Advisors’ management held at Schwab. Fees are based
on the assets within these accounts according to the valuation of the accounts at the close of the quarter as valued by
the account custodian. RiversEdge Advisors strongly encourages Client to confirm the market values for accuracy
against Client’s custodian statements.
Clients have the option to have fees billed directly to their checking or savings accounts. RiversEdge utilizes Bluepay
and/or Quickbooks to bill clients.
Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment
portfolio utilizing one or more Independent Managers. RiversEdge Advisors will be compensated via a fee share from the
advisors to which it directs those clients. This relationship will be disclosed in each contract between RiversEdge
Advisors and each Independent Manager. The fees shared will not exceed any limit imposed by any regulatory agency.
This creates a conflict of interest in that the Advisor has an incentive to direct clients to the Independent Managers that
provide the Advisor with a larger fee split. RiversEdge Advisors will always act in the best interests of the client, including
when determining which Independent Manager to recommend to clients. Independent Managers typically do not offer
any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed
under management with an Independent Manager. The Advisor will allocate a portion of the advisory fee collected to the
Independent Manager pursuant to the terms of the executed agreement between the Advisor and the Independent
Manager. If the Client is required to authorize and enter into an agreement with an Independent Manager then the terms
of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with
the Independent Manager.
Financial Planning Services
Financial planning and consulting fees of the Firm are typically charged on fixed fee basis, hourly rate basis, or as a
percentage per annum for services provided at any asset level, depending on the level and scope of services
required and the professional providing them. Asset-based fees can range up to 0.25%. Fixed fees can range up to
$20,000. Hourly fees can range up to $1,000 per hour. All fee arrangements are open to negotiation.
Combined Services
RiversEdge Advisors will generally charge fees for combined services based on the terms outlined under Investment
Management Services above.
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Retirement Plan Advisory Services
3(21) Advisory Services
Fees for retirement plan advisory services are charged a fixed fee or asset-based fee of up to 2.50% per annum and
are billed quarterly, at the end of each calendar quarter, based on the fair market value of Plan assets supervised by
the Advisor at the end of the quarter. The fees in the first quarter of the Agreement shall be prorated from the
inception date to the end of the first calendar quarter.
3(38) Advisory Services
Fees for retirement plan advisory services are charged an annual fixed or asset-based fee of up to 2.50% per
annum. The specific billing method for these fees varies and therefore will be outlined in the Agreement. These
fees are billed either monthly or quarterly, at the end of each period and may be based on the period-end balance
or an average balance. The fees in the first billing period of the Agreement shall be prorated from the inception
date to the end of the first billing period.
All retirement plan advisory fees may be negotiable depending on the size and complexity of the Plan.
Orion Cash & Credit Program
Fees under the Orion Cash & Credit Program will vary depending on the financial product selected. The Advisor
receives annual payments from Orion equal to 25% of the eligible revenue earned and received by Orion with respect
to RiversEdge’s clients utilizing the program. This creates a conflict of interest because the Advisor has an incentive to
recommend products through this program. The Advisor will not recommend financial products under this program
unless it is in the client’s best interest.
B. Fee Billing
Investment Management Services
Clients provide written authorization permitting advisory fees to be deducted by RiversEdge Advisors to be paid
directly from their accounts held by the Custodian as part of the investment advisory agreement and separate
account forms provided by the Custodian. Fees are calculated based on the daily average balance of the assets under
management in the account[s] and is calculated at the end of each calendar quarter.
Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s overall
fees may include the Advisor’s investment advisory fee (as noted above) plus investment advisory fees and/or platform
fees charged by the Independent Manager[s], as applicable. The Independent Manager will assume responsibility for
calculating the Client’s fees and deduct all fees from the Client’s account[s].
Financial Planning Services
Fees for financial planning may be paid via check, credit card/ACH or deducted from the advisory account. Client
will select payment method within the agreement. Fees are due upon completion of services.
Combined Services
RiversEdge Advisors will generally charge fees for combined services based on the terms outlined under Investment
Management Services above.
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than RiversEdge Advisors, in connection
with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for
certain mutual funds and other types of investments. The fees charged by RiversEdge Advisors are separate and
distinct from these custody and execution fees.
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In addition, all fees paid to RiversEdge Advisors for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the
funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. The Client should review both the fees charged by the fund[s] and the fees charged by RiversEdge
Advisors to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional
information. Additionally, as noted above, the Advisor will select share classes which do not have trading costs, but do
have higher internal expense ratios than institutional share classes. Please refer to Item 12 – Brokerage Practices for
additional information.
D. Payment of Fees and Termination
Investment Management Services
RiversEdge Advisors is compensated for its investment advisory services at the end of the quarter in which
investment advisory services are rendered.
Use of Independent Managers – In the event that the Advisor has determined that an Independent Manager is no
longer in the Client’s best interest or a Client should wish to terminate their relationship with the Independent
Manager, the terms for the termination will be set forth in the respective agreements between the Client or the
Advisor and the Independent Manager. RiversEdge Advisors will assist the Client with the termination and
transition as appropriate.
Financial Planning Services
RiversEdge Advisors is compensated for financial planning services upon completion of services.
Combined Services
RiversEdge Advisors is compensated for its combined services at the end of the quarter in which services are
rendered.
Retirement Plan Advisory Services
RiversEdge Advisors is compensated for its retirement plan advisory services at the end of the billing period, after
advisory services are rendered.
Either party may terminate the investment advisory, financial planning or retirement plan agreement, at any time, by
providing advance written notice to the other party. Upon termination, the Client shall be responsible for investment
advisory fees up to and including the effective date of termination.
E. Compensation for Sales of Securities
RiversEdge Advisors does not buy or sell securities to generate commissions and does not receive a portion of the
fees paid by Clients for securities transactions.
Jarrett Morris is also a registered representative of Purshe Kaplan Sterling Investments, Inc. ("PKS"), a securities
broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor
Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative of PKS, Mr. Morris will
implement securities transactions under PKS and not through RiversEdge Advisors. In such instances, Mr. Morris
will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1
fees for the sale of investment company products. Compensation earned by Mr. Morris in his capacity as a registered
representative is separate from and in addition to RiversEdge Advisors’ advisory fees. This practice presents a
conflict of interest because Mr. Morris is a registered representative has an inventive to effect securities transactions
for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to
implement any recommendation provided by Mr. Morris. Neither the Advisor nor Mr. Morris will earn ongoing
investment advisory fees in connection with any products or services implemented in Mr. Morris’s separate capacity as
a registered representative. Please see Item 10 - Other Financial Industry Activities and Affiliations.
Certain Advisory Persons are also licensed as independent insurance professionals. These persons will earn
commission-based compensation for selling insurance products, including insurance products they sell to Clients.
Insurance commissions earned by Advisory Persons are separate and in addition to advisory fees. This practice
presents a conflict of interest because persons providing investment advice on behalf of the Advisor, who are
insurance agents have an incentive to recommend insurance products to Clients for the purpose of generating
commissions rather than solely based on the Client’s needs. However, Clients are under no obligation, contractually
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or otherwise, to purchase insurance products through any person affiliated with the Advisor. Please see Item 10 –
Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
RiversEdge Advisors does not charge performance-based fees for its investment advisory services. The fees
charged by RiversEdge Advisors are as described in Item 5 above and are not based upon the capital
appreciation of the funds or securities held by any Client.
RiversEdge Advisors does not manage any proprietary investment funds or limited partnerships (for example, a
mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its
Clients.
Item 7 – Types of Clients
RiversEdge Advisors offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, and retirement plans.
RiversEdge Advisors generally does not impose a minimum size for establishing a relationship. However, certain
investments and strategies may require certain minimums for effective implementation.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
RiversEdge Advisors primarily employs a fundamental analysis method in developing investment strategies for its
Clients. Research and analysis from RiversEdge Advisors are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are
generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, RiversEdge Advisors generally employs a long-term investment strategy for its Clients, as
consistent with their financial goals. RiversEdge Advisors will typically hold all or a portion of a security for more
than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of
Clients. At times, RiversEdge Advisors may also buy and sell positions that are more short-term in nature,
depending on the goals of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. RiversEdge Advisors will assist Clients in determining an
appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no
guarantee that a Client will meet their investment goals.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Below are some of the risks associated with the Advisor’s investment approach:
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Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Risks
Options are contracts to purchase a security at a given price, risking that an option may expire out of the money
resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an
offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas
the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple
options on the same underlying security, but with different strike prices or expiration dates, which helps limit the
risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk,
market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate
risk.
Cryptocurrency ETF Risks
For certain clients, the Advisor will recommend ETFs that track the price performance of one or more
cryptocurrencies by investing in a portfolio linked to their instruments. Crypto ETFs can track the value of
cryptocurrencies by investing in futures contracts for digital currency, or by investing in digital currencies directly.
Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not backed by real
assets or tangible securities and are more volatile than traditional currencies and financial assets. In general,
investing in instruments the value of which are derived from or based on crypto assets, is highly speculative and
subject to numerous risks.
A cryptocurrency is a peer-to-peer, decentralized, cryptocurrency, the implementation of which relies on the
principles of cryptography to validate the transactions and generation of the currency itself. A network (or utility)
token relies on a network protocol with similar principles to a cryptocurrency, but also purports to serve functions
other than the storage of value. The creation and use of cryptocurrency is not currently subject to a fully developed
set of legal or regulatory requirements, and trading in crypto assets is subject to high levels of volatility and the
potential for market abuse. Risks associated with Crypto ETFs include but are not limited to; the cost to own these
ETFs may be more than owning the actual crypto (but may eliminate the risk of investors being hacked or losing
passwords or private keys needed to access their investment when it is stored in a secure bitcoin wallet), the risk
of the individual ETF fund company failure, (which would require liquidation of the fund and the costs associated
with the failure of the company), risk of underlying assets being blocked by regulatory authorities, reinvestment
risk, high transaction costs and limited historical data. Additionally, Crypto ETFs may have no earnings, dividends,
or interest payments generated by underlying holdings. Operational and management costs may decrease the
value of the ETF as a whole. Expense ratios should be considered and understood as presented in the ETF
Prospectus.
Due to the above risk factors along with other risk factors, we assess that the value at risk at any given time is
always 100% downside, therefore, we must limit total exposure along with carefully considering the risks and
needs of each individual investor.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
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Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving RiversEdge Advisors or its management
persons RiversEdge Advisors values the trust Clients place in the Advisor. The Advisor encourage Clients to
perform the requisite due diligence on any advisor or service provider with whom the Client engages. The
backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s name or CRD# 298390.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5, Mr. Morris is also a registered representative of PKS. In Mr. Morris’s separate capacity as a
registered representative, Mr. Morris will receive commissions for the implementation of recommendations for
commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Morris
of RiversEdge Advisors. Neither RiversEdge Advisors nor Mr. Morris will earn ongoing investment advisory fees in
connection with any services implemented in the Mr. Morris’s separate capacity as a registered representative.
Under supervision by PKS, PKS may have access to certain confidential information of the Client, including, but not
limited to financial information, investment objectives, transactions and holdings information.
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons of RiversEdge Advisors will serve as licensed insurance
professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s
role with RiversEdge Advisors. As insurance professionals, Advisory Persons will receive customary commissions
and other related revenues from the various insurance companies whose products are sold. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending insurance products. Clients are under no obligation to implement any recommendations made the
Advisor or by its Advisory Persons.
RiversEdge Tax & Advisory
RiversEdge Advisors is affiliated with RiversEdge Business Services LLC, dba RiversEdge Tax & Advisory, through
common control and ownership. If Clients require tax and accounting services, RiversEdge Advisors will
recommend that Clients use the services of the affiliate. RiversEdge Advisor’s advisory services are separate and
distinct from the compensation paid to RiversEdge Tax & Advisory for its services. This affiliated firm is otherwise
regulated by the professional organizations to which it belongs and must comply with the rules of those
organizations.
This arrangement with an affiliated entity presents a conflict of interest because RiversEdge Advisors has a
direct or indirect financial incentive to recommend an affiliated firm's services. While RiversEdge Advisors believes
that compensation charged by the affiliated firm is competitive, such compensation may be higher than fees
charged by other firms providing the same or similar services. Clients are under no obligation to use the services of
any firm RiversEdge Advisors recommends, whether affiliated or otherwise, and may obtain comparable services
and/or lower fees through other firms.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. RiversEdge Advisors will be compensated via a fee share from the advisors to which it
directs those clients. This relationship will be disclosed in each contract between RiversEdge Advisors and each
Independent Manager. The fees shared will not exceed any limit imposed by any regulatory agency. This creates a
conflict of interest in that the Advisor has an incentive to direct clients to the Independent Managers that provide the
Advisor with a larger fee split. RiversEdge Advisors will always act in the best interests of the client, including when
determining which Independent Manager to recommend to clients. The Advisor will ensure that all recommended
advisors or managers are licensed or notice filed in the states in which the Advisor is recommending them to
clients.
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Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
A. Code of Ethics
RiversEdge Advisors has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary
commitment to each Client. This Code applies to all persons associated with RiversEdge Advisors (“Supervised
Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the
Advisor’s duties to the Client. RiversEdge Advisors and its Supervised Persons owe a duty of loyalty, fairness and
good faith towards each Client. It is the obligation of RiversEdge Advisors associates to adhere not only to the
specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of
topics that address ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at
(302) 573-6864.
B. Personal Trading with Material Interest
RiversEdge Advisors allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. RiversEdge Advisors does not act as principal in any
transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment
company. RiversEdge Advisors does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
RiversEdge Advisors allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. Owning the same securities that are recommended
(purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and
mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider
trading (material non-public information controls) and personal securities reporting procedures. When trading for
personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary
duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous
terms than Client trades, or by trading based on material non-public information. This risk is mitigated by
RiversEdge Advisors requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While RiversEdge Advisors allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or
traded afterward. At no time will any associated person of RiversEdge Advisors, transact in any security to the
detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
RiversEdge Advisors does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client
assets and authorize RiversEdge Advisors to direct trades to the Custodian as agreed upon in the investment
advisory agreement. Further, RiversEdge Advisors does not have the discretionary authority to negotiate
commissions on behalf of Clients on a trade-by-trade basis.
Where RiversEdge Advisors does not exercise discretion over the selection of the Custodian, it may recommend
the Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not
recommended by RiversEdge Advisors. As its Advisory Persons are also registered representatives of PKS,
RiversEdge Advisors and its Advisory Persons are limited in the Custodians in which they can recommend to
Clients.
RiversEdge Advisors will generally recommend that Clients establish their account[s] at SEI or Charles Schwab &
Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s
“qualified custodian”. Schwab may enable the Advisor to obtain many mutual funds without transaction charges
and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab
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may be higher or lower than those charged by other financial institutions. The Advisor maintains an institutional
relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see Item 14
below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research and
other services. RiversEdge Advisors does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian, but does receive economic benefits from Schwab. Please see Item 14 below.
2. Brokerage Referrals - RiversEdge Advisors does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where RiversEdge Advisors will
place trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions
(i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts
(i.e., purchase of a security into one Client account from another Client’s account[s]). RiversEdge Advisors will not
be obligated to select competitive bids on securities transactions and does not have an obligation to seek the
lowest available transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required. RiversEdge Advisors will execute its transactions through the Custodian,
unless otherwise instructed in writing by the Client.
RiversEdge Advisors may aggregate orders in a block trade or trades when securities are purchased or sold
through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business
day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This
must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Principals of the Advisor and
periodically by the CCO. The CCO also has oversight of investment advisory processes. Formal reviews are
generally conducted at least annually or more or less frequently depending on the needs of the Client. Clients are
offered an annual financial plan, subject to scope of their agreement with the Advisor.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may be reviewed as
a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify RiversEdge Advisors if
changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan.
Additional reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
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Item 14 – Client Referrals and Other Compensation
A. Compensation Received by RiversEdge Advisors
RiversEdge Advisors does not receive securities commissions from product sponsors, broker-dealers or any un-
related third party. RiversEdge Advisors may refer Clients to various third parties to provide certain financial
services necessary to meet the goals of its Clients. Likewise, RiversEdge Advisors may receive referrals of new
Clients from a third-party.
Participation in Institutional Advisor Platform
RiversEdge Advisors has established an institutional relationship with Schwab through its “Schwab Advisor
Services” unit, a division of Schwab dedicated to serving independent advisory firms like RiversEdge Advisors. As
a registered investment advisor participating on the Schwab Advisor Services platform, RiversEdge Advisors
receives access to software and related support without cost because the Advisor renders investment management
services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the
Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients,
the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the
receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may
influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems
support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
RiversEdge Advisors that may not benefit the Client, including: educational conferences and events, financial start-
up support, consulting services and discounts for various service providers. Access to these services creates a
financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest.
RiversEdge Advisors believes, however, that the selection of Schwab as Custodian is in the best interests of its
Clients.
With regard to SEI, RiversEdge has access to a variety of economic benefits, services, and products in connection
with RiversEdge’s use of SEI’s investment adviser platform. The terms and availability of these benefits vary
among advisors on the SEI platform (including RiversEdge) depending on the business conducted with SEI and
other factors. These services generally help RiversEdge conduct its advisory business, but each specific benefit
does not necessarily benefit each client.
Beyond access to SEI investment products, these include conferences, seminars and other educational and
networking activities, business entertainment, reimbursement of travel and attendance expenses, research and
other investment support services (such as client proposal and other financial planning support), technical and
operational solutions (including the SEI Wealth Platform), marketing assistance (including joint marketing designed
to promote SEI’ investment products), compliance services, human resources consulting, risk
management/insurance assistance, front office, middle office, back office and other administrative support
(including providing clerical staff to assist in the completion of required paperwork), SEI attendance at client
meetings, information technology services, continuity and succession planning, access to financing and banking
options, trust services, portfolio reporting, automatic rebalancing, tax loss harvesting, waiver or payment of certain
fees (including paying account transfer fees or other charges that RiversEdge or its clients would incur when
changing service providers), vendor discounts, discount pricing on SEI services, and broader practice
management consulting. These benefits may be provided via SEI, its affiliates, or third parties and may be made
available to RiversEdge at no fee, at a discounted fee, or via financial compensation provided by SEI. Some of
these offerings depend on RiversEdge conducting a minimum amount or type of current or expected future
Page 15
business with SEI, or having a minimum account size or amount of assets under management with SEI or invested
in SEI investment products. Certain of these services or products, including those provided by or paid for by SEI,
may be used by RiversEdge in connection with its general business activities, in addition to supporting
RiversEdge’s interaction with SEI systems. The benefits, services, products, or payments discussed herein may be
significant to RiversEdge and create an incentive for the RiversEdge to utilize SEI services or investment products
for its customers rather than other service providers or investment products. However, RiversEdge strives at all
times to put the interests of its clients first, including when selecting custodians or investment products for clients.
RiversEdge is independently owned and operated; it is not affiliated with SEI.
B. Client Referrals from Solicitors
The Advisor compensates employees for client referrals.
Item 15 – Custody
RiversEdge Advisors does not accept or maintain custody of any Client accounts, except for the authorized
deduction of the Advisor’s fee. All Clients must place their assets with a “qualified custodian”. Clients are required
to engage the Custodian to retain their funds and securities and direct RiversEdge Advisors to utilize the
Custodian for the Client’s security transactions. RiversEdge Advisors encourages Clients to review statements
provided by the Custodian. For more information about custodians and brokerage practices, see Item 12 below.
Item 16 – Investment Discretion
RiversEdge Advisors generally has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may
be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by RiversEdge Advisors. Discretionary authority will only be authorized upon full disclosure to the Client. The granting
of such authority will be evidenced by the Client's execution of an Investment Advisory Agreement containing all
applicable limitations to such authority. All discretionary trades made by RiversEdge Advisors will be in accordance
with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
RiversEdge Advisors does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither RiversEdge Advisors, nor its management, have any adverse financial situations that would reasonably
impair the ability of RiversEdge Advisors to meet all obligations to its Clients. Neither RiversEdge Advisors, nor
any of its advisory persons, has been subject to a bankruptcy or financial compromise. RiversEdge Advisors is not
required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of
$1,200 or more for services to be performed six months or more in advance.
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Form ADV Part 2B – Brochure Supplement
for
Brian J. Carney, CFP®, ChFC®, AIF®, CDFA™
Partner & Founder
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Brian
J. Carney (CRD# 4447761) in addition to the information contained in the RiversEdge Advisors, LLC dba RiversEdge
Advisors (“RiversEdge Advisors” or the “Advisor”, CRD# 298390) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the RiversEdge Advisors
Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (302) 573-6864.
Additional information about Mr. Carney is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4447761.
Page 17
Item 2 – Educational Background and Business Experience
Brian J. Carney, born in 1979, is dedicated to advising Clients of RiversEdge Advisors as Partner & Founder.
Mr. Carney earned a Bachelor of Science from Ursinus College in 2001. Additional information regarding Mr.
Carney’s employment history is included below.
Employment History:
12/2024 to Present
08/2024 to Present
02/2024 to 12/2024
09/2018 to 02/2024
09/2018 to 11/2019
01/2014 to 09/2018
01/2014 to 09/2018
10/2010 to 12/2013
04/2009 to 12/2013
10/2001 to 02/2009
Partner & Founder, RiversEdge Advisors, LLC
Partner, RiversEdge Tax & Advisory
Chief Executive Officer, RiversEdge Advisors, LLC
Partner, RiversEdge Advisors, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Investment Advisor Representative,
Cambridge Investment Research Advisors, Inc.
Registered Representative, Cambridge Investment Research, Inc.
Investment Advisor Representative, Newton One Advisors LLC
Registered Representative, M Holdings Securities, Inc.
Financial Advisor, Securian Financial Services, Inc.
dba Diamond State Financial Group
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have
obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Page 18
Chartered Financial Consultant® (“ChFC®”)
The Chartered Financial Consultant® (ChFC®) program prepares you to meet the advanced financial planning
needs of individuals, professionals and small business owners. You'll gain a sustainable advantage in this
competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income
taxation, retirement planning, investments and estate planning. The ChFC® requires three years of full-time,
relevant business experience, nine two-hour course specific proctored exams, and 30 hours of continuing
education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of
Ethics.
Program Objectives:
• Function as an ethical, competent and articulate practitioner in the field of financial planning
• Utilize the intellectual tools and framework needed to maintain relevant and current financial planning
knowledge and strategies.
• Apply financial planning theory and techniques through the development of case studies and solutions.
• Apply in-depth knowledge in a holistic manner from a variety of disciplines; namely, estate planning,
retirement planning or non-qualified deferred compensation.
Accredited Investment Fiduciary (“AIF®”)
The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company.
The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive
investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an
initial training program, annual continuing education, and pledge to abide by the designation's code of ethics.
Since October 2002, the Accredited Investment Fiduciary® (AIF®) designation has been the mark of commitment to
a standard of investment fiduciary excellence. Those who earn the AIF® mark successfully complete a specialized
program on investment fiduciary standards of care and subsequently passed a comprehensive examination. AIF®
designees demonstrate a thorough understanding of fi360's Prudent Practices for investment advisors and
stewards.
Certified Divorce Financial Analyst (“CDFA™”)
The Certified Divorce Financial Analyst™, (CDFA™) is a professional certification granted in the United States and
Canada by the Institute for Divorce Financial Analysts™ (IDFA™). To attain the right to use the CDFA™ (Certified
Divorce Financial Analyst™) certification, an individual must satisfactorily fulfill the following requirements:
• Education – Professionals must develop their theoretical understanding and knowledge of the financial
aspects of divorce by completing a comprehensive course of study approved by the IDFA™;
• Examination – Practitioners must pass a four-part (in the USA) or three-part (in Canada) Certification
Examination that tests their understanding and knowledge of the financial aspects of divorce. In addition,
the practitioner must demonstrate the practical application of this knowledge in the divorce process;
• Experience – Individuals must have a minimum of three years’ experience in a financial or legal capacity
prior to earning the right to use the CDFA™ certification mark; and
• Ethics – Practitioners agree to abide by a strict code of professional conduct known as the “Code of Ethics
and Professional Responsibility,” which sets forth their ethical responsibilities to the public, clients,
employers and other professionals. The IDFA™ may perform a background check during this process, and
each candidate for CDFA™ certification must disclose any investigations or legal proceedings relating to
his or her professional or business conduct.
Individuals who become certified must complete the following ongoing education requirements in order to maintain
the right to continue to use the CDFA™ designation:
• Continuing Education – Complete a minimum of fifteen (15) hours of continuing education every two years,
that are specifically related to the field of divorce, and
• Ethics – Practitioners must voluntarily disclose any public, civil, criminal, or disciplinary actions that may
have been taken against them during the past two years as part of the renewal process. If a complaint has
been brought against a CDFA™ by another professional or member of the general public, the CDFA™
must be examined and cleared by IDFA’s Ethics Committee to maintain their designation.
Page 19
Certified Exit Planning Advisor (CEPA)
The Certified Exit Planning Advisor (CEPA) credential is for professional advisors who want to effectively engage
more business owners. Candidates must meet all the following requirements:
• have five years of full-time or equivalent experience working directly with business owners as a financial
advisor, attorney, CPA, business broker, investment banker, commercial lender, estate planner, insurance
professional, business consultant or in a related capacity;
• have an undergraduate degree from a qualifying institution or additional professional work experience (two
years of relevant professional experience may be substituted for each year of required undergraduate
studies); and
• be an Exit Planning Institute member in good standing.
There is a five-day educational program and an online, proctored closed book final exam. The continuing education
requirements are 40 hours every three years.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances in the past 10 years where the Advisor or its Advisory
Persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities
and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property;
bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. There no disclosures to
make for this Item. However, the Advisor encourages Clients to independently view the background of Mr. Carney
on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or
his Individual CRD# 4447761.
Item 4 – Other Business Activities
Mr. Carney is a partner of RiversEdge Business Services LLC, dba RiversEdge Tax & Advisory, an affiliated tax and
accounting firm. From time to time, he may offer clients advice or products from this activity and clients should be
aware that these services involve a conflict of interest. RiversEdge Advisors always acts in the best interest of the
client and clients always have the right to decide whether or not to utilize the services of any representative of
RiversEdge Advisors in such individual’s outside capacities.
Insurance Agency Affiliations
Mr. Carney is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart Mr. Carney’s role with RiversEdge Advisors. As an insurance professional, Mr. Carney will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Carney is not required to offer the products of any particular insurance company. Commissions generated
by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Carney or the Advisor.
Item 5 – Additional Compensation
Mr. Carney has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Carney serves as a Partner & Founder of RiversEdge Advisors and is supervised by Jarrett Morris, the Chief
Compliance Officer. Mr. Morris can be reached at (302) 573-6864.
RiversEdge Advisors has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of RiversEdge Advisors. Further, RiversEdge
Advisors is subject to regulatory oversight by various agencies. These agencies require registration by
RiversEdge Advisors and its Supervised Persons. As a registered entity, RiversEdge Advisors is subject to
examinations by regulators, which may be announced or unannounced. RiversEdge Advisors is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
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Form ADV Part 2B – Brochure Supplement
for
Jarrett F. Morris
Partner, Founder and Chief Compliance Officer
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Jarrett
F. Morris (CRD# 5146654) in addition to the information contained in the RiversEdge Advisors, LLC dba RiversEdge
Advisors (“RiversEdge Advisors” or the “Advisor”, CRD# 298390) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the RiversEdge Advisors
Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (302) 573-6864.
Additional information about Mr. Morris is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5146654.
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Item 2 – Educational Background and Business Experience
Jarrett F. Morris, born in 1983, is dedicated to advising Clients of RiversEdge Advisors as a Partner, Founder and
the Chief Compliance Officer. Mr. Morris earned a B.S. in Finance from University of Delaware in 2005. Additional
information regarding Mr. Morris’ employment history is included below.
Employment History:
12/2024 to Present
08/2024 to Present
02/2024 to 12/2024
09/2018 to 02/2024
09/2018 to Present
12/2012 to 09/2018
12/2012 to 09/2018
04/2006 to 12/2012
Partner, Founder and Chief Compliance Officer, RiversEdge Advisors, LLC
Partner, RiversEdge Tax & Advisory
Chief Operating Officer and Chief Compliance Officer
Partner and Chief Compliance Officer, RiversEdge Advisors, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
Investment Advisor Representative,
Cambridge Investment Research Advisors, Inc.
Registered Representative, Cambridge Investment Research, Inc.
Financial Advisor, Securian Financial Services, Inc.
dba Diamond State Financial Group
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard
of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP®
certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject
areas include insurance planning and risk management, employee benefits planning, investment planning,
income tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues
and apply one’s knowledge of financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order
to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP® certification.
Chartered Financial Consultant® (“ChFC®”)
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The Chartered Financial Consultant® (ChFC®) program prepares you to meet the advanced financial planning
needs of individuals, professionals and small business owners. You'll gain a sustainable advantage in this
competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income
taxation, retirement planning, investments and estate planning. The ChFC® requires three years of full-time,
relevant business experience, nine two-hour course specific proctored exams, and 30 hours of continuing
education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of
Ethics.
Program Objectives:
• Function as an ethical, competent and articulate practitioner in the field of financial planning
• Utilize the intellectual tools and framework needed to maintain relevant and current financial planning
knowledge and strategies.
• Apply financial planning theory and techniques through the development of case studies and solutions.
• Apply in-depth knowledge in a holistic manner from a variety of disciplines; namely, estate planning,
retirement planning or non-qualified deferred compensation.
Accredited Investment Fiduciary (“AIF®”)
The AIF® mark is held by the Center for Fiduciary Studies, LLC, a Fiduciary360 (fi360) company.
The professional designations awarded by fi360 demonstrate the focus on all the components of a comprehensive
investment process, related fiduciary standards of care, and commitment to excellence. AIF® designees undergo an
initial training program, annual continuing education, and pledge to abide by the designation's code of ethics.
Since October 2002, the Accredited Investment Fiduciary® (AIF®) designation has been the mark of commitment to
a standard of investment fiduciary excellence. Those who earn the AIF® mark successfully complete a specialized
program on investment fiduciary standards of care and subsequently passed a comprehensive
examination. AIF® designees demonstrate a thorough understanding of fi360's Prudent Practices for investment
advisors and stewards.
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the Advisor or its Advisory Persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal,
civil or disciplinary events to disclose regarding Mr. Morris. However, the Advisor encourages Clients to
independently view the background of Mr. Morris on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5146654.
Item 4 – Other Business Activities
Mr. Morris is a partner of RiversEdge Business Services LLC, dba RiversEdge Tax & Advisory, an affiliated tax and
accounting firm. From time to time, he may offer clients advice or products from this activity and clients should be
aware that these services involve a conflict of interest. RiversEdge Advisors always acts in the best interest of the client
and clients always have the right to decide whether or not to utilize the services of any representative of RiversEdge
Advisors in such individual’s outside capacities.
Broker-Dealer Affiliation
Mr. Morris is also a registered representative of Purshe Kaplan Sterling Investments, Inc. (“PKS”). PKS is a registered
broker-dealer (CRD# 35747), member FINRA, SIPC. In Mr. Morris’ separate capacity as a registered representative,
Mr. Morris will receive commissions for the implementation of recommendations for commissionable transactions.
Clients are not obligated to implement any recommendation provided by Mr. Morris. Neither the Advisor nor Mr.
Morris will earn ongoing investment advisory fees in connection with any products or services implemented in Mr.
Morris’ separate capacity as a registered representative.
Insurance Agency Affiliations
Mr. Morris is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Morris’ role with RiversEdge Advisors. As an insurance professional, Mr. Morris will receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Mr. Morris is not required to offer the products of any particular insurance company. Commissions generated by
Page 23
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Morris or the Advisor.
Item 5 – Additional Compensation
Mr. Morris has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Morris serves as a Partner, Founder and the Chief Compliance Officer of RiversEdge Advisors. Mr. Morris can
be reached at (302) 573-6864.
RiversEdge Advisors has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of RiversEdge Advisors. Further, RiversEdge
Advisors is subject to regulatory oversight by various agencies. These agencies require registration by RiversEdge
Advisors and its Supervised Persons. As a registered entity, RiversEdge Advisors is subject to examinations by
regulators, which may be announced or unannounced. RiversEdge Advisors is required to periodically update the
information provided to these agencies and to provide various reports regarding the business activities and assets
of the Advisor.
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