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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 2026
14471 Chambers Road, Suite 208
Tustin, CA 92780
www.RMRCapitalMgmt.com
Firm Contact:
David Van Overeem
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of RMR Capital
Management, LLC. If clients have any questions about the contents of this brochure, please contact
us at (949) 922-3145. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any State Securities Authority. Additional
information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD #285334.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
RMR Capital Management, LLC is required to make clients aware of information that has changed
since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them.
Clients can then determine whether to review the brochure in its entirety or to contact us with
questions about the changes. Since our firm’s last annual amendment filing on February 21, 2025, we
have the following material changes to disclose:
The firm changed its main office address to 14471 Chambers Road, Suite 208, Tustin, CA
92780
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Item 3: Table of Contents
Item 1: Cover Page ....................................................................................................................................... 1
Item 2: Material Changes ............................................................................................................................ 2
Item 3: Table of Contents ............................................................................................................................ 3
Item 4: Advisory Business .......................................................................................................................... 4
Item 5: Fees & Compensation ..................................................................................................................... 5
Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 6
Item 7: Types of Clients & Account Requirements ................................................................................... 6
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 7
Item 9: Disciplinary Information ................................................................................................................ 8
Item 10: Other Financial Industry Activities & Affiliations ...................................................................... 8
Item 11: Code of Ethics, Participation or Interest in ................................................................................ 8
Client Transactions & Personal Trading .................................................................................................... 8
Item 12: Brokerage Practices ..................................................................................................................... 9
Item 13: Review of Accounts or Financial Plans ..................................................................................... 13
Item 14: Client Referrals & Other Compensation ................................................................................... 13
Item 15: Custody ....................................................................................................................................... 13
Item 16: Investment Discretion ............................................................................................................... 14
Item 17: Voting Client Securities .............................................................................................................. 14
Item 18: Financial Information ................................................................................................................ 14
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Item 4: Advisory Business
Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of California in 2016 and the State of California, Department of Business Oversight in 2017. Our
firm is wholly owned by David Van Overeem.
Our firm provides advisory services for many different types of clients to help meet their financial
goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary, it is our duty to
always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm
has established a service-oriented advisory practice with open lines of communication. Working with
clients to understand their investment objectives while educating them about our process, facilitates
the kind of working relationship we value.
Types of Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds,
exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or
investments. The client’s individual investment strategy is tailored to their specific needs and may
include some or all of the previously mentioned securities. Portfolios will be designed to meet a
particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives.
Complementary Financial Planning:
At our firms discretion, we may provide standalone financial planning and consulting services to
clients for the management of financial resources based upon an analysis of current situation, goals,
and objectives. Our Complementary Financial planning services will typically involve preparing a
financial plan or rendering a financial consultation for clients based on the client’s financial goals
and objectives at no charge to the client. This planning or consulting may encompass Investment
Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate
and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal
Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service.
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Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management clients. General
investment advice will be offered to our Complementary Financial Planning & Consulting, Retirement
Plan Consulting, clients.
Each Asset Management or Comprehensive Portfolio Management client has the opportunity to place
reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on
investments in certain securities or types of securities may not be possible due to the level of
difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm does not offer or sponsor a wrap fee program.
Regulatory Assets Under Management
As of December 31, 2025, our firm manages $170,842,000 in discretionary assets and $0 in non-
discretionary assets.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Asset Management:
Assets Under Management
Annual Fee %
$0 to $999,999.99
Up to 1.00%
$1,000,000 & Above
Up to 0.75%
The maximum annual fee charged for this service will not exceed 1.00%. Fees to be assessed will be
outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata
basis monthly in arrears based on the value of the account(s) on the value of the account(s) on the
time-weighted daily average of the month. Fees are negotiable and will be deducted from client
account(s). Our firm bills on cash unless otherwise indicated in writing. Adjustments will be made
for deposits and withdrawals during the quarter. In rare cases, our firm will agree to directly invoice.
As part of this process, Clients understand the following:
a) The client’s independent custodian sends statements at least quarterly showing the market
values for each security included in the Assets and all account disbursements, including the
amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our
firm will send an invoice directly to the custodian; and
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c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Complementary Financial Planning & Consulting:
Our firm will not charge a fee for our Complementary Financial Planning Service.
Other Types of Fees & Expenses
Clients will incur transaction fees for trades executed by their chosen custodian, via individual
transaction charges. These transaction fees are separate from our firm’s advisory fees and will be
disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction
fees for U.S. listed equities and exchange traded funds.
Clients may also pay holdings charges imposed by the chosen custodian for certain investments,
charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), distribution
fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and
mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire
transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm
does not receive a portion of these fees.
Termination & Refunds
Advisory fees for our Asset Management, Comprehensive Portfolio Management services are charged
monthly in arrears. If you wish to terminate our services, you need to contact us in writing and state
that you wish to cancel this Agreement. Upon receipt of your letter of termination, we will proceed
to close out your account and charge you a pro-rata advisory fee(s) for services rendered up to the
point of termination.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us. Our firm has the following types of clients:
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit Sharing Plans; and
Corporations, Limited Liability Companies and/or Other Business Types.
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Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Cyclical Analysis: statistical analysis of specific events occurring at a sufficient number of relatively
predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical
forces drive price movements in the financial markets. Risks include that cycles may invert or
disappear and there is no expectation that this type of analysis will pinpoint turning points, instead
be used in conjunction with other methods of analysis.
Fundamental Analysis: considers the economic, financial, and other qualitative/quantitative factors
that may impact the price of a security. Fundamental analysis attempts to measure its intrinsic value
as compared to its current price. Risks may include using incorrect assumptions, financial
misreporting and/or failure by management to disclose key, material events, and unforeseen
micro/macroeconomic factors that may cause the price of a security to diverge from its intrinsic
value.
Investment Strategies We Use
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Fixed Income Portfolio Management Investment Strategies: We believe that a conservative, risk-
averse approach to fixed income management will provide both steady incremental performance,
and low relative volatility. The disciplined process we employ in an effort to realize this philosophy
is generally grounded in four key decisions:
Constraint of portfolio duration within a narrow range relative to the benchmark in order to
limit exposure to market and interest rate risk.
Strategic allocations to key sectors to add value relative to the benchmark.
Proactive management of term structure to add value in different yield curve environments.
Security selection based on rigorous credit and relative value analysis and broad
diversification of nongovernment issuers.
Long-Term Purchases: We may buy securities for your account and hold them for a relatively long
time (more than a year) in anticipation that the security’s value will appreciate over a long horizon.
The risk of this strategy is that we could miss out on potential short-term gains that could have been
profitable to your account. Moreover, if our predictions are incorrect, it’s possible that the security’s
value may decline sharply before we make a decision to sell.
Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and
commercial papers. Generally, these assets are considered nonproductive and will be exposed to
inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will
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generally return less than the advisory fee charged by our firm. Our firm may recommend cash and
cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best
interest. Our firm considers cash and cash equivalents to be an asset class. Therefore, our firm assess
an advisory fee on cash and cash equivalents unless indicated otherwise in writing.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, are appropriately diversified in investments, and ask
any questions.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our services related to our Asset
Management, and Portfolio Monitoring services, as applicable.
Item 9: Disciplinary Information
Neither our firm nor its management personnel have been subject to any criminal or civil actions,
administrative proceedings, or self-regulatory organization (“SRO”) proceedings.
Item 10: Other Financial Industry Activities & Affiliations
Our firm is not registered, nor does it have an application pending to register, as a broker-dealer,
futures commission merchant, commodity pool operator, commodity trading advisor, or an
associated person of the foregoing entities.
Our firm does not recommend or select other investment advisers for clients. Our firm does not
directly or indirectly receive compensation for the recommendation or selection of other investment
advisers.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material
facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
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transaction and insider trading. Our firm requires all representatives to conduct business with the
highest level of ethical standards and to comply with all federal and state securities laws at all times.
Upon employment with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Our firm does not maintain custody of client assets (although our firm may be deemed to have
custody of client assets if give the authority to withdraw assets from client accounts (see Item 15
Custody, below). Client assets must be maintained in an account at a “qualified custodian,” generally
a broker-dealer or bank. Our firm recommends that clients use Charles Schwab & Co., Inc. (“Schwab”),
a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Our firm is
independently owned and operated, and not affiliated with Schwab. Schwab will hold client assets in
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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a brokerage account and buy and sell securities when instructed. While our firm recommends that
clients use Schwab as custodian/broker, clients will decide whether to do so and open an account
with Schwab by entering into an account agreement directly with them. Our firm does not open the
account. Even though the account is maintained at Schwab, our firm can still use other brokers to
execute trades, as described in the next paragraph.
How Brokers/Custodians Are Selected
Our firm seeks to recommend a custodian/broker who will hold client assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. A wide range of factors are considered, including, but not limited to:
combination of transaction execution services along with asset custody services (generally
without a separate fee for custody)
capability to execute, clear and settle trades (buy and sell securities for client accounts)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.)
availability of investment research and tools that assist in making investment decisions
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate them
reputation, financial strength and stability of the provider
prior service to our firm and our other clients
availability of other products and services that benefit our firm, as discussed below (see
“Products & Services Available from Schwab”)
Custody & Brokerage Costs
Schwab generally does not charge a separate fee for custody services but is compensated by charging
commissions or other fees to clients on trades that are executed or that settle into the Schwab
account. Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds.
For some accounts, Schwab may charge your account a percentage of the dollar amount of assets in
the account in lieu of commissions. Schwab’s commission rates and/or asset-based fees applicable to
client accounts were negotiated based on our firm’s commitment to maintain a minimum threshold
of assets statement equity in accounts at Schwab. This commitment benefits clients because the
overall commission rates and/or asset-based fees paid are lower than they would be if our firm had
not made the commitment. In addition to commissions or asset-based fees Schwab charges a flat
dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a
different broker-dealer but where the securities bought or the funds from the securities sold are
deposited (settled) into a Schwab account. These fees are in addition to the commissions or other
compensation paid to the executing broker-dealer. Because of this, in order to minimize client trading
costs, our firm has Schwab execute most trades for the accounts.
Products & Services Available from Schwab
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like our firm. They provide our firm and clients with access
to its institutional brokerage – trading, custody, reporting and related services – many of which are
not typically available to Schwab retail customers. Schwab also makes available various support
services. Some of those services help manage or administer our client accounts while others help
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manage and grow our business. Schwab’s support services are generally available on an unsolicited
basis (our firm does not have to request them) and at no charge as long as our firm keeps a total of
at least $10 million of client assets in accounts at Schwab. If our firm has less than $10 million in
client assets at Schwab, our firm may be charged quarterly service fees. Here is a more detailed
description of Schwab’s support services:
Services that Benefit Clients
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which our firm might not otherwise have access or that would
require a significantly higher minimum initial investment by firm clients. Schwab’s services
described in this paragraph generally benefit clients and their accounts.
Services that May Not Directly Benefit Clients
Schwab also makes available other products and services that benefit our firm but may not directly
benefit clients or their accounts. These products and services assist in managing and administering
our client accounts. They include investment research, both Schwab’s and that of third parties. This
research may be used to service all or some substantial number of client accounts, including accounts
not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
provides pricing and other market data;
assists with back-office functions, recordkeeping and client reporting.
Services that Generally Benefit Only Our Firm
Schwab also offers other services intended to help manage and further develop our business
enterprise. These services include:
technology, compliance, legal, and business consulting;
educational conferences and events
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party
vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these
services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other
benefits, such as occasional business entertainment for our personnel.
Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance
the client experience, help clients reach their goals and put client interests before that of our firm or
associated persons.
Our Interest in Schwab’s Services.
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The availability of these services from Schwab benefits our firm because our firm does not have to
produce or purchase them. Our firm does not have to pay for Schwab’s services so long as a total of
at least $10 million of client assets in accounts are kept at Schwab. Beyond that, these services are
not contingent upon our firm committing any specific amount of business to Schwab in trading
commissions or assets in custody. The $10 million minimum may serve as an incentive to recommend
that clients maintain their account with Schwab based on our interest in receiving Schwab’s services
that benefit our business rather than based on the client’s interest in receiving the best value in
custody services and the most favorable execution of transactions. This is a potential conflict of
interest. Our firm believes, however, that the selection of Schwab as custodian and broker is in the
best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s
services (based on the factors discussed above – see “How Brokers/Custodians Are Selected”) and not
Schwab’s services that benefit only our firm.
Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referral from a broker-dealer or a third party.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
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Item 13: Review of Accounts or Financial Plans
Our David Van Overeem, Chief Compliance Officer, reviews accounts on at least an annual basis for
our Portfolio Management, Asset Management clients. The nature of these reviews is to learn
whether clients’ accounts are in line with their investment objectives, appropriately positioned based
on market conditions, and investment policies, if applicable. Our firm may review client accounts
more frequently than described above. Among the factors which may trigger an off-cycle review are
major market or economic events, the client’s life events, requests by the client, etc. Our firm does
not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on
at least an annual basis when our Portfolio Management, Asset Management clients are contacted.
Financial Planning clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us. Our firm does not provide ongoing services to financial
planning clients, but are willing to meet with such clients upon their request to discuss updates to
their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or
verbal updated reports regarding their financial plans unless they separately engage our firm for a
post-financial plan meeting or update to their initial written financial plan.
Item 14: Client Referrals & Other Compensation
Charles Schwab & Co., Inc.
Our firm receives economic benefit from Schwab in the form of the support products and services
made available to our firm and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of
Schwab’s products and services is not based on our firm giving particular investment advice, such as
buying particular securities for our clients.
Referral Fees
Our firm does not pay referral fees (non-commission based) to independent solicitors (non-
registered representatives) for the referral of their clients to our firm in accordance with relevant
state statutes and rules.
Item 15: Custody
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review
these statements. Additionally, if our firm decides to send its own account statements to clients, such
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statements will include a legend that recommends the client compare the account statements
received from the qualified custodian with those received from our firm. Clients are encouraged to
raise any questions with us about the custody, safety or security of their assets and our custodial
recommendations.
Item 16: Investment Discretion
Clients have the option of providing our firm with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Limitations may be imposed by the client in the form of
specific constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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