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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Office Address:
1200 Smith St., Suite 610
Houston, TX 77002
Phone: (281) 580-2100
Website: www.postoakprivatewealth.com
Email: rwyrick@postoakprivatewealth.com
October 1, 2025
This brochure provides information about the qualifications and business practices of Post Oak Private
Wealth Advisors . Being registered as a registered investment adviser does not imply a certain level of skill or
training. If you have any questions about the contents of this brochure, please contact us at (281) 580-2100.
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.
A D D I T I O N A L I N F O R M A T I O N A B O U T P O S T O A K P R I V A T E W E A L T H A D V I S O R S
( C R D # 1 5 9 2 9 3 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T
W W W . A D V I S E R I N F O . S E C . G O V
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Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the required annual update for Registered Investment
Advisors. Since the last update on February 4, 2025, the following changes have occurred:
We no longer offer estate planning assistance services through Wealth.com. All
references to this service have been removed from this ADV.
We are now wholly owned by Post Oak Private Wealth Holdings, LLC.
We now also offer Fidelity Brokerage Services as an approved custodian.
As part of our discretionary management services, we now also offer Multi-Asset
Class Portfolios. Additional information about the fees and services can be found in
Item 4 & Item 5 below.
This Firm Brochure being delivered is the complete brochure for the Firm.
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Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 3
Wrap Fee Programs ......................................................................................................................................................... 3
Client Assets under Management .............................................................................................................................. 3
Item 5: Fees and Compensation ....................................................................................................... 3
Method of Compensation and Fee Schedule .......................................................................................................... 3
Client Payment of Fees ................................................................................................................................................... 6
Additional Client Fees Charged ................................................................................................................................... 6
Prepayment of Client Fees ............................................................................................................................................ 6
External Compensation for the Sale of Securities to Clients ........................................................................... 6
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6
Sharing of Capital Gains ................................................................................................................................................. 6
Item 7: Types of Clients ....................................................................................................................... 7
Description .......................................................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7
Methods of Analysis ......................................................................................................................................................... 7
Investment Strategy ........................................................................................................................................................ 7
Security Specific Material Risks .................................................................................................................................. 7
Item 9: Disciplinary Information ..................................................................................................... 9
Criminal or Civil Actions ................................................................................................................................................ 9
Administrative Enforcement Proceedings ............................................................................................................. 9
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 9
Item 10: Other Financial Industry Activities and Affiliations ............................................... 9
Broker-Dealer or Representative Registration .................................................................................................... 9
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Futures or Commodity Registration ......................................................................................................................... 9
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 9
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ................................................................................................................................................... 10
Code of Ethics Description ......................................................................................................................................... 10
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 10
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 10
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest .................................................................................................................. 11
Item 12: Brokerage Practices ......................................................................................................... 11
Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 11
Aggregating Securities Transactions for Client Accounts ............................................................................. 12
Item 13: Review of Accounts ........................................................................................................... 12
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 12
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 12
Content of Client Provided Reports and Frequency ........................................................................................ 12
Item 14: Client Referrals and Other Compensation ................................................................ 13
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 13
Advisory Firm Payments for Client Referrals .................................................................................................... 13
Item 15: Custody .................................................................................................................................. 13
Account Statements ...................................................................................................................................................... 13
Item 16: Investment Discretion ..................................................................................................... 13
Discretionary Authority for Trading...................................................................................................................... 13
Item 17: Voting Client Securities ................................................................................................... 14
Proxy Votes ...................................................................................................................................................................... 14
Item 18: Financial Information ...................................................................................................... 14
Balance Sheet .................................................................................................................................................................. 14
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 14
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 14
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Item 4: Advisory Business
Firm Description
RMW Advisors, LLC dba Post Oak Private Wealth Advisors (“we”, “us”) is a Texas limited
liability company formed in October 2011. It was subsequently registered as a Texas
investment adviser. In July 2019, the firm was registered with the SEC. Post Oake Private
Wealth Holdings, LLC is the sole (100%) owner of the RMW Advisors, LLC dba Post Oak
Private Wealth Advisors. Robert Wyrick continues to serve as managing member through
LegacyCo.
Types of Advisory Services
PORTFOLIO MANAGEMENT
We offer discretionary and non-discretionary management on individualized portfolios for
our clients. We work with each client to formulate an individualized portfolio based upon
his/her objectives, time frame, risk parameters and other investment considerations. We
use marketable securities that may include bonds, common stock (equities), options and
treasury bonds. (Additional information about securities used their risks can be found
under Item 8.) Our investment philosophy is to use principals of value, safety and quality
to seek investment options globally. We place heavy emphasis on risk control, believing
that avoiding losses allows appreciation potential of equities to be realized.
Discretionary
When the Client provides us discretionary authority the Client will sign a limited
trading authorization or equivalent. We will have the authority to execute transactions
in the account without seeking Client approval on each transaction.
Non-Discretionary
When the Client elects to use us on a non-discretionary basis, we will determine the
securities to be bought or sold and the amount of the securities to be bought or sold.
However, we will obtain prior Client approval on each and every transaction before
executing any transaction.Each portfolio is designed to meet your individual needs,
stated goals and objectives. Additionally, you have the opportunity to place reasonable
restrictions on the types of investments to be held in the portfolio.
Multi-Asset Class Portfolios
Some advisors with Post Oak Private Wealth Advisors may offer multi-asset class
portfolios. These portfolios are comprised of ETFs and mutual fund holdings and are
approved through our proprietary research. While each individual investment is analyzed
on a stand-alone basis, we view risk for the multi-asset class portfolios on a portfolio level
and assess each investment's risk in that context as client portfolios are constructed.
Client portfolios may deviate considerably from our neutral strategic position as we seek to
capture opportunities and reduce risk arising from asset class mispricing. Proprietary due
diligence is conducted on every fund used in client portfolios. The process begins with a
quantitative assessment of performance and consistency criteria, including past relative
and absolute investment returns, style drift, drawdowns and volatility.
Qualitative screening begins with a preliminary assessment of the management team, its
strategy, investment philosophy and process, the repeatability of investment approach, risk
management and operations.
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Once a manager is added to our approved list, we institute a regular monitoring process
which includes telephone calls, site visits, review of positioning and continued performance
analysis.
The resulting portfolios reflect our global view, our manager research process, and the
investment objectives and risk tolerance of the client. Client portfolios are carefully
monitored and adjusted as we alter our view based on changing market conditions.
SEI Managed Accounts Solutions
Post Oak Private Wealth Advisors offers discretionary management services through a
program sponsored by SEI Investments Management Corp (SIMC). SIMC has developed a
standard managed account solutions (“MAS”), which program includes SEI’s distribution
focused strategies, an integrated managed account solutions providing a tax overlay service
(“Tax Management”) and a Goals Based Investing managed account solutions, consisting of
MAS and Tax Management portfolios invested in accordance with SEI’s goals-based
investment solutions and, may, in the future, develop additional managed account solutions
(collectively, the “Managed Account Solutions”). Under this program, SIMC acts as a co-
investment advisor to the Investor, along with Post Oak Private Wealth Advisors, pursuant
to a tri-party investment management agreement executed among SIMC, Post Oak Private
Wealth Advisors and each Investor investing assets into the Managed Account Solutions
(the “Tri-party Agreement”). For each Managed Account Solutions, SIMC is responsible for
developing managed account portfolios designed to be invested in accordance with a stated
investment objective (the “Managed Account Portfolios”). For each Managed Account
Portfolio, other than the Managed Account Portfolios implementing distribution-focused
strategies (the “DFS Portfolios”), SIMC is solely responsible for screening, reviewing and
selecting the various money managers and/or individual mutual funds and Other Assets
available for selection by Advisors and their Investors designed to meet the specific
Managed Account Portfolio’s stated investment objective or goal. For each DFS Portfolio,
SIMC is responsible for selecting the SEI Funds and/or Other Assets underlying each DFS
Portfolio and actively managing each Investor Account invested in a DFS Portfolio in
accordance with the portfolio’s investment objectives.
SEI Mutual Fund Models Program and SEI Funds
Post Oak Private Wealth Advisors offers discretionary management services through a
program sponsored by SEI Investments Management Corp (SIMC). SIMC has developed
various model mutual fund asset allocation portfolios (the "Mutual Fund Models") designed
to be invested in accordance with a stated investment objective or goal (the "Mutual Fund
Models Program"). SIMC currently develops its Mutual Fund Models through two
underlying programs, described in various SEI literature as either SEI's Institutional Mutual
Fund models or SEI's Goals Based Investing models and, may in the future, develop
additional mutual fund model programs. Each Mutual Fund Model's underlying portfolio
allocation is generally comprised exclusively of mutual funds in the SEI family of funds
("SEI Funds"), which are each advised by SIMC. Pursuant to the Mutual Fund Models
Program, SEI will make available its various Mutual Fund Models to Post Oak Private
Wealth Advisors who, in turn, may assist Investors in determining into which Mutual Fund
Models to invest their assets.
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FINANCIAL PLANNING
Financial Planning services typically focus on one or more specific areas such as financial
and cash management, risk management, financial issues relating to divorce or death of a
family member, insurance planning, estate planning, tax issues, retirement planning,
educational funding, goal setting, or other needs identified by the client or by our review of
the client’s financial circumstances.
Through discussion with the client and/or
questionnaires, we will collect pertinent data; identify goals, objectives, financial concerns
and potential solutions. We will present the client with a written analysis. Following the
conclusion of the consulting services, we may make recommendations regarding
implementation of the financial strategies discussed.
Clients are not obligated to follow any recommendations we may make or to implement
any recommendations through us.
SEMINARS AND WORKSHOPS
Post Oak Private Wealth Advisors holds seminars and workshops to educate the public on
different types of investments and the different services they offer. The seminars are
educational in nature and no specific investment or tax advice is given.
Client Tailored Services and Client Imposed Restrictions
Our services are individualized to each client. However, we generally do not allow clients
to place restrictions on the types of securities held in their accounts.
Wrap Fee Programs
Post Oak Private Wealth Advisors does not sponsor any wrap fee programs.
Client Assets under Management
As of December 31, 2024, we manage $282,025,465 in client assets on a discretionary basis
and $0 on a non-discretionary basis.
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
PORTFOLIO MANAGEMENT SERVICES
Post Oak Private Wealth Advisors offers direct asset management services to advisory
Clients.
Standard Fee Schedule:
Post Oak Private Wealth Advisors charges an annual investment advisory fee based on the
total assets under management as follows:
Custodian Reported Value of Account Management Fee
Up to $500,000
$500,000 to $ 2,500,000
$2,500,000 to $5,000,000
$5,000,000 +
1.50%
1.25%
1.00%
0.85%
Your management fee is negotiable based on account size, services offered and individual
client circumstances. The management fee is calculated and collected monthly in arrears.
At the conclusion of the last day of each month, we download the value of your account
from its custodian. We use this value to calculate our management fee, based on the annual
rate, divided by 365 and then multiplied by the number of days in the month We then debit
our management fee from your account.
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Multi-Asset Class Portfolios
Post Oak Private Wealth Advisors offers a tiered fee schedule for clients whose assets are in
a multi-asset class portfolio.
Custodian Reported Value of Account Management Fee
On the first $1,000,000
On the next $4,000,000
On the next $5,000,000
Amounts over $10,000,000
1.00%
0.75%
0.55%
0.35%
The annual management fee is a tiered fee. A tiered fee means the applicable rate will be
applied to the balance on the last day of the billing period in each applicable range of
account value and based on the number of days in that given month. For example, an
account with a month end value of $1,300,000 will be charged 1.00% annually on the first
$1,000,000 and 0.75% annually on the next $300,000.
The management fee is exclusive of brokerage commissions, transaction fees, and other
related costs and expenses that are incurred by the client. Clients may incur certain charges
imposed by custodians, brokers, third party investment and other third parties such as fees
charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Mutual funds and exchange traded funds also charge
internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees
and commissions are exclusive of and in addition to our management fee and we do not
receive any portion of these commissions, fees, and costs. For more information about our
recommended brokerage practice please see Item 12.A.
A client may terminate the Investment Management Agreement for any reason at any time
and, within the first five (5) business days after signing the contract, without any cost or
penalty. Thereafter, the contract may be terminated at any time by giving ten (10) days
written notice. Upon termination, fees will be prorated for the number of days that services
were rendered on the Account’s valuation as of the termination date. The written notice of
termination must be sent to Post Oak Private Wealth Advisors, 1200 Smith St., Suite 610,
Houston, TX 77002. Upon our receipt of written notice of termination, the client will be
charged a prorated amount of the management fee based on the number of days services
were provided during the termination month. For example, if there are 30 days in a month
and the service was cancelled 15 days into the month, the client will be charge 50% of the
monthly management fee. (15 divided by 30 equals 50%)
SEI Managed Account Solutions
For the SEI Managed Account Solutions program Post Oak Private Wealth Advisors charges
an annual investment advisory fee based on the total assets under management as follows:
Assets Under Management
Up to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 to $3,000,000
$3,000,001 to $4,000,000
$4,000,001 to $5,000,000
Over $5,000,000
Post Oak Private Wealth
Advisors Annual Fee
1.00%
0.90%
0.80%
0.70%
0.60%
0.50%
Post Oak Private Wealth
Advisors Quarterly Fee
0.250%
0.225%
0.200%
0.175%
0.150%
0.125%
The annual fee may be negotiable.
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Post Oak Private Wealth Advisors receives compensation as a result of a Client’s
participation in SIMC’s programs. For assisting Clients in selecting appropriate Mutual
Fund Models, Managed Account Portfolios or Custom Portfolios in accordance with the
terms of Post Oak Private Wealth Advisor’s advisory agreement and, if applicable Triparty
Agreement, with such Clients and providing on-going account services, Post Oak Private
Wealth Advisors will receive a fee payable from the Client’s Account assets. Post Oak
Private Wealth Advisor’s fee will be calculated quarterly on the Client’s Account balance
and payable quarterly in arrears net of any income, withholding or other taxes. Post Oak
Private Wealth Advisor’s fee is separate from and in addition to SIMC’s Investment
Management Fee described below. Post Oak Private Wealth Advisor’s fee and SIMC’s
Investment Management fee will be deducted by SEI directly from the Client’s account. Post
Oak Private Wealth Advisors does not have the ability to directly deduct their advisory fee
from the client account.
In addition to the fees charged by Post Oak Private Wealth Advisors above, SEI charges the
following annual fees:
No Platform Fee
SEI Fees ranging from 0.55 – 1.15%
SEI Sponsored Programs - SIMC Sub-Advised Program
SEI Mutual Funds, SEI Managed Account
Solutions, SEI Sub-Advised Program
Custom High Net Worth Solutions
Third Party Assets - Mutual Fund Models Program
Non-Transaction Fee (NTF) Mutual Funds No Platform Fee
Transaction Fee (TF) Mutual Funds and
20 basis points
all other securities, including equities,
The platform fee is subject to a $1,000 per year,
per account, maximum
fixed income and ETFs
Post Oak Private Wealth Advisors Managed - Custody-only Program
Custom portfolio
No Platform Fee
Clients may terminate their account within five (5) business days of signing the Investment
Advisory Agreement with no obligation. For accounts closed mid-quarter, Post Oak Private
Wealth Advisors will be entitled to a pro rata fee for the days service was provided in the
final quarter. Client shall be given thirty (30) days prior written notice of any increase in
fees. Any increase in fees will be acknowledged in writing by both parties before any
increase in said fees occurs.
FINANCIAL PLANNING AND CONSULTING
Post Oak Private Wealth Advisors charges a fixed fee of no more than $5,000 for financial
planning. Prior to the planning process the Client will be provided an estimated plan fee.
Services are completed and delivered inside of thirty (30) days contingent upon timely
delivery of all required documentation.
Fees for financial plans are due upon delivery of the completed plan.
Client may cancel within five (5) business days of signing Agreement with no obligation
and without penalty. If the Client cancels after five (5) business days, any unpaid earned
fees will be due to Post Oak Private Wealth Advisors. Post Oak Private Wealth Advisors
reserves the right to waive the fee should the Client implement the plan through Post Oak
Private Wealth Advisors.
SEMINARS AND WORKSHOPS
Post Oak Private Wealth Advisors does not charge a fee for attendance to these seminars.
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Client Payment of Fees
Investment management fees are debited monthly in arrears, meaning that we debit you
after the billing period. Fees are usually deducted from a designated Client account to
facilitate billing. The Client must consent in advance to direct debiting of their investment
account.
Fees for financial plans are due upon delivery of the completed plan.
Post Oak Private Wealth Advisors, in its sole discretion, may waive its minimum fee and/or
charge a lesser investment advisory fee based upon certain criteria (e.g., historical
relationship, type of assets, anticipated future earning capacity, anticipated future
additional assets, dollar amounts of assets to be managed, related accounts, account
composition, negotiations with Clients, etc.).
If a client is utilizing a TPM, they pay the TPM’s investment advisory fees. Prior to signing
an investment advisory agreement, the method of payment will be disclosed in the TPM’s
Form ADV Part 2.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transaction
fees, postage and handling and miscellaneous fees.
For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
Post Oak Private Wealth Advisors does not require any prepayment of fees.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to Post Oak Private Wealth Advisors.
External Compensation for the Sale of Securities to Clients
Investment Advisor Representatives of Post Oak Private Wealth Advisors receive external
compensation sales of investment related products such as insurance as licensed insurance
agents. From time to time, they will offer clients services from those activities. Less than
1% of their compensation is from external compensation.
This represents a conflict of interest because it gives an incentive to recommend products
based on the commission received. As an
insurance agent, Investment Advisor
Representatives do not charge advisory fees for the services offered through insurance
carriers. This conflict is mitigated by disclosures, procedures, and Post Oak Private Wealth
Advisors’ fiduciary obligation to place the best interest of the Client first and Clients are not
required to purchase any products or services. Clients have the option to purchase these
products through another insurance agent of their choosing.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
We do not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) or provide side by side management.
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Item 7: Types of Clients
Description
We offer our services to individuals, institutions, pension and profit-sharing plans, trusts,
estates, and corporations or other business entities. We require a minimum account size of
$50,000 for our portfolio management services. We may aggregate related accounts in the
same household to meet account minimums. Also account minimums may be negotiated,
reduced or waived at our discretion.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We use various methods of security analysis to help us manage client investment
account(s). These may include one or more of the following:
Fundamental Analysis - Fundamental analysis is a technique that attempts to determine a
security’s value by focusing on underlying factors that affect a company's actual business
and its future prospects. The analysis is performed on historical and present data. On a
broader scope, one can perform fundamental analysis on industries or the economy as a
whole. The term refers to the analysis of the economic well-being of a financial entity as
opposed to only its price movements.
Technical Analysis - Technical Analysis is a method of evaluating securities by analyzing
statistics generated by market activity, such as past prices and volume. Technical analysts
do not attempt to measure a security's intrinsic value, but instead use charts and other
tools to identify patterns that can suggest future activity.
We use various sources of information to help us manage your investment account(s).
These include:
Financial newspapers and magazines
Research materials prepared by others
Corporate rating services
Annual reports, company financial statements, prospectuses and filings with the
Securities and Exchange Commission
Company press releases
Financial news media, including televised and Web-based
Contact with investment company representatives
Investment Strategy
We use several types of securities in our clients’ accounts. These securities may include,
but are not limited to, the following: Bonds and other corporate debt instruments;
Exchange Traded Funds; Mutual Funds such as Large Cap Growth, Large Cap Value, Mid
Cap Growth, Mid Cap Value, Small Cap Growth, Index, Leveraged, Inverse and Small Cap
Value; Government Debt instruments including Treasury Bills and Municipal securities;
Stocks; Preferred Stock; High Yield Debt; Domestic Fixed Income; Options; Money Market
Funds and Cash.
Security Specific Material Risks
All investments bear different types and degrees of risk and investing in securities
involves risk of loss that clients should be prepared to bear. While we use investment
strategies that are designed to provide appropriate investment diversification, some
investments have significantly greater risks than others. Obtaining higher rates of return
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on investments entails accepting higher levels of risk. Recommended investment strategies
seek to balance risks and rewards to achieve investment objectives. A client needs to ask
questions about risks he/she does not understand; we would be pleased to discuss them.
We strive to render our best judgment on behalf of our clients. Still, we cannot assure or
guarantee clients that investments will be profitable or ensure that no losses will occur in
an investment portfolio. Past performance is an important consideration with respect to
any investment or investment adviser but is not a reliable predictor of future performance.
We continuously strive to provide outstanding long-term investment performance, but
many economic and market variables beyond its control can affect the performance of an
investment portfolio.
An investment could lose money over short or even long periods. A client should expect
his/her account value and returns to fluctuate within a wide range, like the fluctuations of
the overall stock and bond markets. A client’s account performance could be hurt by:
Stock market risk: The chance that stock prices overall will decline. Stock markets
tend to move in cycles, with periods of rising stock prices and periods of falling
stock prices.
Interest rate risk: The chance that bond prices overall will decline because of
rising interest rates.
Manager risk: The chance that the proportions allocated to the various securities
will cause the client’s account to underperform relevant to benchmarks or other
accounts with a similar investment objective.
International investing risk: Investing in the securities of non-U.S. companies
involves special risks not typically associated with investing in U.S. companies.
Foreign securities tend to be more volatile and less liquid than investments in U.S.
securities, and may lose value because of adverse political, social or economic
developments overseas or due to changes in the exchange rates between foreign
currencies and the U.S. dollar. In addition, foreign investments are subject to
settlement practices, as well as regulatory and financial reporting standards, which
differ from those of the U.S.
Active management fees risk: Active management strategies that involve frequent
trading generate higher transaction costs that diminish the fund's return. In
addition, the short-term capital gains resulting from frequent trades often have an
unfavorable income tax impact when such funds are held in a taxable account.
Leveraged and inverse fund risks: A number of factors may hinder a leveraged or
inverse fund’s ability to achieve correlation with its benchmark index, including
fees, expenses, transaction costs, use of margin or other leveraged investment
techniques, index rebalancing, and other factors described in the prospectus. The
effects of leverage and compounding, however, are the two primary reasons why the
return of an index over the specified rebalancing period does not translate into the
return of a leveraged or inverse fund held for longer than the rebalancing period
(and remember, a leveraged or inverse fund does not typically attempt to track an
index over any period longer than the rebalancing period, which is most commonly
one day). Compounding and leverage are likely to have a significant effect on long-
term performance, whether positive or negative. This is one reason why a leveraged
or inverse fund that closely tracks the daily performance of an index will not
necessarily track the long-term performance of that index. When held for longer
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than one day, a leveraged or inverse fund that seeks to achieve a multiple of the
daily return of a benchmark index can even have negative performance over a
period in which the benchmark index achieved positive returns. This divergence
tends to be particularly pronounced in volatile markets but can also occur in
relatively "flat" markets.
Options Risk: Like other securities - including stocks, bonds, and mutual funds -
options carry no guarantees, and a person must be aware that it is possible to lose
all of the principal he/she invests and sometimes more. As an option holder, a
person risks the entire amount of the premium he/she paid pay. But as an options
writer, a person takes on a much higher level of risk. For example, if a person writes
an uncovered call, he/she faces unlimited potential loss, since there is no cap on
how high a stock price can rise. However, since initial options investments usually
require less capital than equivalent stock positions, a potential cash loss as an
options investor are usually smaller than if someone bought the underlying stock or
sold the stock short. The exception to this general rule occurs when an option is
used to provide leverage: Percentage returns are often high, but it is important to
remember that percentage losses can be high as well.
Item 9: Disciplinary Information
Criminal or Civil Actions
Post Oak Private Wealth Advisors and its management have not been involved in any
criminal or civil action.
Administrative Enforcement Proceedings
Post Oak Private Wealth Advisors and its management have not been involved in
administrative enforcement proceedings.
Self- Regulatory Organization Enforcement Proceedings
Post Oak Private Wealth Advisors and its management have not been involved in legal or
disciplinary events that are material to a Client’s or prospective Client’s evaluation of Post
Oak Private Wealth Advisors or the integrity of its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Post Oak Private Wealth Advisors is not registered as a broker-dealer and no affiliated
representatives of Post Oak Private Wealth Advisors are registered representatives of a
broker-dealer.
Futures or Commodity Registration
Neither Post Oak Private Wealth Advisors nor its affiliated representatives are registered
or have an application pending to register as a futures commission merchant, commodity
pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of
Interest
Managing Member Robert Wyrick has a financial affiliated business as an insurance agent
with RMW Advisors, LLC dba Post Oak Private Wealth Advisors. Approximately 5% of his
time is spent on this activity. He may offer Clients services from this activity. As an
insurance agent, he may receive separate yet typical compensation.
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This practice represents a conflict of interest because it gives an incentive to recommend
products based on the commission amount received. This conflict is mitigated by
disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the
Client first and the Clients are not required to purchase any products. Clients have the
option to purchase these products through another insurance agent of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of
Interest
Post Oak Private Wealth Advisors has co-advisory arrangements through SEI’s Managed
Account Solutions program. Our fee is separate and in addition to the SEI’s fee. This
information can be found in Items 4 & 5. We will ensure that SEI is properly registered or
exempt from registration in the client’s state of residence prior to making any
recommendations.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
Our Code of Ethics establishes ideals for ethical conduct upon fundamental principles of
openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any
client or prospective client upon request.
Our Code of Ethics covers all supervised persons, and it describes its high standard of
business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions
relating to the confidentiality of client information, a prohibition on insider trading, a
prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and personal securities trading
procedures, among other things. All supervised persons must acknowledge the terms of the
Code of Ethics annually, or as amended.
Investment Recommendations Involving a Material Financial Interest and Conflict
of Interest
We do not have a material interest in any securities.
Advisory Firm Purchase of Same Securities Recommended to Clients and
Conflicts of Interest
Our owner, Mr. Wyrick, may, from time to time, buy or sell for his own accounts securities
that are the same as, similar to, or different than those that his clients purchase or sell.
Differences can arise due to variations in personal goals, investment horizons, risk
tolerance, and the timing of purchases and sales. The securities traded are typically broadly
traded, large scale securities (not penny stocks) and/or mutual funds in which proprietary
trades will not affect market prices. Nonetheless, client transactions will precede those
orders placed for any proprietary trades. Mr. Wyrick is aware of his fiduciary duty to his
clients and the prohibitions against the use of any insider information. We keep records of
all associates’ proprietary trading activities and make them available to regulators to
review on the premises. Whenever we deem that there may appear to be a conflict of
interest, we will inform affected clients of the holdings involved prior to placing any orders.
It is our policy that we will not affect any principal or agency cross securities transactions
for client accounts. We will also not cross trades between client accounts. Principal
transactions are generally defined as transactions where an adviser, acting as principal for
its own account or the account of an affiliated broker-dealer, buys from or sells any
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security to any advisory client. A principal transaction may also be deemed to have
occurred if a security is crossed between an affiliated hedge fund and another client
account. An agency cross transaction is defined as a transaction where a person acts as an
investment adviser in relation to a transaction in which the investment adviser, or any
person controlled by or under common control with the investment adviser, acts as broker
for both the advisory client and for another person on the other side of the transaction.
Agency cross transactions may arise where an adviser is dually registered as a broker-
dealer or has an affiliated broker-dealer.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Post Oak Private Wealth Advisors does not maintain a firm proprietary trading account and
does not have a material financial interest in any securities being recommended and
therefore no conflicts of interest exist. However, affiliated persons may buy or sell
securities at the same time they buy or sell securities for Clients. In order to mitigate
conflicts of interest such as front running, affiliated persons are required to disclose all
reportable securities transactions as well as provide Post Oak Private Wealth Advisors with
copies of their brokerage statements.
The Chief Compliance Officer of Post Oak Private Wealth Advisors is Robert Wyrick. He
reviews all employee trades each quarter. The personal trading reviews ensure that the
personal trading of affiliated persons does not affect the markets and that Clients of the
firm receive preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Post Oak Private Wealth Advisors may recommend the use of a particular broker-dealer
such as Charles Schwab & Co., Inc., (“Schwab”) and Fidelity Brokerage Services (“Fidelity”),
both registered broker-dealers, members FINRA/SPIC as approved custodians. We are
independently owned and operated and not affiliated with either brokerage firm. Schwab
or Fidelity will hold the Clients’ assets in a brokerage account and buy and sell securities
when we instruct them to. While we recommend that the Client use Schwab and/or Fidelity
as the custodian/broker, the client will decide whether to do so and open an account with
Schwab and/or Fidelity by entering into an account agreement directly with them. We do
not open the account for you; however, we can assist the Client in doing so. If the Client
does not wish to place their assets with Schwab or Fidelity, then we cannot manage the
account.
Directed Brokerage
In circumstances where a Client directs Post Oak Private Wealth Advisors to use a
certain broker-dealer, Post Oak Private Wealth Advisors still has a fiduciary duty to
its Clients. The following may apply with Directed Brokerage: Post Oak Private
Wealth Advisors inability to negotiate commissions, to obtain volume discounts,
there may be a disparity in commission charges among Clients and conflicts of
interest arising from brokerage firm referrals. The firm may be unable to achieve
most favorable execution of client transactions, and this practice may cost clients
more money.
Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
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execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is affected, the ability to effect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. The firm does not receive any portion of the trading fees.
Soft Dollar Arrangements
“Soft dollars” are defined as a form of payment investment firms can use to pay for
goods and services such as news subscriptions or research. When an investment
firm gives its business to a particular brokerage firm, the brokerage firm in return
can agree to use some of its revenue to pay for these types of services. We do not
receive soft dollar benefits through Charles Schwab & Co. Inc or Fidelity Brokerage
Services.
Brokerage for Client Referrals
We do not receive client referrals or any other incentive from any custodian or any
third party.
Aggregating Securities Transactions for Client Accounts
Generally, we will aggregate orders with respect to the same security purchased for
different clients. When orders are aggregated, each participating account receives the
average share price for the transaction and bears a proportionate share of all transaction
costs, based upon each account’s participation in the transaction, subject to our discretion
depending on factual or market conditions. Clients participating in block trading may
include proprietary or related accounts. Such accounts are treated as client accounts and
are neither given preferential nor inferior treatment versus other client accounts.
Allocations of orders among client accounts must be made in a fair and equitable manner.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Mr. Wyrick reviews the general holdings of the firm’s portfolios on a bi-weekly basis. In
addition to these reviews, Mr. Wyrick meets with clients on an annual basis to discuss and
review their accounts.
Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, Post Oak Private Wealth Advisors suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Additional reviews are conducted periodically depending on market conditions, economic
or political events, or by changes in a client’s financial situation (such as retirement,
termination of employment, physical move or inheritance).
Content of Client Provided Reports and Frequency
Clients receive quarterly statements from their custodian. We urge clients to carefully
review such statements. In addition to the quarterly statements from the account
custodians, each client receives online access to his or her account through Charles Schwab
website, which contains account holdings and balance information.
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Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and
Conflicts of Interest
Post Oak Private Wealth Advisors receives a portion of the annual management fees
collected by the TPM(s) to whom Post Oak Private Wealth Advisors refers Clients.
This situation creates a conflict of interest because Post Oak Private Wealth Advisors
and/or its Investment Advisor Representative have an incentive to decide what TPMs to
use because of the higher solicitor fees to be received by Post Oak Private Wealth Advisors.
However, when referring Clients to a TPM, the Client’s best interest will be the main
determining factor of Post Oak Private Wealth Advisors.
Post Oak Private Wealth Advisors may receive a non-economic benefit from Schwab in the
form of support products and services they make available to us and other independent
advisors whose clients maintain their accounts at Schwab. The availability to us from
Schwab’s products and services is not based on us giving particular investment advice,
such as buying particular securities for the Client.
Advisory Firm Payments for Client Referrals
We do not pay for client referrals or use solicitors.
Item 15: Custody
Account Statements
All client funds, securities and accounts are held at third-party custodians. We do not take
possession of a client’s securities. However, the client will be asked to authorize us with
the ability to deduct fees directly from the client’s account. This authorization will be to
deduct our management fee only. A client may object to the deduction of our fees from the
Account by notifying us at the address or telephone number shown on each billing invoice
or by notifying client’s custodian. The client’s custodian shall also send a quarterly
statement indicating the amount of fees withdrawn from the client’s Account.
Clients should receive quarterly statements from the broker dealer, bank or other qualified
custodian that holds and maintains client’s investment assets. We urge clients to carefully
review such statements.
Item 16: Investment Discretion
Discretionary Authority for Trading
If applicable, Client will authorize us discretionary authority, via the advisory agreement, to
determine, without obtaining specific Client consent, the securities to be bought or sold,
and the amount of the securities to be bought or sold. If applicable, Client will authorize us
discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement. If, however, consent for discretion is not given,
we will obtain prior Client approval before executing each transaction.
We allow Clients to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to us in writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. We do not receive any portion of the transaction fees or commissions paid by
the Client to the custodian.
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Item 17: Voting Client Securities
Proxy Votes
Post Oak Private Wealth Advisors does not vote proxies on securities. Clients are expected
to vote their own proxies. The Client will receive their proxies directly from the custodian
of their account or from a transfer agent.
When assistance on voting proxies is requested, Post Oak Private Wealth Advisors will
provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to
the Client.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Post Oak Private Wealth Advisors
does not serve as a custodian for Client funds or securities and Post Oak Private Wealth
Advisors does not require prepayment of fees of more than $1,200 per Client and six
months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Post Oak Private Wealth Advisors has no condition that is reasonably likely to impair our
ability to meet contractual commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Post Oak Private Wealth Advisors has not had any bankruptcy petitions in the last ten
years.
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