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Part 2A Appendix 1: Wrap Fee Program
Institutional Brochure
Item 1. Cover Page
Roof Eidam Maycock Peralta, LLC
235 Pine Street, Suite 1200
San Francisco, CA 94104
Phone: 415-788-4600
Fax: 415-788-4606
www.rempadvisors.com
This Wrap Fee Program brochure provides information about the qualifications and business
practices of Roof Eidam Maycock Peralta, LLC. If you have any questions about the contents of
this brochure, please contact us at 415-788-4600, or by email at jperalta@rempadvisors.com.
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. Roof Eidam Maycock Peralta,
LLC’s registration with the SEC does not imply a certain level of skill or training.
Additional information about Roof Eidam Maycock Peralta, LLC is available on the SEC’s website
at www.adviserinfo.sec.gov.
Please note use of the term “registered investment adviser” and description of Roof Eidam
Maycock Peralta, LLC and/or our associates as “registered” does not imply a certain level of skill
or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s
associates who advise you for more information on the qualifications of our firm and its
employees.
February 2026
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Item 2. Material Changes
Roof Eidam Maycock Peralta, LLC is required to advise you of any material changes to our
Institutional Wrap Fee Program Brochure (“Institutional Brochure”) from our last annual update,
identify those changes on the cover page of our Institutional Brochure or on the page immediately
following the cover page, or in a separate communication accompanying our Institutional
Brochure. We must state clearly that we are discussing only material changes since the last
annual update of our Institutional Brochure, and we must provide the date of the last annual
update of our Institutional Brochure.
Since our last annual amendment filed on 02/04/2025, we do not have any material change(s) to
report.
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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. Services, Fees & Compensation ....................................................................................... 4
Item 5. Account Requirements and Types of Clients .................................................................... 6
Item 6. Portfolio Manager Selection and Evaluation ..................................................................... 7
Item 7. Client Information Provided to Portfolio Managers ........................................................... 9
Item 8. Client Contact with Portfolio Managers ............................................................................. 9
Item 9. Additional Information ..................................................................................................... 10
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Item 4. Services, Fees & Compensation
Firm Description
Roof Eidam Maycock Peralta LLC (“REMP”) is an independently owned Registered Investment
Advisor, registered with the U.S. Securities and Exchange Commission. REMP has been
providing investment advice and financial planning services to both institutional and individual
investors since 1992. As of December 31st, 2025, we managed $804,912,358 on a discretionary
basis.
Principal Owners
The principal owners of REMP include Gary Edmund Roof, Don Henry Eidam, Jr., Randall Robert
Maycock, and Juan Carlos Peralta.
Types of Advisory & Consulting Services
Investment Advice: REMP will design and recommend an investment portfolio, as well as specific
investment recommendations, and will assist in implementing such recommendations. REMP will
also provide portfolio review meetings, quarterly composite portfolio performance reports and
additional ancillary services. REMP will be compensated for such services through payment of a
Management Fee pursuant to the client's purchase of financial products.
Advisory Management Fee: The maximum Management Fee charged by REMP is 1.00% of gross
assets under management (valued at fair market value). The fair market value of assets in a
client's account under management will be determined on the last business day of each calendar
quarter and the agreed upon fee shall be applicable to cash and cash equivalents unless
otherwise agreed to in writing. Fees are not negotiable and shall be billed quarterly in advance.
The graduated Management Fee Schedule is as follows:
Annual Fee Percentage
Valuation of Portfolio of Assets
under Management
First $1,000,000
Next $1,000,000
Next $8,000,000
Above $10,000,000
0.75%
0.50%
0.25%
0.15%
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Retirement Plan Consulting: Our firm provides Retirement Plan Consulting services to employer
plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting
employer plan sponsors in establishing, monitoring and reviewing their company's participant-
directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include:
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• Establishing an Investment Policy Statement – Our firm will assist in the development of
a statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
•
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid plan participants in developing strategies to meet their investment
objectives, time horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance
on allocation strategies.
When providing Retirement Plan Consulting services, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate (excluding
real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or
assets, other illiquid investments, or brokerage window programs (collectively, “Excluded
Assets”). All Retirement Plan Consulting services shall be in compliance with the applicable state
laws regulating retirement consulting services. This applies to client accounts that are retirement
or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts
appointment to provide services to such accounts, our firm acknowledges its fiduciary standard
within the meaning of Section 3(21) of ERISA as designated by the Retirement Plan Consulting
Agreement with respect to the provision of services described therein.
Our Retirement Plan Consulting services are billed based on a percentage of Plan assets under
management. The total estimated fee, as well as the ultimate fee charged, is based on the scope
and complexity of our engagement with the client. The maximum fee will not exceed 1.00% of
managed Plan assets. The fee-paying arrangements will be determined on a case-by-case basis
and will be detailed in the signed consulting agreement.
Additional Fees
You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange
traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and
other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer
fees and other fees and taxes on brokerage accounts and securities transactions. These fees are
not included within the wrap-fee you are charged by our firm.
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We do not recommend or offer the wrap program services of other providers. Our investment
advisory representatives receive a portion of the advisory fee that you pay us, either directly as a
percentage of your overall fee or as their salary from our firm. In cases where our investment
advisory representatives are paid a percentage of your overall advisory fee, this may create an
incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee
program (where you would pay for trade execution costs) or brokerage account where
commissions are charged. This is because, in some cases, we may stand to earn more
compensation from advisory fees paid to us through a wrap fee program arrangement if your
account is not actively traded.
LPL Financial has a trading platform with select exchange traded funds (“ETFs”) that do not
charge transaction fees. The no-transaction-fee ETF trading platform is available to clients
participating in LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset
Management (“SAM”) programs. The limited number of ETFs available on the no-transaction fee
platform may have higher overall expenses than other types of securities and ETFs not included
in the platform.
Additionally, Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S.
listed equities and exchange traded funds. Since we pay trading costs as a part of our Wrap Fee
Program, our costs in administering the program have decreased. Furthermore, we now have a
financial incentive to use these products without transaction fee.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm by providing written or
electronic notice to the other party at any time. Upon notice of termination, our firm will process
a pro-rata refund of any unearned advisory fees charged in advance.
Item 5. Account Requirements and Types of
Clients
Description
REMP provides investment advice to charitable organizations and institutions. REMP provides
consulting services to pension plans. We do not offer discretionary investment advice & financial
planning to pension plans unless otherwise agreed upon.
Account Minimums
A minimum of $500,000 is required for new clients to establish an advisory relationship with
REMP. However, direct familial accounts may be combined to meet this minimum. Exceptions
may be made on a case-by-case basis at the discretion of management.
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Item 6. Portfolio Manager Selection and
Evaluation
Our firm does not utilize outside portfolio managers. All asset management accounts are
managed by our in-house professionals on a wrap fee basis only.
Tailored Relationships
REMP provides customized services tailored to the unique investment needs of each of their
clients. Clients may impose restrictions on investing in certain securities or types of securities.
Such restrictions must be submitted to REMP in writing. Client-imposed restrictions may affect
REMP’s ability to perform its stated investment strategy, and therefore investment performance
may deviate from that of other client portfolios managed in accordance with the same strategy.
Performance-Based Fees & Side-by-Side Management
REMP does not accept any performance-based fees. REMP generally avoids investment vehicles
in which the fund managers engage in side-by-side management.
Methods of Analysis, Investment Strategies & Risk of Loss
REMP will utilize fundamental, technical and cyclical methods when analyzing securities. They
will consider financial newspapers and magazines, research materials prepared by others,
corporate rating services, annual reports, prospectuses, filings with the SEC, and company press
releases.
REMP will consider implementing strategies for both the long term (securities to be held at least
a year) and short term (securities to be held less than a year). REMP may also purchase securities
on margin.
REMP builds custom portfolios for their client accounts based on the overall risk tolerance of each
client. REMP establishes model portfolios based on the various associated risks and applies the
models to each client’s portfolio.
REMP portfolios typically include mutual funds and exchange traded funds (“ETF”). Investing in
these instruments, as with all securities, involves the risk of loss, and clients should be prepared
to bear these losses. Mutual funds and ETFs, like stocks, generally fluctuate in value and may
decline significantly over short time periods. Perhaps the most significant risk associated with
mutual funds and ETFs is market risk. This risk is defined by the perception of investors and the
day-to-day fluctuations associated with any portfolio. Market risks include, but are not limited to:
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fiscal and monetary policy decisions, general economic conditions, geopolitical uncertainty,
inflation or deflation concerns, commodity price fluctuations, and currency valuations.
Some of the mutual funds will contain fixed-income securities. Fixed-income assets have two
main sources of risk. Interest rate risk is the risk that a rise in interest rates will cause the price of
a debt security held by the fund to fall. Securities with longer maturities typically suffer greater
declines than those with shorter maturities. Credit risk is the risk that an issuer of a debt security
will default (fail to make scheduled interest or principal payments), potentially reducing income
distributions and market values. This risk is increased when a security is downgraded or the
perceived creditworthiness of the issuer deteriorates.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder, or option buyer). The contract offers the buyer the right,
but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price
(the strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky
practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation,
option buyers and writers have conflicting views regarding the outlook on the performance of a:
• Call Option: Call options give the option to buy at certain price, so the buyer would want
the stock to go up. Conversely, the option writer needs to provide the underlying shares
in the event that the stock's market price exceeds the strike due to the contractual
obligation. An option writer who sells a call option believes that the underlying stock's price
will drop relative to the option's strike price during the life of the option, as that is how he
will reap maximum profit. This is exactly the opposite outlook of the option buyer. The
buyer believes that the underlying stock will rise; if this happens, the buyer will be able to
acquire the stock for a lower price and then sell it for a profit. However, if the underlying
stock does not close above the strike price on the expiration date, the option buyer would
lose the premium paid for the call option.
• Put Option: Put options give the option to sell at a certain price, so the buyer would want
the stock to go down. The opposite is true for put option writers. For example, a put option
buyer is bearish on the underlying stock and believes its market price will fall below the
specified strike price on or before a specified date. On the other hand, an option writer
who sells a put option believes the underlying stock's price will increase about a specified
price on or before the expiration date. If the underlying stock's price closes above the
specified strike price on the expiration date, the put option writer's maximum profit is
achieved. Conversely, a put option holder would only benefit from a fall in the underlying
stock's price below the strike price. If the underlying stock's price falls below the strike
price, the put option writer is obligated to purchase shares of the underlying stock at the
strike price.
The potential risks associated with these transactions are that (1) all options expire. The closer
the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices
can move very quickly. Depending on factors such as time until expiration and the relationship of
the stock price to the option’s strike price, small movements in a stock can translate into big
movements in the underlying options.
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Covered Calls: The risks associated with this type of strategy involve having the underlying stock
called away. Each contract has a strike price at which the writer of the contract agrees to allow
the purchaser call the stock away from the writer. This can create a taxable event whereby the
writer of the option is required to recognize a capital gain on the underlying security. Furthermore,
the market price could appreciate beyond the strike price, forcing the writer to sell their holdings
below current market value.
Uncovered Options: Uncovered option writing is suitable only for the knowledgeable investor
who understands the risks, has the financial capacity and willingness to incur potentially
substantial losses, and has sufficient liquid assets to meet applicable margin requirements. If the
value of the underlying instrument moves against an uncovered writer’s options position, our firm
may request significant additional margin payments. If an investor does not make such margin
payments, we may be forced to close stock or options positions in the investor’s account.
The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an
extremely risky position and may incur large losses if the value of the underlying instrument
increases above the exercise price.
As with writing uncovered calls, the risk of writing uncovered put options is substantial. The writer
of an uncovered put option bears a risk of loss if the value of the underlying instrument declines
below the exercise price. Such loss could be substantial if there is a significant decline in the value
of the underlying instrument.
Item 7. Client Information Provided to Portfolio
Managers
Our firm manages all assets in house, so communication with your portfolio manager(s) takes
place on a regular basis as needed (daily, weekly, monthly, etc.) to ensure your most current
investment goals and objectives are understood by your portfolio manager(s). In most cases, we
will communicate such information as part of our regular investment management duties.
Nevertheless, we will also communicate information when you ask us to, when market or
economic conditions make it prudent to do so, etc.
Item 8. Client Contact with Portfolio Managers
Clients are always free to directly contact their portfolio manager(s) with any questions or
concerns they have about their portfolios or other matters.
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Item 9. Additional Information
Disciplinary Information
REMP has not been subject to any legal or disciplinary events.
Other Financial Industry Activities and Affiliations
Representatives of our firm are licensed insurance agents. However, to eliminate any potential
conflicts of interest, we will rebate all commissions earned from any insurance products sold
against client advisory fees.
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
REMP has adopted a Code of Ethics designed to comply with Rule 204A-1 under the Investment
Advisers Act of 1940. This Code establishes rules of conduct for all partners and employees of
REMP and is designed to, among other things, govern personal securities trading activities in the
accounts of partners and employees. The Code is based upon the principle that REMP and its
employees owe a fiduciary duty to REMP’s clients to conduct their affairs, including their personal
securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead
of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or
potential conflicts of interest or any abuse of their position of trust and responsibility. Pursuant to
Section 206 of the Advisers Act, both REMP and its employees are prohibited from engaging in
fraudulent, deceptive or manipulative conduct. The purpose of the Code is to preclude activities
which may lead to or give the appearance of conflicts of interest, insider trading and other forms
of prohibited or unethical business conduct. A full copy of our Code of Ethics is available upon
request.
Periodic Reviews
Advisory accounts are reviewed at least every 12 months but may be reviewed more frequently
based on client need. The annual review is an in-depth review of the client's investment plan. The
reviews are conducted by Gary E. Roof, partner, Don H. Eidam, Jr., partner, Randall R. Maycock,
partner, or Juan Carlos Peralta, partner.
Review Triggers
Additional reviews may be triggered by client need and/or market conditions affecting specific
clients.
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Regular Reports
REMP provides clients with quarterly reports on their investment portfolios. The reports include
information on holdings and performance relative to benchmarks.
Client Referrals & Other Compensation
REMP does not receive or pay any fees for referral or solicitation of clients or have any other
formal compensation arrangements.
In an effort to keep our clients informed as to the services we offer and the various financial
products we utilize, our employees may attend conferences or events subsidized by product
providers. These trips are educational in nature, and are not dependent upon the use of any
specific products. While a conflict of interest may exist given that these trips are at least partially
funded by product sponsors, we will always adhere to our fiduciary duties in selecting appropriate
investments for our clients.
We receive an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients maintain their
accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services
for which we would otherwise have to pay once the value of our clients’ assets in accounts at
Schwab reaches a certain size. Schwab has offered to provide assistance to REMP in the amount
of up to $70,000 to be used towards technology, research, marketing, compliance and consulting
related expenses. Schwab also offered to provide reimbursement of Transfer of Account Exit Fees
for an approximate value not to exceed $70,000, for transferring clients to Schwab within 12
months. You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the arrangement because the cost of these services would otherwise
be borne directly by us. You should consider these conflicts of interest when selecting a custodian.
Custody
Our firm does not maintain custody of client assets except for the limited instances of direct fee
debiting and third party money movements. All of 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 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.
Third Party Money Movement:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
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guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse
client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have
custody. As such, our firm has adopted the following safeguards in conjunction with our custodian:
• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or
from time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of
the third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Proxy Voting
REMP will not vote proxies for its clients’ accounts. Clients will obtain information on their proxy
votes directly from the custodian. Clients may contact REMP if they have any questions on a
particular proxy solicitation.
Selecting Brokerage Firms
If a recommendation is appropriate, we recommend that our clients use LPL Financial (“LPL”) and
Charles Schwab & Co., Inc. (“Schwab”), FINRA-registered broker-dealers, members SIPC, as the
qualified custodians (collectively “Custodians”). We are independently owned and operated and
not affiliated with Custodians. Custodians will hold your assets in a brokerage account and buy
and sell securities when we instruct them to. While we recommend that you use Custodians, you
will decide whether to do so and open your account with either Custodian by entering into an
account agreement directly with them.
The factors used by REMP in selecting a broker/dealer affiliation include:
the nature and quality of the approved investment products;
the nature and quality of the investment research & due diligence;
the nature, efficiency and quality of services provided;
the nature, efficiency and quality of best execution practices;
the cost effectiveness to clients; and
the nature, quality and availability of research reports to clients.
•
•
•
•
•
•
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Because LPL and Schwab maintain restricted approved-lists of Mutual Funds and Limited
Partnerships available to REMP, a client's investment selection may be limited to those particular
Mutual Funds and Limited Partnerships on such approved-lists.
LPL and Schwab Research and Soft Dollars
LPL and Schwab conduct a limited amount of investment research on stocks, bonds, mutual
funds, ETFs, limited partnerships and real estate investment trusts. Research and compliance
support provided by LPL and Schwab is used to service all of REMP’s client accounts. REMP
does not receive any soft-dollar compensation.
LPL and Schwab Order Aggregation
The aggregation or blocking of client transactions allows REMP to execute transactions in a
timely, equitable, and efficient manner, and seeks to reduce overall transaction costs to clients.
REMP will aggregate client transactions where possible and when advantageous to clients. In
these instances, clients participating in any aggregated transactions will receive an average share
price and transaction costs will be shared equally and on a pro-rata basis.
Schwab Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab generally does not charge separately for custody
services but is compensated by charging commissions or other fees on trades that it executes or
that settle into Schwab account. For some accounts, Schwab may charge 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 our client accounts were negotiated based on our commitment to
maintain a minimum threshold of our clients’ assets in accounts at Schwab. The overall
commission rates and/or asset-based fees paid are lower than they would be if we 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 we have executed by a different
broker-dealer but where the securities bought or the funds from the securities sold are deposited
(settled) into Schwab accounts. These fees are in addition to the commissions or other
compensation paid to the executing broker-dealer. Because of this, in order to minimize trading
costs, we have Schwab execute most trades for client accounts. It is important to note that REMP
pays all transaction fees for clients participating in the REMP Wrap Fee Program.
Products and Services Available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like us. They provide us and our clients with access to their institutional brokerage services
(trading, custody, reporting, and related services), many of which are not typically available to
Schwab retail customers. However, certain retail investors may be able to get institutional
brokerage services from Schwab without going through us. Schwab also makes available various
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support services. Some of those services help us manage or administer our clients’ accounts,
while others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following
is a more detailed description of Schwab’s support services:
Services that benefit you. 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 we might not otherwise
have access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products
and services that benefit us but do not directly benefit you or your account. These products and
services assist us in managing and administering our clients’ accounts and operating our firm.
They include investment research, both Schwab’s own and that of third parties. We use this
research to service all or a substantial number of our clients’ accounts, including accounts not
maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and compliance related needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab also discounts or waives its fees for some of these
services or pays all or a part of a third party’s fees. [Schwab also provides us with other benefits,
such as occasional business entertainment of our personnel.] If you did not maintain your account
with Schwab, we would be required to pay for those services from our own resources.
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.
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• 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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