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Root Financial Partners, LLC
801 Barton Springs Road
Austin, TX 78704
(760) 452-0720
Form ADV Part 2A – Firm Brochure
Dated: January 14, 2026
This Brochure provides information about the qualifications and business practices of Root Financial
Partners (“Root”). If you have any questions about the contents of this Brochure, please contact us at
(760) 452-0720. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Root Financial Partners is registered as an Investment Adviser with the SEC. Registration of an
Investment Adviser does not imply a certain level of skill or training.
Additional information about Root is available on the SEC’s website at www.adviserinfo.sec.gov which
can be found using the firm’s identification number 290289.
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Item 2: Material Changes
This Brochure has been updated to reflect material changes to Root Financial Partners, LLC’s (“Root”)
advisory business since the last annual update. Material changes include the following:
● Change in Principal Place of Business: Root relocated its principal place of business to the
State of Texas. Corresponding updates have been made throughout this Brochure to reflect
the firm’s current address and jurisdiction.
● Addition of Vista Private Wealth: Root launched Vista, a dedicated private wealth offering
designed for clients with advanced planning needs, including households with significant
investable assets, multigenerational wealth considerations, concentrated equity positions, or
complex estate and business planning needs.
● Expansion of Investment Strategies and Risk Disclosures: Root expanded its disclosures
regarding investment strategies and related risks, including the use of separately managed
account strategies, long/short investment strategies, municipal bond strategies, and
investments in private vehicles and other non-traditional investment structures.
● Solicitor Arrangements for Held-Away Retirement Plans: Root added the ability to act as a
solicitor for unaffiliated third-party investment advisers in connection with certain held-away
retirement accounts, including arrangements under which the third-party adviser may deduct
advisory fees directly from client accounts pursuant to client authorization.
Clients are encouraged to review this brochure carefully. A copy of this Brochure is available upon
request, and clients may contact Root with any questions regarding these changes.
Future Changes
From time to time, Root Financial Partners, LLC (“Root”) may amend this Disclosure Brochure to reflect
updates to our business practices, regulatory changes, or our routine annual review as required by
securities regulations. When material changes occur, we will provide either an updated Disclosure
Brochure or a Summary of Material Changes to all clients.
You may view the current version of our Disclosure Brochure at any time by visiting the SEC’s
Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov and searching for
Root Financial Partners, LLC or by using our CRD number: 290289.
To request a printed or electronic copy of the most recent Disclosure Brochure, you may contact us at
(760) 452-0720.
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Item 3: Table of Contents
Item 3: Table of Contents....................................................................................................................................................................................3
Item 4: Advisory Business................................................................................................................................................................................... 4
Item 5: Fees and Compensation................................................................................................................................................................... 11
Item 6: Performance-Based Fees and Side-By-Side Management...................................................................................16
Item 7: Types of Clients....................................................................................................................................................................................... 17
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss................................................................................ 18
Item 9: Disciplinary Information.................................................................................................................................................................. 24
Item 10: Other Financial Industry Activities and Affiliations......................................................................................................25
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.......................26
Item 12: Brokerage Practices..........................................................................................................................................................................28
Item 13: Review of Accounts........................................................................................................................................................................... 32
Item 14: Client Referrals and Other Compensation....................................................................................................................... 33
Item 15: Custody..................................................................................................................................................................................................... 34
Item 16: Investment Discretion..................................................................................................................................................................... 36
Item 17: Voting Client Securities................................................................................................................................................................... 37
Item 18: Financial Information.......................................................................................................................................................................38
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Item 4: Advisory Business
Description of Advisory Firm
Root Financial Partners, LLC (“Root”) is registered with the U.S. Securities and Exchange Commission
(“SEC”) as an investment adviser under the Investment Advisers Act of 1940. The firm was founded in
September 2017. James Conole is the principal owner of Root, and Ari Taubleib holds a minority
ownership interest. Root Financial Partners, LLC maintains additional office locations outside of its
principal place of business. Advisory services provided from these locations are subject to the same
supervisory structure, compliance policies, and procedures as those conducted from the firm’s
principal office. All advisory personnel operate under centralized oversight and supervision.
As of December 31, 2025, Root reported approximately $2,141,036,560 in assets under management on
a discretionary basis and $6,737,828.91 in non-discretionary assets under management.
Types of Advisory Services
Investment Management Services
Root Financial Partners, LLC (“Root”) offers investment advisory services focused on managing
individually tailored portfolios. We provide continuous and customized investment advice based on
each client’s unique financial situation, goals, and preferences.
Our investment process begins with in-depth conversations to understand a client’s financial
objectives, time horizon, risk tolerance, and other relevant circumstances. Based on this information,
we develop a personalized investment strategy, which may include a written investment policy
statement or an asset allocation plan. We then construct and manage the portfolio to align with the
agreed-upon targets and investment approach.
Root may recommend or select unaffiliated third-party investment advisers or investment managers
(“sub-advisers”) to manage all or a portion of a client’s assets, including through separately
managed account (“SMA”) strategies. These sub-advisers are responsible for the day-to-day
discretionary management of the assets assigned to them, in accordance with the applicable
investment mandate. Such SMA strategies may include, among others, long-only equity or fixed
income strategies, municipal bond strategies, and alternative or long/short investment strategies,
depending on client objectives and suitability.
Root conducts initial and ongoing due diligence on all sub-advisers and is responsible for their
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selection, oversight, and monitoring. Clients are not required to engage any sub-adviser
recommended by Root, and all sub-advisers are properly registered or licensed as investment
advisers. Root does not receive compensation from any sub-adviser.
Clients will pay a separate advisory fee to Root, in addition to any fees charged by the sub-adviser, as
described in Item 5 of this Brochure. All fees are fully disclosed prior to engagement.
In managing portfolios, we consider each client’s stated objectives, such as capital appreciation,
income, growth, or a combination thereof—as well as relevant tax considerations. Clients may impose
reasonable restrictions on investing in specific securities, types of securities, or industry sectors. “Such
SMA strategies may include, among others, long-only equity or fixed income strategies, municipal
bond strategies, and alternative or long/short investment strategies, depending on client objectives
and suitability.”
Root may offer advisory services with respect to certain held-away retirement accounts, such as
401(k) and 403(b) plans, when permitted by the plan sponsor and authorized by the client. In these
cases, Root provides investment recommendations or allocates assets to third-party investment
managers through platforms or arrangements that allow for such access. These accounts remain
under the custody of the employer-sponsored plan provider, and Root does not act as the custodian
of plan assets.
In addition to traditional investment offerings, Root may provide oversight of private investment
vehicles and strategies involving complex or non-traditional securities. These strategies may involve
higher risk, greater volatility, leverage, short selling, derivatives, or other speculative investment
techniques, and are not suitable for all clients. Engagement in these strategies is subject to
additional suitability review, client authorization, and, where applicable, strategy-specific disclosures
provided prior to implementation.
As part of this service, we also provide Comprehensive Financial Planning, which is described in more
detail below. Fees for portfolio management are outlined in Item 5 of this brochure.
Financial Planning
As part of our advisory services, Root Financial Partners, LLC (“Root”) provides comprehensive
financial planning tailored to each client’s unique circumstances. This process involves an in-depth
evaluation of your current and future financial position, considering known variables to project future
cash flows, asset values, and withdrawal strategies. Projections and analyses are based on
assumptions and information provided by the client and are inherently uncertain; actual results may
differ materially.
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We take a holistic approach and examine how various components of your financial life affect one
another. Clients who engage in this service will receive a written or electronic financial plan outlining
actionable recommendations designed to help meet their stated goals.
The financial plan may address any of the following areas, depending on your needs and the scope
of engagement:
● Business Planning: For business owners or those considering starting or exiting a business, we
provide general education on financial considerations relevant to business ownership. We do
not recommend specific business entity types or offer legal structuring advice, but can help
clients understand the financial implications of different choices and coordinate with outside
professionals as needed.
● Cash Flow and Debt Management: We assess your income, expenses, and liabilities to
evaluate surpluses or deficits and recommend strategies for budgeting, debt prioritization,
and maintaining appropriate cash reserves.
● College Savings: We project education funding needs and recommend savings strategies,
while also helping clients assess financial aid considerations and gifting strategies for children
or grandchildren.
● Employee Benefits Optimization: We analyze your employer-sponsored benefit options
(retirement plans, health insurance, stock plans, etc.) to help you make informed decisions.
Business owners may also receive guidance on structuring benefit programs from a financial
planning perspective.
● Estate Planning: We review your current estate documents (wills, trusts, powers of attorney,
etc.) and provide education on how these tools may fit into your broader financial plan. Root
does not provide legal services or draft estate planning documents. We may coordinate with
your estate attorney and can provide referrals upon request. Any coordination with outside
professionals is performed at the client’s request.
● Financial Goal Setting: We help you identify and prioritize short- and long-term goals, define
target timelines and budgets, and develop savings strategies aligned with those objectives.
●
Insurance and Risk Management: We evaluate your existing insurance coverage (life,
disability, long-term care, liability, and property) and provide guidance on addressing any
gaps based on your financial exposure and goals. We do not sell insurance products or
receive commissions.
●
Investment Analysis: We develop investment strategies that align with your risk tolerance,
time horizon, and goals. This may include asset allocation guidance, retirement plan reviews,
and education on investment vehicles and tax implications. Investment strategies are
discussed further in Item 8.
● Retirement Planning: Our retirement analysis includes projections to evaluate whether you're
on track for your retirement goals. We may recommend changes—such as saving more,
adjusting investment risk, or changing retirement age—to improve outcomes. For clients near or
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in retirement, we offer guidance on tax-efficient withdrawal strategies and cash flow planning.
Any tax-related considerations are provided for planning purposes only and do not constitute
tax advice.
● Risk Management: We analyze potential financial threats from unexpected events such as
premature death, disability, or long-term care needs, and offer recommendations for
mitigating those risks through insurance or other strategies.
● Tax Planning Strategies: We may provide guidance on tax-efficient savings and withdrawal
strategies as part of your financial plan. However, Root does not provide tax advice, and we
recommend clients consult a qualified tax professional before implementing any tax-related
strategy. We are happy to coordinate with your CPA and can participate in joint planning
conversations at your request. Root does not prepare or file tax returns
Vista Private Wealth
Root offers a dedicated private wealth division, known as Vista, for clients with advanced planning
needs. Vista is designed for households with a minimum of $10 million in investable assets managed
by Root and is focused on serving clients with multigenerational wealth, concentrated equity
positions, closely held businesses, or complex estate coordination needs. Eligibility for Vista services
is determined by Root based on a combination of asset levels, complexity of planning needs, and
overall client circumstances
In certain cases, Root may offer Vista services to clients who do not yet meet the minimum asset
threshold but have complex financial needs and a high likelihood of meeting the minimum over time,
such as through illiquid holdings or anticipated liquidity events. In these cases, minimum annual fee
requirements may apply, as described in Item 5. Any such minimum fee requirements will be outlined
in the client’s advisory agreement and disclosed prior to engagement
While Root does not provide legal or tax advice, we coordinate closely with clients’ outside
professionals to align investment management with broader estate, tax, and business planning
strategies. Root’s role is limited to providing investment and financial planning guidance and does
not include the preparation of legal documents or tax filings.
Comprehensive Financial Planning
In limited circumstances, Root may offer financial planning as a standalone service for clients who
may not require investment management. This ongoing engagement is delivered under a monthly
subscription model, giving clients continuous access to a dedicated planner. This service does not
include discretionary investment management unless separately agreed to in writing
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Under this arrangement, clients work one-on-one with a planner throughout the year. The process
begins by helping the client define their goals, values, and financial priorities. Clients are asked to
provide information across key areas of their financial life, including net worth, cash flow, insurance,
employee benefits, retirement planning, investments, education funding, and estate planning.
Based on this information, we develop a personalized financial plan that is delivered in a written or
electronic format. The planner will review the plan with the client and, if needed, hold follow-up
meetings to support
implementation.
Implementation support
is
limited to guidance and
coordination and does not include execution of transactions unless covered under a separate
advisory agreement.
Throughout the year, the client’s financial situation and goals are monitored. We conduct periodic
check-ins and offer guidance to ensure action steps are being carried out. An annual review is
conducted to evaluate whether the plan remains appropriate and to make any necessary updates.
Root does not provide legal or tax advice, and clients are encouraged to consult with qualified
professionals as needed. We may coordinate with your CPA or attorney at your request. Root does
not prepare legal documents or file tax returns.
Retirement Plan Services
Root Financial Partners, LLC (“Root”) does not offer standalone retirement plan consulting services.
However, in limited circumstances, we may provide support related to an employer-sponsored
retirement plan when an existing financial planning or investment management client is also a
business owner. Root does not provide services directly to retirement plans unless expressly agreed
to in writing.
In these cases, our guidance may include general education or support related to the client’s
company retirement plan, including investment options, plan design considerations, or participant
education. Any such services are incidental to the broader financial planning engagement and are
provided solely for the benefit of the client as an individual. Root does not exercise discretionary
authority over plan assets unless specifically authorized in writing
When applicable, and if the client’s business retirement plan is governed by the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”), Root may acknowledge fiduciary status under
Section 3(21) or 3(38) of ERISA in accordance with the terms of a written agreement. These services
are offered only in connection with an individual client’s comprehensive relationship with our firm and
are not marketed or contracted independently. The scope of fiduciary responsibility, if any, is limited
to the services expressly described in the applicable agreement.
Educational Seminars and Speaking Engagements
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We may provide educational seminars on an “as announced” basis for members of the general
public, industry professionals, and other groups seeking general information on investments, financial
planning and other areas of personal finance. The content of these seminars may vary depending on
the topic and intended audience. These seminars are purely educational in nature and do not involve
the sale of any investment products. Information presented is general and impersonal, is not based
on any individual’s financial circumstances, and does not constitute individualized investment advice.
Attendance at an educational seminar does not create an advisory relationship with Root Financial
Partners, LLC.
Root may charge a registration or attendance fee for participation in certain educational seminars.
Any such fees are charged solely for access to the educational content and are not contingent on the
purchase of any investment products or advisory services. Fees, if applicable, will be disclosed in
advance of registration. Root does not receive any additional direct or indirect compensation in
connection with these seminars beyond the disclosed attendance fees.
Educational Academies
Root Financial Partners, LLC offers two paid, online educational programs: the Retirement Planning
Academy and the Early Retirement Academy. These programs are designed for individuals seeking to
learn general financial planning concepts on a self-directed basis. Each academy includes access to
financial planning software, along with a series of pre-recorded video lessons covering topics such as
retirement planning, budgeting, investment education, and tax strategy. Any outputs or projections
generated through the software are for educational and illustrative purposes only and are based on
user-entered assumptions.
These academies are educational in nature and do not include any personalized investment advice,
individual financial planning services, or access to advisory personnel. Participation in either
academy does not create an advisory relationship with Root Financial Partners, LLC, and users are not
required to sign an investment advisory agreement. Root Financial does not collect sufficient
personal financial information in connection with the academies to render individualized advice, and
all information provided is intended to be general and impersonal. Participation in an academy does
not guarantee any particular financial outcome.
Individuals who enrolled in an academy prior to September 1, 2025 are billed an annual enrollment fee
of $30. Individuals enrolling on or after September 1, 2025 are subject to a $399 enrollment fee. Fees
are charged for access to the educational content and software and are subject to change for future
enrollees.
Advisory clients of Root Financial may also choose to enroll in one of the academies, but access to
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the academy is separate from any advisory services provided and is billed independently. Fees paid
for academy enrollment are separate from and in addition to any advisory fees described in Item 5.
Enrollment in an academy does not entitle the participant to ongoing advisory services or fiduciary
oversight from the firm.
Client Tailored Services and Client Imposed Restrictions
We offer a consistent suite of advisory services to our clients; however, the specific services provided
may vary based on the client’s needs and engagement terms. Specific client financial plans and their
implementation are dependent upon the client’s Investment Policy Statement, which outlines each
client’s current situation (including income, tax considerations, and risk tolerance) and is used to
construct a client-specific plan to aid in the selection of a portfolio that aligns with stated objectives.
Clients may impose reasonable restrictions on investing in certain securities, asset classes, industries,
or investment strategies. Such restrictions may limit the universe of available investments and may
affect portfolio diversification or performance.
Wrap Fee Programs
Root does not sponsor or participate in a wrap fee program, as defined by the Securities and
Exchange Commission.. Clients pay advisory fees to Root separately from brokerage, transaction, and
custodial charges assessed by their account custodian. Because these costs are not bundled into a
single, inclusive fee, Root’s services do not meet the definition of a wrap fee program under Form ADV
instructions.
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Item 5: Fees and Compensation
The investment advisory contract entered into with Root may be terminated by the client within
five (5) business days of signing the contract without penalty, and with a full refund of any fees
paid. The manner in which Root is compensated depends on the type of advisory service
provided. Please review the fee and compensation information below.
Investment Management Services
Client relationships are subject to a minimum annual advisory fee of $10,000. If the advisory fees
calculated under the firm’s standard asset-based fee schedule total less than $10,000 on an
annualized basis, the minimum fee will apply. The minimum annual advisory fee applies once the
advisory relationship is established, unless otherwise agreed to in writing.
For clients whose billable assets do not generate fees that meet the minimum, one of the following
billing methods will be selected at the start of the relationship:
1. Monthly Account Billing (Default): The minimum fee is billed in arrears, prorated monthly, and
deducted from managed accounts.
2. Direct Invoicing: The minimum fee is billed quarterly, in advance, via manual invoice to the
client.
Unless direct invoicing is specifically elected during onboarding, monthly billing from managed
accounts will apply by default. Once the client’s calculated advisory fees exceed the $10,000
minimum on an annualized basis, billing will automatically convert to the firm’s standard method,
monthly in arrears via account debit, and direct invoicing will be discontinued. No amendment to the
advisory agreement will be required. This conversion will occur only as permitted under the terms of
the advisory agreement
In cases where asset-based billing is not available and the scope of planning materially exceeds that
of a standard advisory relationship, the firm may recommend engagement under its flat-fee
planning model. In such instances, a separate agreement will outline the applicable flat fee and
scope of services.
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Our standard advisory fee is based on the market value of the assets under management and is
calculated as follows:
Account Value
Annual Advisory Fee
$0 - $1,000,000
1.00%
$1,000,001 - $5,000,000
0.75%
$5,000,001 - $10,000,000
0.50%
$10,000,001 - $25,000,000
0.40%
$25,000,001 - $50,000,000
0.30%
$50,000,001 - $100,000,000
0.25%
$100,000,001 and Above
0.20%
The annual fees are pro-rated and charged in arrears on a monthly basis. The monthly advisory fee is
based upon the average daily account value of the previous month, and is a blended fee that is
calculated by assessing the percentage rates using the account values as shown in the above chart;
this results in a combined weighted fee. For example, an account valued at $5,000,000 would pay an
annual effective blended fee of approximately 0.80%. Fees are adjusted for intra-month cash flows
and prorated using calendar days. Terminated accounts are refunded on a daily-prorated basis.
Certain legacy clients and family members of Root associates may pay different fees on alternate
billing cycles. No increase in the annual fee shall be effective without agreement from the client by
signing a new agreement or amendment to their current advisory agreement. Such fee
arrangements are negotiated on an individual basis and are not discriminatory in nature.
When Root recommends the use of a sub-adviser, clients will be responsible for paying both Root’s
advisory fee and the sub-adviser’s fee. These fees are separate and distinct. Root does not receive
any portion of the sub-adviser’s fee. The sub-adviser’s compensation, billing practices, and
applicable minimums will be disclosed in their Form ADV Part 2A, which will be provided to clients
prior to engagement. Root’s fee for ongoing advisory services is described above and will be fully
disclosed in the client agreement. All fees will be discussed with and agreed to by the client in
advance.
Advisory fees are directly debited from client accounts, with exceptions at Root's discretion. For legacy
quarterly clients, accounts initiated or terminated during a calendar quarter will be charged a
prorated fee based on the amount of time remaining in the billing period. For monthly arrears clients,
fees will be charged up to date of notice. An account may be terminated with written notice at least
15 calendar days in advance. Upon termination of the account, any unearned fee will be refunded to
the client. Comprehensive Financial Planning is included with this Service.
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When Root recommends the use of third-party investment managers or separately managed
account strategies, clients are responsible for paying both Root’s advisory fee and the fees charged
by the third-party manager. Such fees are separate and in addition to Root’s advisory fee. Any
applicable manager fees, minimums, and billing practices will be disclosed in the manager’s Form
ADV or other applicable disclosure documents provided to the client prior to engagement. Root does
not receive compensation from these third-party managers.
Fees for held-away retirement account management are assessed based on the value of assets
under our discretionary management, consistent with other managed accounts. These accounts are
typically billed at the same rate as other portfolio assets, unless otherwise agreed. Fees are not
deducted directly from the held-away account and are instead invoiced or deducted from another
linked account, as authorized by the client.
In cases where advisory services are provided for investments held outside of traditional managed
accounts, such as private funds or alternative vehicles, Root may assess a fee based on the notional
value or oversight scope of such positions. These fees may be invoiced separately or integrated into
the client’s comprehensive billing arrangement with current brokerage accounts, and will be
disclosed in advance.
Financial Planning (Fixed Fee)
In specialized cases determined by Root, financial planning services may be offered on a fixed fee
basis. The fee is determined based on the scope and complexity of the engagement and will be
agreed upon in writing before any work begins. Fixed fees generally range between $2,000 and
$65,000, though fees outside of this range may apply in certain complex situations. Unless otherwise
negotiated, the full fixed fee is due at the beginning of the engagement; however, Root will not collect
fees in excess of $500 for services to be rendered more than six months in advance.
Fees may be paid via electronic funds transfer or credit card. Root does not pass through any
payment processing or convenience fees to clients. If the client terminates the agreement more than
five (5) business days after signing, Root will retain up to 50% of the fixed fee to the extent services
have been rendered, and any unearned portion will be refunded
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Financial Planning (Hourly Fee)
Financial planning services are offered at an hourly rate ranging from $250 to $750 per hour,
depending on the scope and complexity of the engagement. Fees accrue as services are performed
and are due at the completion of the engagement. In the event of early termination by the client, any
fees for hours already worked will be due; however, the client retains the right to terminate the
agreement within five (5) business days of execution without penalty and receive a full refund of any
fees paid. Fees for this service may be paid by electronic funds transfer or check.
Retirement Plan Services
Account Value
Annual Advisory Fee
$0- $500,000
1.25%
$500,001 - $3,000,000
1.00%
$3,000,001 - $5,000,000
0.75%
$5,000,001 - $10,000,000
0.50%
$10,000,001 and Above
0.25%
Platform fees apply to services including 3(38) investment management, 3(16) fiduciary and plan
administrator services, recordkeeping and TPA services, custodian and trustee services, and named
fiduciary oversight. These fees are deducted directly from plan assets by the custodian and remitted
to the appropriate service providers, including Root Financial Partners, LLC (“Root”).
Root’s advisory fees are calculated on a blended basis, using predefined asset tiers as shown in the
applicable fee schedule. For example, a plan with $4,000,000 in assets would pay an effective fee of
approximately 0.97%. Fees are assessed quarterly
in arrears. Plans that receive additional
contributions exceeding $25,000 during the quarter will incur a prorated advisory fee on those
amounts.
Upon termination of services, no refunds are issued, as fees are billed in arrears for services already
rendered. The employer will receive a final prorated invoice for advisory services and, if applicable, for
any third-party administration fees.
Platform fees charged by third-party providers are separate from Root’s advisory fees. Root does not
receive compensation or share in any portion of these third-party fees. Additionally, Root is not
contractually obligated to maintain relationships with any specific TPA or recordkeeper, and therefore
no material conflicts of interest are present as a result of these arrangements.
Retirement Academy Fees
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Each of our online academies is offered for a one-time, non-recurring enrollment fee that provides
ongoing access to the video content and associated planning software, subject to the terms
disclosed at the time of enrollment.
For individuals enrolling on or after September 1, 2025, the Retirement Planning Academy is available
for a one-time enrollment fee of $399, and the Early Retirement Academy is available for a one-time
enrollment fee of $399.
Individuals who enrolled in an academy prior to September 1, 2025 are subject to a legacy pricing
structure, which may differ from current enrollment fees.
Payments are processed securely via credit or debit card through the respective academy websites.
Root Financial Partners, LLC does not retain or have access to client payment information and does
not have access to client funds in connection with these payments.
Other Types of Fees and Expenses
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which may be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes related to
brokerage accounts and securities transactions. Mutual fund 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 fee, and we shall not receive any portion of
these commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker- dealers
for client’s transactions and determining the reasonableness of their compensation (e.g.,
commissions).
We do not accept compensation for the sale of securities or other investment products including
asset-based sales charges or service fees from the sale of mutual funds.
Clients engaging in options strategies or investing in private vehicles may incur additional expenses,
such as custodial processing fees, subscription document handling, or margin-related interest. These
costs are imposed by third-party providers and are in addition to Root’s advisory fees. Root does not
receive any portion of these expenses. Any such strategies are implemented only pursuant to client
authorization and applicable advisory agreements.
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Item 6: Performance-Based Fees and Side-By-Side
Management
Root does not offer performance-based fees and does not engage
in side-by-side
management. All advisory fees are based on asset values, fixed fees, or hourly charges, as
applicable, and do not vary based on the performance of client accounts.
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Item 7: Types of Clients
Root provides financial planning and portfolio management services to individuals, high
net-worth individuals, pension and profit-sharing plans, charitable organizations, trusts,
estates, and small businesses.
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Item 8: Methods of Analysis, Investment Strategies and Risk of
Loss
Our primary methods of investment analysis are fundamental, technical, cyclical and charting
analysis. Each method involves certain risks, which are described below.
Fundamental analysis involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience, and
expertise of the company’s management, and the outlook for the company’s industry. The resulting
data is used to measure the true value of the company’s stock compared to the current market
value. The risk of fundamental analysis is that information obtained may be incorrect and the
analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s
value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an
effort to pick sectors that may outperform market indices. However, there is no assurance of accurate
forecasts or that trends will develop in the markets we follow. In the past, there have been periods
without discernible trends and similar periods will presumably occur in the future. Even where major
trends develop, outside factors like government intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can
translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic
market, a technical method may fail to identify trends requiring action. In addition, technical methods
may overreact to minor price movements, establishing positions contrary to overall price trends,
which may result in losses. Finally, a technical trading method may underperform other trading
methods when fundamental factors dominate price moves within a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and
trends based upon business cycles. Economic/business cycles may not be predictable and may
have many fluctuations between long term expansions and contractions. The lengths of economic
cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the
difficulty in predicting economic trends and consequently the changing value of securities that would
be affected by these changing trends.
Charting analysis involves the gathering and processing of price and volume information for a
particular security. This price and volume information is analyzed using mathematical equations. The
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resulting data is then applied to graphing charts, which is used to predict future price movements
based on price patterns and trends. Charts may not accurately predict future price movements.
Current prices of securities may not reflect all information about the security and day-to-day
changes in market prices of securities may follow random patterns and may not be predictable with
any reliable degree of accuracy.
Passive Investment Management
We primarily employ a passive investment management approach. Passive investing involves
constructing portfolios composed of various distinct asset classes, which are allocated in a way that
seeks to achieve an optimal balance of correlation, risk, and return. To capture the performance of
these asset classes, we use funds that track market indexes—typically index mutual funds or
exchange-traded funds (ETFs).
Passive investment management is generally characterized by low portfolio costs (due to the low
internal expenses of the underlying funds), minimal trading activity (which reduces transaction
costs), and greater tax efficiency (as the underlying funds and overall portfolio experience lower
turnover).
In contrast, active investment management relies on a portfolio manager or team using specific
strategies or techniques to try to outperform the broader market or a designated benchmark.
However, academic research generally suggests that many active managers fail to outperform their
benchmarks over time.
We may also provide advice regarding investments in private pooled investment vehicles and
separately managed accounts offered by third-party providers. These strategies may involve limited
liquidity, minimum investment thresholds, and complex tax considerations. In these cases, we
conduct due diligence on the investment structure and strategy and monitor the allocation on an
ongoing basis as part of our advisory relationship.
Certain strategies may utilize options or other derivative instruments as part of a portfolio allocation.
These instruments involve additional risks, including leverage, volatility, and the potential for losses in
excess of the invested amount. Clients should be aware of the complexity of these investments and
the need for regular review and monitoring. Such strategies are implemented only where appropriate
and pursuant to client authorization and the applicable advisory agreement.
We may utilize unaffiliated third-party investment managers in connection with certain held-away
retirement accounts, including employer-sponsored 401(k) plans, where permitted by the plan
provider. Through client authorization, Root coordinates with such managers to provide investment
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recommendations or model-based allocation guidance for these accounts. Implementation of any
changes is subject to the rules, capabilities, and constraints of the applicable retirement plan and
plan provider.
Root does not have custody of these assets, as all assets remain held by the plan provider or plan
custodian, and Root does not have the ability to withdraw funds. Held-away retirement accounts may
be considered as part of the client’s overall asset allocation, portfolio review, and financial planning
process. Fees for services related to held-away accounts are disclosed in advance and billed in
accordance with the client’s advisory agreement.
Long/Short Investment Strategies
In certain circumstances, client assets may be allocated to separately managed account (“SMA”)
strategies that employ long/short investment techniques. These strategies seek to gain exposure to
securities expected to appreciate in value while simultaneously taking short positions in securities
expected to decline. Short sales involve borrowing securities and selling them with the expectation of
repurchasing them at a later date, which may result in losses exceeding the initial investment if the
price of the security increases.
Long/short strategies may involve the use of leverage, derivatives, or other non-traditional
investment techniques, and may experience greater volatility, increased transaction costs, and
periods of underperformance relative to long-only investment strategies. These strategies may not
be suitable for all clients and may underperform during certain market environments.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment
which you should be prepared to bear. Many of these risks apply equally to stocks, bonds,
commodities and any other investment or security. Material risks associated with our investment
strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall
because of a general market decline, reducing the value of the investment regardless of the
operational success of the issuer’s operations or its financial condition.
Strategy Risk: Root’s investment strategies and/or investment techniques may not work as intended.
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Small and Medium Cap Company Risk: Securities of companies with small and medium market
capitalizations are often more volatile and less liquid than investments in larger companies. Small
and medium cap companies may face a greater risk of business failure, which could increase the
volatility of a client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other
strategies. A high portfolio turnover would result in correspondingly greater brokerage commission
expenses and would result in the distribution of additional capital gains for tax purposes. These
factors may negatively affect the account’s performance.
Limited Market Risk: Certain securities may be less liquid (harder to sell or buy) and their prices may
at times be more volatile than at other times. Under certain market conditions we may be unable to
sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset classes, industries,
sectors or types of investment. From time to time these strategies may be subject to greater risks of
adverse developments in such areas of focus than a strategy that is more broadly diversified across
a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value
may fall below par value or the principal investment. The opposite is also generally true: bond prices
generally rise when interest rates fall. In general, fixed income securities with longer maturities are
more sensitive to these price changes. Most other investments are also sensitive to the level and
direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or
the securities’ claim on the issuer’s assets and finances.
Inflation Risk: Inflation may erode the buying-power of your investment portfolio, even if the dollar
value of your investments remains the same.
Risks Associated with Securities
Apart from the general risks outlined above, which apply to all types of investments, specific securities
may have other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s
bankruptcy or restructuring, could lose all value. A slower-growth or recessionary economic
environment could have an adverse effect on the price of all stocks.
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Corporate Bonds are debt securities issued to borrow money. Generally, issuers pay investors
periodic interest and repay the amount borrowed either periodically during the life of the security
and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon
bonds, which do not pay current interest, but rather are priced at a discount from their face values
and their values accrete over time to face value at maturity. The market prices of debt securities
fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market
prices of debt securities decline when interest rates rise and increase when interest rates fall. The
longer the time to a bond’s maturity, the greater its interest rate risk.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes,
including the construction of public facilities. Municipal bonds pay a lower rate of return than most
other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative
after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket.
Investing in municipal bonds carries the same general risks as investing in bonds in general. Those
risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit
risk, and liquidity and valuation risk.
Municipal SMA strategies may involve increased exposure to issuer-specific or state-specific credit
events, reduced
liquidity
in certain market environments, call and reinvestment risk, and
concentrated sector or geographic exposures determined by the manager. These risks may cause
the portfolio to behave differently from broadly diversified municipal bond funds.
Options and other derivatives carry many unique risks, including time-sensitivity, and can result in
the complete loss of principal. While covered call writing does provide a partial hedge to the stock
against which the call is written, the hedge is limited to the amount of cash flow received when
writing the option. When selling covered calls, there is a risk the underlying position may be called
away at a price lower than the current market price.
Strategies that employ short selling, leverage, or derivatives involve additional risks, including the
potential for losses that exceed the amount invested, increased volatility, liquidity constraints, and the
possibility that hedging techniques may be ineffective. These strategies may behave differently from
traditional equity and fixed-income markets and may not achieve their intended objectives.
Exchange Traded Funds’ prices may vary significantly from the Net Asset Value due to market
conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected.
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Investment Company and Fund Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition,
the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk
arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are
also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or
below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage
ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such
action appropriate, the shares are de-listed from the exchange, or the activation of market-wide
“circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally.
Root has no control over the risks taken by the underlying funds in which clients invest.
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Item 9: Disciplinary Information
Criminal or Civil Actions
Neither Root nor its management persons have been involved in any criminal or civil actions that
are material to a client’s or prospective client’s evaluation of Root’s advisory business.
Administrative Enforcement Proceedings
Neither Root nor
its management persons have been
involved
in any administrative
enforcement proceedings before a regulatory body that are material to a client’s or prospective
client’s evaluation of Root’s advisory business.
Self-Regulatory Organization Enforcement Proceedings
Neither Root nor its management persons have been involved in any legal or disciplinary events
that are material to a client’s or prospective client’s evaluation of Root’s advisory business or the
integrity of its management.
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Item 10: Other Financial Industry Activities and Affiliations
No employees of Root Financial Partners, LLC (“Root”) are registered, nor do they have pending
applications to register, as broker-dealers or registered representatives of a broker-dealer.
Similarly, no employees are registered or seeking registration as futures commission merchants,
commodity pool operators, or commodity trading advisors.
Root does not have any related parties or affiliated entities. As such, we have no business
relationships with affiliates to disclose.
In certain cases, Root acts as a solicitor for unaffiliated third-party registered investment advisers
and receives cash compensation for client referrals. These solicitation arrangements are governed by
written agreements and are disclosed to each referred client at or before the time of the referral. Root
does not provide investment advisory services to the referred individuals or entities and does not
share in the advisory fees charged by the third-party adviser beyond the disclosed solicitation
compensation.
To help mitigate potential conflicts of interest associated with these solicitation arrangements, Root
ensures that:
● Clients are informed in writing of the solicitor relationship, the nature of the compensation
received by Root, and any material conflicts of interest at or before the time of the referral.
● The decision to engage a referred adviser is entirely at the discretion of the client.
● Root’s solicitation activities comply with applicable SEC
regulations,
including
the
requirements of Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended.
Recommendations or Selections of Other Investment Advisers
As noted in Item 4 of this Brochure, Root may recommend clients engage sub-advisers to
manage their accounts. In such cases, Root does not share in the sub-adviser’s fee. Root’s
advisory fee is separate and in addition to the sub-adviser’s compensation (as described in
Item 5) and will be fully disclosed prior to engagement. Clients are not obligated, contractually
or otherwise, to engage any sub-adviser recommended by Root. Root will only recommend
sub-advisers who are appropriately registered or licensed as investment advisers.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best
interests of each client. Our clients entrust us with their funds and personal information, which in turn
places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code
of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of
Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc. and accepts the
obligation not only to comply with the mandates and requirements of all applicable laws and
regulations but also to take responsibility to act in an ethical and professionally responsible manner
in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with
each of its specific provisions will not shield associated persons from liability for personal trading or
other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics'
Principles is outlined below:
●
Integrity: Associated persons shall offer and provide professional services with integrity.
● Objectivity: Associated persons shall be objective in providing professional services to
clients.
● Competence: Associated persons shall provide services to clients competently and maintain
the necessary knowledge and skill to continue to do so in those areas in which they are
engaged.
● Fairness: Associated persons shall perform professional services in a manner that is fair and
reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of
interest in providing such services.
● Confidentiality: Associated persons shall not disclose confidential client information without
the specific consent of the client unless in response to proper legal process, or as required by
law.
● Professionalism: Associated persons’ conduct in all matters shall reflect credit of the
profession.
● Diligence: Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we
require all firm access persons to attest to their understanding of and adherence to the Code of
Ethics at least annually. Our firm will provide a copy of its Code of Ethics to any client or prospective
Page 26
client upon request.
Investment Recommendations
Involving a Material Financial
Interest and
Conflicts of Interest
Neither our firm, its associates or any related person is authorized to recommend to a client, or effect
a transaction for a client, involving any security in which our firm or a related person has a material
financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts
of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we
recommend to clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest
involving the firm or personal trading, our policy may require that we restrict or prohibit associates’
transactions in specific reportable securities transactions. Any exceptions or trading pre-clearance
must be approved by the firm principal in advance of the transaction in an account, and we maintain
the required personal securities transaction records per regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, the firm or its related persons may buy or sell securities for their personal accounts
at or around the same time that transactions are effected for clients.
The firm maintains policies and procedures designed to prevent conflicts of interest and the misuse
of material non-public information in connection with personal trading. These controls include, as
applicable, pre-clearance requirements, restricted
lists, transaction reviews, and post-trade
monitoring.
Personal securities transactions are reviewed to ensure that client interests are not disadvantaged
and that personal trading does not improperly benefit related persons at the expense of clients.
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Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
Root Financial Partners does not have any affiliation with broker-dealers. Specific custodian
recommendations are made based on the client’s needs and the overall quality of services provided
by the custodian. We evaluate custodians based on factors such as service offering, technology,
trading capabilities, reputation, financial strength, and cost.
When providing advisory services for held-away retirement accounts, such as employer-sponsored
401(k) plans, Root provides investment recommendations or model-based allocation guidance
pursuant to client authorization and subject to the constraints of the applicable plan provider. Root
does not select or change the plan custodian, and implementation of any recommendations is
subject to the plan’s available investment options and administrative processes.
Research and Other Soft-Dollar Benefits
We may receive certain benefits from custodians we recommend, such as Charles Schwab and
Altruist, including access to technology platforms, research, practice management resources, and
other tools that help us manage client accounts. These benefits are not considered “soft dollar”
arrangements under Section 28(e) of the Securities Exchange Act of 1934, as we do not enter into
formal soft dollar arrangements with any custodian.Brokerage for Client Referrals
We do not receive client referrals or other benefits from any broker-dealer or third party in exchange
for recommending them to clients.
Clients Directing Which Broker/Dealer/Custodian to Use
We generally recommend that clients use a specific custodian; however, clients may request to
custody their assets at a custodian of their choice or direct us to use a particular broker-dealer. In
such cases, we may not be able to achieve the most favorable execution of client transactions, which
may result in higher costs for the client.
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The Custodians and Brokers We Use (Altruist)
Root may recommend Altruist Financial LLC, an unaffiliated SEC-registered broker-dealer and
FINRA/SIPC member, as
introducing broker
to Apex Clearing Corporation, an unaffiliated
SEC-registered broker-dealer and FINRA/SIPC member, for custody and brokerage services. Altruist
offers fully digital account opening, commission-free trading, and integration with our internal
technology tools. We do not receive research or other soft dollar benefits from Altruist, nor do we
receive referrals in exchange for using them.
The Custodians and Brokers We Use (Charles Schwab)
We recommend that clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer
and member of SIPC, as the qualified custodian for their investment accounts. Schwab maintains
custody of client assets and facilitates trade execution at our direction.
Root is independently owned and operated and is not affiliated with Schwab. While clients are not
required to use Schwab, most choose to do so due to its strong service offering, technology, and
integration with our systems.
As part of our onboarding process, we assist clients with account setup and paperwork required to
open and fund Schwab accounts. All accounts are opened in the client’s name, and no account is
opened without the client’s review and signature on Schwab’s required documentation. The client
enters into a direct custodial relationship with Schwab.
Although Schwab holds client assets, we may be deemed to have limited custody under SEC rules
due to our authority to deduct advisory fees (see Item 15 – Custody).
How we select brokers/custodians
We strive to recommend custodians and broker-dealers that provide overall value to our clients
based on factors such as:
● Execution quality and reliability
● Breadth of investment options
● Cost (e.g., commission rates, account fees)
● Custody and operational support
● Availability of technology and reporting tools
● Financial strength and reputation
● Access to resources that support our business and client service
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Your brokerage and custody costs
Custodians may charge clients directly for certain transactions or services. Schwab, for example, is
compensated through commissions and by earning interest on uninvested cash balances. Some
trades, such as many mutual funds and ETFs, may be commission-free. Altruist does not charge
clients commissions for most trades and may receive compensation through clearing arrangements
with Apex.
Products and services available to us from Schwab
Schwab Advisor Services™ provides institutional services to Root, including custody, trading, reporting,
and practice management resources. Some services benefit the client directly, such as access to
investment products and trading support. Other services may benefit Root, such as technology tools,
compliance resources, and educational content. Schwab makes these services available at no
additional cost to Root, creating a potential conflict of interest. However, we believe that
recommending Schwab is in the best interest of our clients based on the overall quality, cost, and
scope of available services.
Services that benefit you
Schwab’s institutional brokerage services include access to a broad range of investment products,
trade execution, and custody of client assets. Some investment products available through Schwab
may not otherwise be accessible to us or may require significantly higher minimum investments.
These services generally benefit you and your account by supporting effective account management
and access to investments.
Services that may not directly benefit you
Schwab also provides products and services that benefit our firm but may not directly benefit your
account. These offerings help us manage and administer client accounts more efficiently and
include:
●
Investment research from Schwab and third-party providers (used across client accounts,
including those not held at Schwab)
● Technology and software that:
○ Provide access to client account data (trade confirmations and statements)
○ Facilitate trade execution and aggregation
○ Offer pricing and market data
○ Enable fee deduction from client accounts
○ Support back-office, recordkeeping, and reporting functions
While these services improve our operational efficiency, they may not result in direct cost savings or
Page 30
performance enhancements for your individual account.
Services that generally benefit only us
Schwab may also provide services designed to support the growth and management of our business.
These include:
● Educational conferences and events
● Consulting services on topics such as technology, compliance, and business operations
● Practice management publications and resources
These services are made available to us regardless of whether client assets are held at Schwab.
Because we receive these services at no cost, they represent a potential conflict of interest. However,
our recommendation to use Schwab as custodian is based on the overall value of services provided,
including quality, reliability, and cost, not solely on the availability of business support services. We
believe this recommendation is in the best interests of our clients.
Aggregating (Block) Trading for Multiple Client Accounts
To promote efficiency and seek best execution, we may aggregate multiple client orders when buying
or selling the same securities (a process known as block trading). When trades are aggregated:
● Each account receives an average execution price
● Transaction costs are shared proportionally among participating accounts
● Allocation is typically based on account size and not on performance or fee structure
Firm-owned or employee accounts may participate in block trades alongside client accounts but will
not receive preferential treatment.
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Item 13: Review of Accounts
Client accounts managed under Root’s Investment Management service are reviewed on a regular
basis by a Root Investment Adviser Representative (IAR), no less than annually. Account reviews are
conducted internally and are not provided to clients unless requested or otherwise agreed. Accounts
not managed on a discretionary basis, such as held-away retirement accounts or planning-only
engagements, are reviewed in accordance with the scope of the applicable advisory agreement.
Reviews consider the client’s stated investment objectives, risk tolerance, and any specific restrictions
or preferences. In addition to scheduled reviews, accounts may be reviewed more frequently if
triggered by significant events, such as:
● Material changes to a client’s financial situation or investment goals
● Market volatility or significant account performance deviations
● Changes to client-imposed restrictions or investment preferences
● Client requests for portfolio adjustments
● Firm-initiated investment strategy updates
Clients will receive ongoing reporting directly from their chosen custodian:
For clients using Charles Schwab:
Clients receive electronic or paper trade confirmations for each transaction executed in their
accounts, unless they have opted to suppress individual confirmations. Schwab also provides
monthly or quarterly account statements and annual tax documents (e.g., Form 1099) summarizing
all account activity, including dividends, interest, and realized gains or losses.
For clients using Altruist:
Clients receive digital trade confirmations and account statements through the Altruist client portal.
Altruist provides monthly statements and annual tax documents detailing account activity. Clients
may adjust communication preferences within their account settings.
Regardless of custodian, clients are encouraged to review all statements carefully and to contact
Root with any questions or discrepancies.
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Item 14: Client Referrals and Other Compensation
Root does not receive any economic benefit, directly or indirectly, from any third party in exchange for
providing specific investment advice to our clients.
However, we do have relationships that may result in indirect economic benefits, as outlined below:
● Altruist: Altruist Financial LLC earns revenue from brokerage accounts opened through the
Altruist platform. Separately, Altruist Corp receives fees from Root for access to the Altruist
technology platform. In some cases, Altruist LLC may also receive Model Marketplace fees
from Root or directly from clients who participate in the Altruist LLC Model Marketplace,
according to Root’s instructions. These fees are not contingent upon specific investment
recommendations.
● Charles Schwab: We receive an economic benefit from Schwab in the form of support
products and services it makes available to Root and other independent investment advisers
whose clients maintain accounts at Schwab. These products and services—and the
associated conflicts of interest—are described in Item 12 (Brokerage Practices). The availability
of these resources is not based on us providing specific investment advice or selecting
particular securities.
● Referral Arrangements: Root acts as a solicitor for certain unaffiliated registered investment
advisers and receives cash compensation for client referrals. Root does not provide
investment advisory services to the referred individuals or entities. These solicitation
arrangements are governed by written agreements between Root and the third-party adviser,
and referred clients receive written disclosures regarding the solicitor relationship and
associated compensation at or before the time of the referral, in accordance with Rule
206(4)-1 under the Investment Advisers Act of 1940, as amended.
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Item 15: Custody
Root Financial Partners, LLC (“Root”) does not maintain physical custody of client funds or securities.
However, under SEC rules, Root may be deemed to have custody in limited situations, such as:
● When clients authorize Root to deduct advisory fees directly from their investment accounts
held at a qualified custodian.
● When clients provide Standing Letters of Authorization (“SLOAs”) that permit Root to instruct
the custodian to transfer funds to a third party on their behalf.
●
In each of these cases, Root adheres to the requirements and safeguards outlined in Rule
206(4)-2 under the Investment Advisers Act of 1940 and applicable SEC no-action guidance.
These safeguards include procedures to ensure client authorization, accurate billing practices,
and reliance on qualified custodians for execution and recordkeeping.
For client accounts from which Root deducts advisory fees:
● Clients authorize fee deduction through the advisory agreement and/or custodian account
setup process.
● Fees are calculated in accordance with the client’s advisory agreement and deducted from
their account by the custodian.
● Root does not send invoices to clients or custodians in connection with fee deductions, as
reliance on qualified custodians and client authorization satisfies applicable SEC custody
requirements.
For accounts with SLOAs:
● Root accepts third-party money movement instructions only when the client has provided a
pre-authorized SLOA to the custodian, consistent with SEC guidance.
● Root does not maintain or process these transfers internally but relies on the custodian to
execute instructions in accordance with the client’s standing authorization.
For held-away retirement accounts:
● Root does not have custody of assets in held-away retirement accounts, including
employer-sponsored retirement plans. Assets remain under the custody of the plan sponsor,
plan provider, or plan custodian at all times, and Root does not have the ability to withdraw
client funds from these accounts.
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●
In certain cases, Root acts as a solicitor for an unaffiliated third-party registered investment
adviser that provides advisory services to the held-away retirement account. Under these
arrangements, the third-party adviser may be authorized to deduct its advisory fees directly
from the retirement account in accordance with the client’s agreement with that adviser and
applicable custodial procedures. Root does not deduct advisory fees directly from held-away
retirement accounts.
● Root’s role with respect to held-away retirement accounts is limited to solicitation,
coordination, and consideration of these accounts as part of the client’s overall financial
planning and portfolio oversight process. Clients receive statements directly from the plan
provider or custodian at least quarterly, which reflect all account activity, including any
advisory fees deducted by the third-party adviser.
Clients receive statements directly from the qualified custodian at least quarterly. These custodial
statements detail all disbursements from the account, including any advisory fees paid to Root or
transfers authorized by the client.
We urge clients to carefully review these custodial statements and compare them to any reports or
summaries received from Root. If discrepancies are noted, clients should contact us promptly.
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Item 16: Investment Discretion
For client accounts directly managed by Root under its investment management services, Root
exercises
investment discretion. This means Root
is authorized to determine, without prior
consultation with the client, the securities to be bought or sold and the amount of securities to be
transacted.
Investment discretion is granted to Root at the outset of the advisory relationship. Clients authorize
this discretionary authority by executing a Limited Power of Attorney (LPOA) as part of the account
opening process with the custodian. The discretionary relationship is also described in detail within
the advisory agreement, which is reviewed and signed by the client. Root’s discretionary authority is
exercised in a manner consistent with the client’s stated investment objectives, risk tolerance, and
any reasonable restrictions provided by the client in writing. Clients may impose or modify restrictions
on investing in certain securities or types of securities at any time by notifying Root in writing.
Root does not exercise investment discretion over accounts that are not managed on a discretionary
basis, including held-away retirement accounts or accounts advised by third-party advisers
pursuant to separate agreements.
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Item 17: Voting Client Securities
Root does not accept authority to vote client proxies. Clients retain responsibility for receiving and
voting all proxies and other shareholder communications related to securities held in their accounts,
except as described below.
In certain cases, proxy voting authority may be delegated to an unaffiliated third-party investment
adviser or investment manager utilized in the client’s portfolio, pursuant to the terms of that adviser’s
agreement with the client. Where applicable, such third-party advisers may vote proxies on behalf of
the client in accordance with their own proxy voting policies and procedures, which are disclosed to
the client separately.
Custodians are generally
responsible
for delivering proxy materials and other corporate
communications to clients, in accordance with their account agreements and regulatory obligations.
Clients should ensure that their delivery preferences are set appropriately with the custodian to
receive such materials in a timely manner.
Root does not vote proxies, does not make proxy voting recommendations, and does not supervise or
direct proxy voting decisions made by third-party advisers. However, clients may contact Root with
general, informational questions about a particular proxy or corporate event.
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Item 18: Financial Information
Root Financial Partners, LLC is not required to include a balance sheet with this Brochure because we
do not require or solicit prepayment of advisory fees of more than $1,200 per client, six months or
more in advance.
Root has no financial condition that is reasonably likely to impair its ability to meet contractual or
fiduciary commitments to clients. Additionally, Root has not been the subject of a bankruptcy petition
at any time.
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