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Form ADV Part 2A/2B
Firm Brochure
MARCH 2026
This Brochure provides information about the qualifications and business practices of RTD Financial, “RTD”. If you have any
questions about the contents of this Brochure, please contact us at 215-557-3800. 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.
RTD Financial is registered as an Investment Adviser with the Securities and Exchange Commission. Registration of an Investment
Adviser does not imply a certain level of skill or training.
Additional information about RTD is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the
firm’s identification number 110744
Form ADV Part 2A/2B 03/31/2026
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Form ADV Part 2A/2B 03/31/2026
Form ADV Part 2A
Item 2: Material Changes
This summary reflects changes since our last amendment dated October 1, 2025.
Gavin Maurer, Zachary Merring, Maxine Shevlin, and Lillia Smith have been added as Investment Advisor
Representatives.
Henry Cluver and Peyton Vostenak are no longer Investment Advisor Representatives at RTD.
RTD now offers an Estate Engagement Service.
Item 3: Table of Contents
C O N T E N T S
Item 1: Cover Page
P A G E
1
Item 2: Material Changes
3
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Standard Fees and Compensation
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Item 6: Performance-Based Fees & Side-By-Side Management
15
Item 7: Types of Clients
15
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
15
Item 9: Disciplinary Information
17
Item 10: Other Financial Industry Activities and Affiliations
17
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
17
Item 12: Brokerage Practices
17
Item 13: Review of Accounts
19
Item 14: Client Referrals and Other Compensation
20
Item 15: Custody
20
Item 16: Investment Discretion
21
Item 17: Voting Client Securities
21
Item 18: Financial Information
Form ADV Part 2B - Brochure Supplement
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23-34
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Form ADV Part 2A/2B 03/31/2026
Item 4: Advisory Business
D E S C R I P T I O N O F A D V I S O R Y F I R M
RTD Financial’s registration was granted by the United States Securities and Exchange Commission on June 13,
1983. Current equity ownership of the firm is as follows:
Owns more than ten percent but less than twenty-five percent
•
Jeffrey Alan Weiand, (CRD Number 1414639), Chairman & CEO
• Marc Charles Labadie, (CRD 5126545), Executive Vice President
• Mitchell J. Metz, (CRD Number 1417894), Senior Vice President
• Richard J. Durso, (CRD Number 2772293), President/Chief Financial Officer
Owns five percent but less than ten percent
• Christopher Vassallo, (CRD Number 6125551), Vice President of Client Development
• Rachel F. Moran, (CRD 5680934), Vice President of Personal Wealth Management
Owns less than five percent
• Gregory J. Young, (CRD 4128382), Chief Investment Officer
• William G. Love, (CRD 2785894), Director of Professional Development/Senior Wealth Advisor
• Nicole M. Offerman, (CRD 5050780), Vice President of Employer Retirement Plan Services
• Man-Hyung Hahn, (CRD 7284517), Director of Tax Planning/Senior Financial Planner
• Brent J. Zackon, (CRD 7375058), Director of Financial Planning Standards/Senior Financial Planner
Kevin Cremi is the firm’s Chief Compliance Officer and Chief Operating Officer. The firm is not publicly owned or
traded. There are no indirect owners of the firm. The firm manages each Client’s portfolio on an individualized basis.
Clients may impose restrictions on their accounts. Any restrictions must be reasonable, may impact performance, and
may limit the firm’s ability to implement its strategy. The firm does not sponsor any wrap programs.
As of December 31, 2025, RTD managed assets on a discretionary basis in the amount of $2,701,427,680 and on a
non-discretionary basis, $23,150,793 for a total of $2,724,578,473.
Types of Advisory Services
Personal Wealth Management
Services Typically Available:
L I F E - C E N T E R E D P L A N N I N G
Advisor will help bring order to Client’s financial life.
• Organize.
• Discover.
Advisor will facilitate initial and ongoing listening and discovery to ensure Advisor fully
understands Client’s life story, money history and purpose.
• Prioritize.
Advisor will assist Client in determining the values and goals most important as well as to
help establish a time frame to achieve.
Identify.
•
Advisor will identify where Client’s human capital and financial resources can best be
applied to accomplish short and long-term goals.
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Form ADV Part 2A/2B 03/31/2026
• Monitor.
Advisor will conduct ongoing reviews and updates to monitor progress toward milestones and
alignment with Client’s life’s values.
F I N A N C I A L P L A N N I N G
Advisor will evaluate and analyze Client’s current and projected financial wellness.
• Analyze.
• Recognize.
Advisor will proactively identify challenges and opportunities as they relate to Client’s short
and long-term financial achievements.
Advisor will assist Client with the financial implications of life transitions as they occur.
• Strategize.
• Visualize.
Advisor will assist Client with understanding the impact various scenarios may have on life
goals.
• Advise.
Advisor will provide advice and recommendations that support Client’s short and long-term
goals.
Advisor will utilize techniques to efficiently manage taxes.
• Assess.
• Monitor.
Advisor will periodically update financial planning projections to ensure Client is able to
maintain financial wellness.
I N V E S T M E N T M A N A G E M E N T ( U N D E R A D V I S O R ’ S M A N A G E M E N T )
• Develop.
Advisor will develop an investment strategy that attempts to align Client’s short and
long-term goals with:
▪ Risk Tolerance – the amount of risk Client wants to take.
▪ Risk Capacity – the amount of risk Client needs to take.
Advisor will construct a written Investment Policy Statement.
• Construct.
Advisor will advise and recommend an asset allocation and Investment selection.
• Advise.
Implement.
Advisor will implement all initial and ongoing trading when needed.
•
Advisor will rebalance as per the Investment Policy Statement guidelines.
• Re-balance.
• Re-allocate.
Advisor will reallocate and adjust the portfolio and/or change underlying investments due to
changes in the economy, Client’s objectives, or security performance criteria.
Advisor will attempt to minimize investment related taxes on an ongoing basis.
• Tax Plan.
Advisor will provide quarterly performance reporting.
• Report.
Advisor will monitor underlying investments and Client allocation on an ongoing basis.
• Monitor.
RTD uses a third-party platform to manage “held away” accounts. A held away account is an account that you
maintain that is not held with a broker-dealer or custodian where we do not have a custodial relationship. Prior to us
managing any held away account, you will be provided with a link allowing you to connect one or more accounts to
the platform. Once an account is connected to the platform, we will review the current allocations, and when deemed
necessary, we will rebalance the account to the target asset allocation. You are responsible to keep the platform link
active, so that RTD will be able to access and manage the respective account without delay. If RTD determines that
the link has become inactive, RTD will use its best efforts to notify the client to resolve the issue.
Client Tailored Services and Client Imposed Restrictions
Specific Client financial plans and their implementation are dependent upon the Client’s Investment Policy Statement
which outlines each Client’s current situation (liquidity needs/tax constraints, if applicable and risk tolerance levels). It
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Form ADV Part 2A/2B 03/31/2026
is used to construct a Client specific plan to aid in the selection of a portfolio of investments that matches restrictions,
needs, and targets.
3(38) Investment Management for Employer Retirement Plans
RTD provides investment management services to retirement plans subject to the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”), referred to here as “ERISA Plan Clients”. Each ERISA Plan Client is
required to enter into an investment management agreement with RTD describing the services that RTD will perform
for the ERISA plan and if agreed to by the ERISA Plan Client, the ERISA plan participants. RTD provides both ERISA
fiduciary services and non-fiduciary services to ERISA Plan Clients.
i.
Plan Level Fiduciary Services
a. Discretionary Investment Management Services under ERISA §3(38). RTD provides investment
management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA
Section 3(38) and in that capacity, RTD’s investment decisions are made in its sole discretion without the ERISA
Plan Client’s prior approval. RTD’s investment management services include the following:
• RTD will develop an Investment Policy Statement (IPS) for the Client. The IPS establishes the investment
policies and objectives for the ERISA Plan.
• For Plan Clients that are participant-directed:
• RTD will select a broad range of investment options consistent with ERISA Section 404(c) and the
regulations thereunder. The investment options selected by RTD may include the RTD managed portfolios
in which RTD is the fund manager. If these RTD managed portfolios are made available as plan investment
options, it will not result in additional compensation to RTD.
• RTD will provide ongoing and continuous discretionary investment management with respect to the asset
classes and investment alternatives available under the ERISA Plan in accordance with the IPS. Under
this authority, RTD may remove and replace the investment alternatives available under the ERISA Plan in
its discretion.
•
If the Client decides to have a qualified default investment alternative (“QDIA”) for participants who fail to
make an investment election under the ERISA plan, RTD will select the investment to serve as the QDIA.
The Client retains the sole responsibility to provide all notices to participants required under ERISA Section
404(c)(5).
• For Plan Clients that are not participant-directed (i.e., pooled plans):
• RTD will develop asset allocations and portfolio modeling consistent with the Plan objectives expressed in
the IPS.
•
In accordance with the IPS, RTD will identify and select specific investments to populate the asset allocation
categories.
• As investment results and/or cash flow change the percentage of Plan assets represented by the different
asset allocation categories, RTD will provide periodic re-balancing as deemed appropriate in accordance
with the IPS.
• RTD will adjust the asset allocations as deemed appropriate in accordance with the IPS.
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Form ADV Part 2A/2B 03/31/2026
• RTD will monitor and measure investment performance and adherence to the IPS. RTD can make changes
in the selected investments, if appropriate, and will provide the Client with periodic reporting of investment
performance and results.
ii.
Participant-Level Fiduciary Services
Non-Discretionary Investment Advisory Services
If agreed to by the Client, RTD will provide non-discretionary investment advice to Plan participants about Plan
investment alternatives. Plan participants will have the final decision-making authority regarding the initial selection,
retention, and changes in investment selections.
a. Plan-Level Non-Fiduciary Services for Participant-Directed and Pooled Plans
If agreed to by the Client, RTD will perform the Non-Fiduciary services described below or, alternatively, may
arrange for the Plan’s other providers to offer these services, as agreed upon between RTD and Client.
• Educate the Client as to its fiduciary responsibilities.
• Assist the Client in monitoring, selecting and supervising service vendors by providing consulting services
on these matters.
• Prepare fee analysis and benchmarking studies.
b. Participant-Level Non-Fiduciary Services for Participant-Directed Plans
• Assist in initial and ongoing enrollment and education sessions with employees designed to increase
retirement plan participation and to improve investment and financial understanding.
• Assist in the education of the participants in the Plan about general investment principles and investment
alternatives available under the Plan. RTD’s assistance in participant investment education will be
consistent with prevailing Department of Labor guidance. As such, RTD does not provide fiduciary advice
(as defined in ERISA) in our education program to the participants.
Retirement Account Clients Potential for Conflict of Interest
RTD is a fiduciary under ERISA with respect to investment management services and investment advice provided to
ERISA clients, including ERISA plan participants if making recommendations or giving individualized investment advice
to the participants. RTD is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment
management services and investment advice provided to ERISA plans, ERISA plan participants, IRA owners and IRAs
(collectively, Retirement Account Clients). As such, RTD is subject to specific duties and obligations under ERISA and
the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from
acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must
either avoid or eliminate the conflict or rely upon a Prohibited Transaction Exemption (“PTE”).
A conflict of interest would arise, and the prohibited transaction rules would be implicated if RTD were to provide
fiduciary advice about plan distributions and rollovers if it results in RTD receiving compensation that it would not have
received absent the advice. In that instance, RTD would mitigate this conflict by acting in the best interest of the client.
No client is under any obligation to roll over ERISA plan or IRA assets to an account advised or managed by
RTD.
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Form ADV Part 2A/2B 03/31/2026
3(38) Investment Management for Pooled Employer Plans
RTD provides investment advisory and fiduciary services to Pooled Employer Plans (PEPs) established under the
Setting Every Community Up for Retirement Enhancement Act of 2019 (the “SECURE Act”). A PEP is a multiple-
employer retirement plan structure that allows unrelated employers to participate in a single qualified defined
contribution plan operated by a registered Pooled Plan Provider (PPP).
RTD serves as an ERISA 3(38) investment manager to the PEP. As a 3(38) fiduciary, we assume full discretionary
authority and responsibility for selecting, monitoring, and replacing the investment options available within the plan. This
includes the construction of the investment menu (excluding any Qualified Default Investment Alternatives, or QDIAs),
implementation of the plan’s Investment Policy Statement (IPS), and ongoing monitoring of the investments for
consistency with the IPS and fiduciary standards.
Our services typically include:
• Developing and maintaining the Investment Policy Statement (IPS) for the PEP, in coordination with the Pooled
Plan Provider (PPP).
• Selecting and managing the investment lineup on a discretionary basis.
• Performing ongoing due diligence and performance monitoring of investment options.
• Providing regular reports and documentation to the PPP and other responsible fiduciaries.
• Conducting periodic investment reviews and recommending changes as needed to maintain compliance with
fiduciary standards.
We do not provide plan administration, recordkeeping, or trustee services. We coordinate exclusively with the PPP, to
help support the fiduciary integrity of the plan.
Investment Management for Trusts and Non-Profits
After assessing Client’s goals, objectives, time horizon and risk tolerance, Advisor will recommend a diversified portfolio
and provide continuous and regular supervision of this portfolio. Clients may place reasonable restrictions on investing
in certain securities or types of securities.
Advisor’s Investment Management services include the following:
• Develop a written Investment Policy Statement.
Investment selection and execution of trades.
•
• Quarterly performance reporting.
• Financial Modeling when appropriate.
• Re-balance the portfolio when appropriate.
• Re-allocate the portfolio due to changes in the economy, of the Client’s objectives, or performance of the
underlying securities managed.
• Portfolio tax management where appropriate.
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Form ADV Part 2A/2B 03/31/2026
Investment Consulting for Trusts and Non-Profits
After assessing Client’s goals, mission, objectives, time horizon, risk tolerance, and discussing with Client, Advisor will
recommend a diversified portfolio and provide continuous and regular supervision of this portfolio. Client is responsible
for providing information to Advisor. Advisor is not responsible for the accuracy of the information provided.
Advisor’s Investment Consulting services include the following (collectively, the “Services”):
•
Initial and periodic financial modeling to identify an appropriate risk and return portfolio mix for the long-term
sustainability of the portfolio.
• Review Client’s outside assets to ensure they are in ongoing compliance with a written Investment Policy
Statement.
• Quarterly performance reporting.
• Recommend re-allocation of the portfolio within the approved ranges of the Investment Policy or recommend
a new investment range due to changes in the economy, of the Client’s objectives, or performance of the
underlying securities managed on a solely non-discretionary basis.
• Annual education and fiduciary training session for new board and finance committee members
• Meeting attendance and updates with finance committee or board.
Estate Engagement
Advisor will provide the following services:
• Asset Inventory and Reporting
• Coordination with Attorney and CPA
• Assistance with Beneficiary Account Openings
• Distribution Planning and Execution Support
• Cost Basis and Tax-Related Data Preparation
• Account Consolidation
• Counsel on Financially Related Administrative Responsibilities
Advisor will not provide discretionary investment management, execute securities transactions, provide legal or tax
advice, or assume responsibility for probate decisions, asset valuations, or fiduciary determinations, unless expressly
agreed to in writing by the parties and permitted by applicable law and custodian policies.
Item 5: Standard Fees and Compensation
Please note, unless a Client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment
advisory contract, the investment advisory contract can be terminated by the Client within five (5) business days of
signing the contract without incurring any advisory fees. How Advisor is compensated depends on the type of advisory
service performed. Please review the fee and compensation information below.
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Form ADV Part 2A/2B 03/31/2026
Fees and Compensation
Personal Wealth Management Fees:
Personal Wealth Management fees are based on factors including total wealth under advisement (TWA) as well as an
evaluation of each client’s unique financial, tax, business, and family complexity. Fees are based on a fixed amount
and can range from a minimum of $1,500 per quarter ($6,000 annually) to a maximum of $30,000 per quarter ($120,000
annually). The fee will be reviewed annually and can be adjusted up or down as each client’s TWA or complexity
changes. Examples of changes would be the acquisition or sale of a business, acquisition of material corporate stock
options, acquisition or sale of illiquid investment or real estate investment properties, inheritance, inflationary impacts,
the depletion of assets during retirement or family/multi-generational planning that increases the complexity of your
planning needs.
Should a change to the fee amount be warranted, you will be notified at least 60 days in advance. You may accept or
terminate without penalty.
Fees are due quarterly in advance and a pro-rata refund will be paid to Client if canceled within any quarter. This
quarterly fixed fee is cancelable anytime without restriction.
Additional Compensation Information
• Minimum Fee of $1,500 per quarter is reduced to $750 per quarter for Clients’ immediate family members (children
and parents).
• With client authorization, quarterly fees are deducted from client account(s) or paid by check or ACH payment. In
either case, clients will be sent an invoice quarterly.
• Under certain circumstances, at our sole discretion, Advisor can offer existing clients a Financial Advisory
Agreement if it’s in the clients’ best interest to do so.
• Under certain limited circumstances, at our sole discretion, Advisor offers advisory services on a pro-bono or
accommodation basis.
• For planning paid for by corporations for the benefit of its employees, the following discounts will apply: 2-5
employees, 10%; 6-10 employees, 15%; over 10 employees, 20%
Employer Retirement Plan Fees
RTD is a fiduciary under ERISA with respect to investment management services and investment advice provided to
ERISA Plan Clients. As such, RTD is subject to specific duties and obligations under ERISA and the IRC that include,
among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited
transactions, RTD will only charge fees for investment advice about vehicles for which RTD and/or its affiliates do not
receive any commission, 12b-1 fees, or other compensation.
The fees described below for Participant Directed Plans are payable quarterly or monthly in arrears as agreed to under
the investment management or advisory agreement between RTD and the ERISA Plan Client. Fees for Pooled
Retirement Plans are payable quarterly in advance. The initial fee is the amount, prorated for the number of days
remaining in the initial Fee Period from the effective date of the investment advisory or management agreement, based
upon the market value of the included assets on the last business day of the initial fee period. Thereafter, the fee is
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Form ADV Part 2A/2B 03/31/2026
based upon the market value of the included assets on the last business day of the fee period (without adjustment for
anticipated withdrawals by plan participants or other anticipated or scheduled transfers or distributions of assets).
• Fees differ for certain non-profit organizations.
• ERISA Plan Client investment management fees may be reduced for start-up retirement plans, or if a Personal
Wealth Management Client, or Trust or Non-Profit Investment Management Client also engages RTD for
retirement plan investment management services on behalf of an ERISA plan. The ERISA plan is obligated to
pay RTD’s fee. As agreed to under the investment management or advisory agreement between RTD and the
ERISA Plan Client, the ERISA Plan Client can authorize the plan custodian to automatically deduct the fee
from the plan or the plan sponsor of the ERISA Plan Client may choose to pay the fee.
Either RTD or the ERISA Plan Client can terminate the investment management or advisory agreement at any time,
without penalty, by sending the other party 30 days prior written notice. Both parties remain responsible for obligations
arising under any transactions initiated before the agreement was terminated. RTD is entitled to a fee, prorated for the
number of days in the Fee Period prior to the effective date of termination, based on the market value of the included
assets on the effective date of termination.
3(38) Investment Management for Participant-Directed Plans Where Participant-
Level Services are Provided
The RTD investment advisory fee for 3(38) investment management services provided to ERISA participant-directed
plans where participant-level services are provided is calculated as of the last business day of each calendar quarter,
or in accordance with the Plan’s agreement with their recordkeeping provider, by charging fees based on the market
value of plan assets in accordance with the following fee schedule, subject to a minimum fee of $3,750 per quarter:
Plan Assets
Quarterly
Annual
$0 - $4,999,999
0.12500%
0.500%
$5,000,000 - $9,999,999
0.10000%
0.400%
$10,000,000 - $19,999,999
0.07500%
0.300%
$20,000,000 - $39,999,999
0.05000%
0.200%
$40,000,000 - $59,999,999
0.03750%
0.150%
$60,000,000 - $99,999,999
0.03125%
0.125%
$100,000,000 - $199,999,999
0.02500%
0.100%
$200,000,000 - $299,999,999
0.02000%
0.080%
$300,000,000 - $399,999,999
0.01500%
0.060%
Over $400,000,000
Custom Pricing
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Form ADV Part 2A/2B 03/31/2026
3(38) Investment Management for Participant-Directed Plans Where No
Participant-Level Services are Provided
The RTD fee for investment management services provided to ERISA participant-directed plans where no participant-
level services are provided is calculated as a flat amount, subject to a minimum fee of $5,000 per quarter. If plan
assets increase or decrease to the next band, fees will automatically be updated for the next billing cycle. If plan
assets do not change to a new band within 3 years, a 10% cost of living adjustment will be applied to the fee every 3
years or until a new band is reached. Fee is calculated as follows:
Plan Assets
Quarterly Fee
Annual Fee
$0 - $19,999,999
$5,000
$20,000
$20,000,000 - $24,999,999
$6,250
$25,000
$25,000,000 - $34,999,999
$7,500
$30,000
$35,000,000 - $44,999,999
$8,750
$35,000
$45,000,000 - $59,999,999
$10,000
$40,000
$60,000,000 - $79,999,999
$11,250
$45,000
$80,000,000 - $99,999,999
$12,500
$50,000
$100,000,000 - $124,999,999
$13,750
$55,000
$125,000,000 - $149,999,999
$15,000
$60,000
$150,000,000 - $199,999,999
$18,750
$75,000
$200,000,000 - $299,999,999
$22,500
$90,000
$300,000,000 - $399,999,999
$26,250
$105,000
$400,000,000 - $499,999,999
$30,000
$120,000
$500,000,000 and above
Custom Pricing with $135,000 min.
3(38) Investment Management for Pooled Employer Plans
The RTD investment advisory fee for 3(38) investment management services provided to Pooled Employer Plans is
calculated as of the last business day of each calendar quarter, or in accordance with the Plan’s agreement with their
recordkeeping provider, by charging fees based on the market value of plan assets in accordance with the following fee
schedule:
Plan Assets
Quarterly
Annual
$0 - $1,000,000
0.0175%
0.070%
$1,000,001 - $3,000,000
0.0150%
0.060%
$3,000,001 - $20,000,000
0.0125%
0.050%
$20,000,000 - $40,000,000
0.0100%
0.040%
$40,000,001 - $75,000,000
0.0075%
0.030%
Over $75,000,001
Custom Pricing
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Form ADV Part 2A/2B 03/31/2026
Pooled Retirement Plan Investment Management Fees:
The RTD investment advisory fee for ERISA plans that are not participant-directed (i.e., pooled plans) is calculated in
advance as of the last business day of each calendar quarter by charging the following fee schedule, subject to a
minimum fee of $1,250 per quarter:
Plan Assets
Quarterly
Annual
First $2,000,000
0.1500%
0.60%
Next $3,000,000
0.1250%
0.50%
Next $5,000,000
0.1000%
0.40%
Over $10,000,000
0.0625%
0.25%
Investment Management Fees for Trusts and Non-Profits
The RTD fee is calculated in advance as of the last business day of each calendar quarter by charging the following
fee schedule, subject to a minimum fee of $1,250.00 per quarter:
Plan Assets
Quarterly
Annual
First $2,000,000
0.1500%
0.60%
Next $3,000,000
0.1250%
0.50%
Next $5,000,000
0.1000%
0.40%
Over $10,000,000
0.0625%
0.25%
Above $20,000,000
Custom Pricing
The advisory fees shown in (III and IV) are blended fees and are calculated by assessing the percentage rates to the
market value of the account by using the predefined levels of assets as shown in the above charts, resulting in a
combined weighted fee. For example, an ending quarter balance of $3,000,000 would pay an effective quarterly fee of
$4,250 (0.1417%). If annualized, the effective annual fee would be $17,000 (0.5667%). The quarterly fee is determined
by the following calculation: (($2,000,000 x 0.60%) + ($1,000,000 x 0.50%)) = $17,000/4 = $4,250.
• For certain non-profit organizations, fees are waived for balances under $500,000.
• For certain non-profit organizations working with an Association Management firm, minimum fees are waived.
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Form ADV Part 2A/2B 03/31/2026
Investment Consulting Fees for Trusts and Non-Profits
The RTD fee for investment consulting services provided to Trusts and Non-Profits is a flat amount calculated in
advance. If assets increase or decrease to the next band, fees will automatically be updated for the next billing cycle.
If plan assets do not change to a new band within 3-years, a 10% cost of living adjustment will be applied to the fee
every 3 years or until a new band is reached. Fee is calculated as follows, subject to a minimum fee of $6,250 per
quarter and minimum assets of $5,000,000:
Plan Assets
Quarterly
Annual
$5,000,000 - $25,000,000
$6,250
$25,000
$25,000,001 - $35,000,000
$7,500
$30,000
$35,000,001 - $45,000,000
$8,750
$35,000
$45,000,001 - $60,000,000
$10,000
$40,000
$60,000,001 - $80,000,000
$11,250
$45,000
$80,000,001 - $100,000,000
$12,500
$50,000
$100,000,001 - $125,000,000
$13,750
$55,000
$125,000,001 - $150,000,000
$15,000
$60,000
$150,000,001 - $200,000,000
$16,250
$65,000
$200,000,001 - $250,000,000
$17,500
$70,000
Custom Pricing w/ $75,000 min.
$250,000,001 and above
$18,750 min.
Estate Engagement Fees
Estate Engagement fees are charged on a flat quarterly fee basis, debited in advance from the Estate Account. Fees
are based on the size, complexity, and anticipated scope of services required for the administration of the estate. Fees
are based on a fixed amount and can range from a minimum of $1,500 per quarter ($6,000 annually) to a maximum of
$30,000 per quarter ($120,000 annually).
Fees are due quarterly in advance and a pro-rata refund will be paid to Client if canceled within any quarter or if when
the Estate is settled. This quarterly fixed fee is cancelable anytime without restriction.
Other Types of Fees and Expenses
Advisor’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which
can be incurred by the client. Clients can 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 on brokerage accounts and securities transactions. Mutual funds and exchange traded
funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and
commissions are exclusive of and in addition to our fee. Advisor does not receive any portion of these commissions,
fees, and costs.
Item 12 further describes the factors considered in selecting or recommending custodians for Client’s transactions and
determining the reasonableness of their compensation (e.g., commissions).
Advisor does 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.
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Form ADV Part 2A/2B 03/31/2026
Item 6: Performance-Based Fees & Side-By-Side Management
Advisor does not charge or receive performance-based fees.
Item 7: Types of Clients
Advisor provides financial planning and/or asset management services to individuals, families, pension plans, profit
sharing plans, pooled employer plans, charitable organizations, endowments, foundations, trusts and estates,
corporations, and other business entities.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
The firm’s strategy is based on asset allocation where we endeavor to help ensure that assets are appropriately
diversified to conform to each Client's specified time horizon and risk/return profile. The level of volatility the Client’s
portfolio is exposed to is communicated to the Client.
The performance of each investment option is periodically compared against an appropriate index and peer
group. “Watch list” procedures for underperforming Investment Managers are documented and consistently
applied. Rebalancing procedures are reasonable, documented, and consistently applied. Periodic reviews are also
made of qualitative and/or organizational changes of Investment Managers and other service providers.
RTD does not utilize ESG factors as a primary investment consideration unless requested by the client.
Margin transactions and option writing can occur if appropriate and only if approved by Client.
Material Risks Involved
All investing strategies offered involve risk and can 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: The Advisor’s investment strategies and/or investment techniques may not work as intended.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value can 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.
Inflation: Inflation will erode the buying power of your investment portfolio, even if the dollar value of your investments
remains the same.
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Form ADV Part 2A/2B 03/31/2026
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.
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have other
risks. Some key material risks involved may include the following:
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.
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.
Corporate Bonds are debt securities 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 their interest rates 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 on 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.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking
industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by
downturns in the U.S. and foreign economies or changes in banking regulations.
Cybersecurity and Operational Risk
RTD relies on technology systems, third-party service providers, and electronic data platforms to deliver advisory
services and maintain client information. As a result, there are risks associated with system failures, service
interruptions, unauthorized access, data breaches, cybersecurity attacks (including phishing, ransomware, and other
malicious activities), and other operational disruptions. These events may occur at RTD, a custodial institution, or other
third-party vendors used to support our services.
A cybersecurity or operational incident could result in the loss, theft, corruption, or unauthorized disclosure of
confidential information; delays or errors in account trading or reporting; financial loss; or temporary or extended inability
to access account information. RTD maintains policies, procedures, and controls designed to prevent, detect, and
respond to cybersecurity and operational events; however, no system or network is completely secure, and RTD cannot
guarantee that such measures will always be successful.
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Form ADV Part 2A/2B 03/31/2026
Clients should also be aware that certain third-party tools, such as account aggregation platforms used to connect and
manage “held-away” accounts, may present additional cybersecurity or data-sharing risks outside RTD’s direct control.
These tools rely on client-maintained credentials and third-party systems, which may become unavailable,
compromised, or inactive. If this occurs, trading, rebalancing, or monitoring of such accounts may be delayed until
access is restored.
Any cybersecurity or operational event may negatively impact a client’s account or RTD’s ability to provide advisory
services. Clients are encouraged to maintain secure personal practices and to notify RTD promptly of any suspected
compromise involving their accounts or personal information.
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of RTD or the integrity of our management. There have been no applicable
disciplinary events.
Item 10: Other Financial Industry Activities and Affiliations
RTD has no other Financial Industry Activities or Affiliations.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
RTD has adopted a written Code of Ethics in compliance with SEC rule 204A-1. The code sets forth standards of
conduct and requires compliance with federal securities laws. Our code also addresses personal trading and requires
our personnel to report their personal securities holdings and transactions to the Chief Compliance Officer of the firm.
Advisor will provide a copy of our Code of Ethics to any Client or prospective Client upon request.
It is further noted that RTD is in and shall continue to be in total compliance with The Insider Trading and Securities
Fraud Enforcement Act of 1988. Specifically, RTD has adopted a firm-wide policy outlining insider-trading compliance
by RTD and its employees. This policy has been distributed to all employees of RTD. There are provisions adopted
for (1) restricting and/or monitoring trading on those securities of which RTD’s employees may have non-public
information, (2) requiring all of RTD’s employees to report all applicable transactions properly to RTD, and (3) monitoring
the securities trading of the firm and its employees and associated persons.
Item 12: Brokerage Practices
C U S T O D I A N S / B R O K E R S U S E D
Client assets are maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. Advisor
currently recommends Charles Schwab as the primary qualified custodian for our private Client accounts. The firms are
SEC-registered custodians and FINRA/SIPC members. Advisor is independently owned and operated and is not
affiliated with either custodian.
Custodians hold Client assets in a brokerage account and buy and sell securities when Advisor/Client instruct them to.
Clients’ open account(s) directly with the custodian. Advisor can assist the Client in this effort. See Item 14 for additional
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Form ADV Part 2A/2B 03/31/2026
related information with respect to certain products and services offered by the qualified custodians (or related parties)
and received by Advisor at no additional charge or for a reduced fee.
Advisor does not participate in any referral program offered by Charles Schwab.
Advisor also utilizes the services of SP Financial Group of Arkadios Capital for fixed income analysis, support, and
execution.
S E L E C T I N G C U S T O D I A N S \ B R O K E R S
The following factors were taken into the consideration in the selection and monitoring of these custodians:
• Creditworthiness, financial strength and reputation of the custodian
• Quality and promptness of overall execution services provided by the custodian
• Client data security policy and procedures
• Promptness and accuracy of oral, hard copy or electronic reports
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.)
• Competitiveness of transaction fees charged by the custodian
• Availability of investment research and tools
• Ability and willingness to correct trade errors
• Promptness and accuracy of confirmation statements
• The broker-dealer's facilities, including any software or hardware, provided to the Advisor
• Reliability, reputation and corporate culture of the custodian
• Prior service to us and our other Clients
R E S E A R C H A N D B E N E F I T S
Although not a material consideration when determining whether to recommend that a client utilize the services of a
particular broker-dealer/custodian, RTD can receive from Schwab (or another broker-dealer/custodian, investment
manager, platform sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services and/or
products, certain of which assist RTD to better monitor and service client accounts maintained at such institutions.
Included within the support services that can be obtained by RTD can be investment-related research, pricing
information and market data, software and other technology that provide access to client account data, compliance
and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis
attendance at conferences, meetings, and other educational and/or social events, marketing support-including client
events, computer hardware and/or software and/or other products used by RTD in furtherance of its investment advisory
business operations.
RTD’s clients do not pay more for investment transactions affected and/or assets maintained at Schwab as a result of
this arrangement. There is no corresponding commitment made by RTD to Schwab, or any other any entity, to invest
any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products
as result of the above arrangement.
D I R E C T E D B R O K E R A G E
As mentioned above, RTD recommends its clients utilize the brokerage and custodial services provided by Schwab.
RTD generally does not accept directed brokerage arrangements (when a client requires that account transactions be
affected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and
arrangements for their account with that broker-dealer, and RTD will not seek better execution services or prices from
other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders
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Form ADV Part 2A/2B 03/31/2026
for other accounts managed by RTD. As a result, a client may pay higher commissions or other transaction costs or
greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case.
In the event the client directs RTD to effect securities transactions for the client’s accounts through a specific broker-
dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher
commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account
transactions through alternative clearing arrangements which may be available through RTD. Higher transaction costs
adversely impact account performance. Transactions for directed accounts will generally be executed following the
execution of portfolio transactions for non-directed accounts.
O R D E R A G G R E G A T I O N
Transactions for each client account will generally be affected independently, unless RTD decides to purchase or sell
the same securities for several clients at approximately the same time. RTD may (but is not obligated to) combine or
“bunch” such orders to seek best execution, to negotiate more favorable commission rates or to allocate equitably
among RTD’s client’s differences in prices and commissions or other transaction costs that might have been obtained
had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be
allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day.
RTD will not receive any additional compensation or remuneration as a result of such aggregation.
I N D I V I D U A L I N V E S T O R R E T I R E M E N T A C C O U N T R E V I E W
We are making investment recommendations to you regarding your retirement plan account or individual retirement
account as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal
Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money or otherwise
are compensated creates some conflicts with your financial interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours.
Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice) to you;
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than what is reasonable for our services; and
• Give you basic information about our conflicts of interest.
T R A D E E R R O R S
RTD promptly corrects any trade errors upon discovery. If a trade error results in a loss, RTD bears the full amount of
that loss so that you are not negatively affected. If a trade error results in a gain, RTD will not retain the gain; gains are
allocated to the affected client, or if not permissible, handled according to the custodian’s error‑resolution policies.
RTD ensures that no client is disadvantaged as a result of a trade error, and you will receive a fee credit for any
negative impact the error may have caused.
Item 13: Review of Accounts
RTD’s Investment Committee establishes the investment policy and parameters for the firm. Advisor implements this
policy for the relationships they service and reviews each managed portfolio at least quarterly. RTD’s Investment
Committee monitors the performance of each investment monthly based on how similar investments have performed
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Form ADV Part 2A/2B 03/31/2026
and recommends changes when necessary. RTD’s Investment Team monitors for rebalancing opportunities on a daily
basis as well as for any material events such as market dislocation or large deposits or withdrawals.
Quarterly reports are prepared for each Client, which currently consists of:
1. Overall Asset Allocation Percentages
2. Value vs. Net Investment
3. Time-Weighted Rates of Return for Quarter, 12 Months, 3/5 Years and Since Inception
Item 14: Client Referrals and Other Compensation
Advisor does not receive any economic benefit, directly or indirectly from any third party for advice rendered to our
Clients. Nor does the Advisor directly or indirectly compensate any person for Client referrals who is not advisory
personnel.
Advisor has a professional relationship with Charles Schwab through which Advisor is offered and receives discounts
for research and reporting related products and tools provided by Ycharts, Fi360/Broadridge, and eMoney
Advisor. Other benefits include; rebalancing technology (iRebal), consulting services related to client experience,
operations and human capital and corporate growth; access to a dedicated trading desk; access to an electronic network
for Client order entry and account information; access to certain mutual funds/exchange-traded funds with no
transaction fees; access to certain institutional funds; and other discounts on marketing, research, technology, and
practice management products or other services provided by third-party vendors. These benefits do not influence
account recommendations and RTD does not select products to satisfy custodian incentives.
While there is no direct link between Advisor's relationship and the investment advice it gives to Clients, these products
or services can assist Advisor in managing Client accounts including accounts not maintained at Charles Schwab. They
can also assist further development of Advisor’s business enterprise. Charles Schwab may on occasion pay expenses
or provide discounts for Advisor's personnel to attend educational conferences.
None of these benefits depend on the level of assets or the number of brokerage transactions directed to Charles
Schwab. Advisor has not committed to maintaining any level of assets at either. Advisor has also negotiated custodial
transaction fees that are consistent with one another. As part of its fiduciary duties to Clients, Advisor endeavors to put
the interests of its Clients first at all times. Clients should be aware, however, that the receipt of economic benefits by
Advisor or its related persons in and of itself creates a potential conflict of interest and indirectly influence the Advisor's
recommendation of Charles Schwab for custody and brokerage services.
It is Advisor’s policy not to engage solicitors or to pay related or non-related persons for referring potential clients to the
firm.
It is Advisor’s policy not to accept or allow related persons to accept any form of compensation, including cash, sales
awards or other prizes, from a non-client in conjunction with the advisory services we provide.
Item 15: Custody
Custody is defined as any legal or actual ability by our firm to access client funds or securities. RTD does not maintain
physical custody of client assets. All client funds and securities are held with one or more “qualified custodians.”
However, although our firm does not take actual possession of client funds or securities, we are deemed to have
constructive custody of certain client accounts and funds under current SEC interpretation and guidance. Therefore, we
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Form ADV Part 2A/2B 03/31/2026
urge all of our clients to carefully review and compare the reviews of account holdings they receive from us to those
they receive from their qualified custodian. Any discrepancies should be reported to us and/or the qualified custodian
immediately.
In cases where a client has, in writing, authorized RTD to debit RTD’s fees directly from such client’s account, RTD has
a level of technical “custody” over such client’s account. In any case, standard RTD practice is to send quarterly invoices
and to further specifically notify such clients, in advance, if any such deduction is expected to be materially greater than
their median quarterly fee.
Certain RTD clients have also provided RTD written authority to transfer funds between specific accounts, which RTD
deems as first-party accounts, of that client that cannot be titled in an identical manner. An example might be a journal
from a client’s individual account to their IRA account or from their individual account to a joint account.
For Client account(s) in which RTD directly debits their advisory fee:
i.
Client will authorize the custodian, in writing, that fees are to be paid directly from their accounts held by the
custodian to RTD.
ii.
The custodian will send at least quarterly statements (normally monthly) to the Client showing all disbursements
from the account(s), including the amount of the advisory fee.
Item 16: Investment Discretion
Clients can hire us to provide discretionary asset management services, in which case we place trades in a client's
account without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign an agreement with our firm and can limit this authority by giving
us written instructions. Clients can also change/amend such limitations by once again providing us with written
instructions.
Item 17: Voting Client Securities
RTD does not vote Client proxies and RTD does not have any authority to and does not vote (or recommend how to
vote) proxies on behalf of Clients. Responsibility for voting proxies remain with the Client. Therefore, Clients maintain
exclusive responsibility for (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment
assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and
shareholder communications relating to the Client’s investment assets. If the Client (other than an ERISA Plan Client)
would like our opinion on a particular proxy vote, they can contact us at the number listed on the cover of this brochure.
Clients will receive proxy materials directly from the account custodian.
RTD may help clients understand materials upon request.
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Form ADV Part 2A/2B 03/31/2026
Item 18: Financial Information
Registered investment advisers are required in this Item to provide Client with certain financial information or disclosures
about our financial condition. Advisor has no financial commitment that impairs our ability to meet contractual and
fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding. Advisor does not require
or solicit prepayment of fees more than six months in advance.
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