Overview

Assets Under Management: $171 million
Headquarters: DALLAS, TX
High-Net-Worth Clients: 8
Average Client Assets: $20.0 million

Frequently Asked Questions

RWR INVESTMENTS LLC charges 1.00% on the first $25 million, 0.50% on the next $50 million, 0.25% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #157966), RWR INVESTMENTS LLC is subject to fiduciary duty under federal law.

RWR INVESTMENTS LLC is headquartered in DALLAS, TX.

RWR INVESTMENTS LLC serves 8 high-net-worth clients according to their SEC filing dated April 20, 2026. View client details ↓

According to their SEC Form ADV, RWR INVESTMENTS LLC offers portfolio management for individuals, portfolio management for pooled investment vehicles, and selection of other advisors. View all service details ↓

RWR INVESTMENTS LLC manages $171 million in client assets according to their SEC filing dated April 20, 2026.

According to their SEC Form ADV, RWR INVESTMENTS LLC serves high-net-worth individuals and pooled investment vehicles. View client details ↓

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (RWR INVESTMENTS LLC - FORM ADV, PARTS 2A AND 2B)

MinMaxMarginal Fee Rate
$0 $25,000,000 1.00%
$25,000,001 $50,000,000 0.50%
$50,000,001 and above 0.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million Below minimum client size
$5 million Below minimum client size
$10 million $100,000 1.00%
$50 million $375,000 0.75%
$100 million $500,000 0.50%

Clients

Number of High-Net-Worth Clients: 8
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 93.83%
Average Client Assets: $20.0 million
Total Client Accounts: 9
Discretionary Accounts: 9
Minimum Account Size: $10,000,000
Note on Minimum Client Size: $10,000,000

Regulatory Filings

CRD Number: 157966
Filing ID: 2096704
Last Filing Date: 2026-04-20 18:32:37

Form ADV Documents

Additional Brochure: RWR INVESTMENTS LLC - FORM ADV, PARTS 2A AND 2B (2026-04-20)

View Document Text
Item 1. Cover Page 3131 Turtle Creek Blvd, Suite 301 Dallas, Texas 75219 (214) 308-1970 www.rwrinvestments.com CRD #157966 Form ADV, Part 2A | Firm Brochure April 20, 2026 This brochure provides information about the qualifications and business practices of RWR Investments LLC (“RWR”, the “Adviser”, or “we”). If you have any questions about the contents of this brochure, please contact the Adviser at (214) 308-1970. The information in this brochure has not been approved or verified by the U.S. Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about RWR is available on the SEC’s website at www.adviserinfo.sec.gov. RWR is an SEC-registered investment adviser. Registration does not imply a certain level of skill or training. Registration does not imply a certain level of skill or training. 1 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Item 2. Material Changes This brochure, dated April 20, 2026, amends our last update dated April 1, 2026. Material changes to this brochure since our last annual amendment was filed on March 31, 2025, include the following: • The Adviser’s address was changed in September 2025. • Item 4. Advisory Business has been expanded to include a discussion of our Outsourced Chief Investment Officer Services, as well as how these services differ from our Full-Service Asset Management services. • As the Adviser’s AUM has surpassed the $100 million threshold for SEC registration, this amendment to the Adviser’s Form ADV transitions the Adviser’s registration from the state of Texas to the SEC. Item 4. Advisory Business has been amended to reflect this change. • Item 5. Fees and Compensation was expanded to include a fee schedule and a discussion of the ways we assess and calculate fees for our clients. • Item 12. Brokerage Practices was expanded to include our relationship with Schwab and the benefits we receive from doing business with Schwab. 2 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 3 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Item 3. Table of Contents Item 2. Material Changes ......................................................................................................................................... 2 Item 3. Table of Contents .......................................................................................................................................... 4 Item 4. Advisory Business ......................................................................................................................................... 5 Item 5. Fees and Compensation ................................................................................................................................ 7 Item 6. Performance-Based Fees and Side-By-Side Management ....................................................................... 10 Item 7. Types of Clients ........................................................................................................................................... 10 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss................................................................. 11 Item 9. Disciplinary Information ............................................................................................................................ 14 Item 10. Other Financial Industry Activities and Affiliations .............................................................................. 14 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 15 Item 12. Brokerage Practices .................................................................................................................................. 16 Item 13. Review of Accounts ................................................................................................................................... 18 Item 14. Client Referrals and Other Compensation ............................................................................................. 18 Item 15. Custody ...................................................................................................................................................... 18 Item 16. Investment Discretion ............................................................................................................................... 18 Item 17. Voting Client Securities ............................................................................................................................ 18 Item 18. Financial Information ............................................................................................................................... 19 4 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Item 4. Advisory Business FIRM DESCRIPTION RWR Investments LLC (“RWR”, the “Adviser”, or “we”) is a Texas limited liability company founded in March 2011 and principally owned by Robert Willing Ryan III. RWR has been a registered investment adviser with the State of Texas since August 22, 2011. On March 31, 2026, RWR became an SEC-registered investment adviser. We provide bespoke, full-service asset management, Outsourced Chief Investment Officer services (“OCIO Services”), and family office services that include portfolio construction, portfolio management, and reporting. Our clients include family offices, ultra-high-net-worth individuals, trusts, and corporate entities (“Managed Account Clients”). In addition, RWR serves as the investment manager to one or more private fund clients created as optional pooled investment vehicles for our qualified Managed Account Clients (the “Private Funds”). We manage all client assets via separately managed accounts. TYPES OF ADVISORY SERVICES We are rooted in family wealth management as our firm began with full-service portfolio management for a single- family office. Today, we continue to offer that service for select clients, but we also offer more focused portfolio management in niche investment strategies for which we have developed an expertise. The investment strategy we deploy and the assets we manage are determined on a client-by-client basis. We provide tailored advisory services based on the unique needs of each client. Clients select the services we provide and determine the approach we take with regard to managing their assets. Full-Service Asset Management Managed Account Clients For those clients that elect to have RWR provide full-service asset management, we will act as their primary investment adviser, managing all assets in their investment portfolio. In this role, we help clients achieve their investment goals and preserve wealth by recommending ways to distribute client investments across different asset classes, selecting direct investments and fund managers in each asset class to manage those investments, analyzing risks to try and protect the portfolio against heavy losses, and offering overall advice regarding which investment solutions work best for the client given their need to convert their assets to cash. We strive to develop comprehensive investment strategies to address each client’s financial goals, objectives, and risk tolerance. As part of providing asset management services, we also provide performance reporting to clients. We endeavor to consider the client’s complete financial outlook when making investment recommendations and planning for the future. Therefore, we may structure our investment advice in view of any outside investments held by the client (non-discretionary assets), considering each investment’s effect on the client’s total portfolio. At the request of the client, we may take on the management of certain assets not initially recommended for investment by RWR. Additionally, we may perform due diligence and provide advice on current or potential outside investments if requested by the client. These services may include ongoing research and analysis, benchmarking, rebalancing, and facilitating capital calls. Private Funds At present, RWR is the investment manager of a single Private Fund, RWR Crescent Cove, LLC. This Private Fund was organized to facilitate an opportunity for our Managed Account Clients to make pooled investments in certain types of assets. RWR or an affiliate may sponsor or manage additional Private Funds in the future. Subscriptions in the Private Fund have historically been offered exclusively to our Managed Account Clients. However, we reserve 5 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 the right to offer subscriptions in any Private Fund to non-clients in the future. Third-Party Manager Selection and Oversight In connection with our investment management services, we may engage one or more third-party investment managers (each, a “third-party manager”) to manage a portion of a client’s assets, either as a separate account manager, sub- to a private fund or other investment vehicle. When selecting a third-party manager for a client, we consider, among other things, our client’s stated investment objectives and the third-party manager’s investment philosophy, management style, financial stability, tenure, performance history, fees, client service, and reporting. Prior to establishing an account with a third-party manager, clients are encouraged to review the third-party manager’s Form ADV disclosure brochures for management fees, services offered, and actual or potential conflicts of interest. In addition to the investment management fees paid to RWR, clients will pay fees directly to any third-party manager for their advisory services. OCIO Services: Strategic Capital Allocation Alternative investments are often a weakness for traditional wealth managers, single family offices, and smaller institutions. A well-diversified portfolio will include strategic allocations to various alternative investments, and client portfolios suffer when investment advisors lack the knowledge or access to make the right investments in this space. Our deep expertise in alternative investments makes us a valuable partner, both for our clients and for their primary wealth manager. We provide this service in two ways: Separately Managed Account Clients can engage us to manage a portion of their assets, with a focused investment strategy, via a separately managed account. In this scenario, the relationship is between RWR and the individual client, meaning we take direction from the client, not their primary wealth manager. At the client’s request, we may liaise with the primary wealth manager to help facilitate the creation of a diversified portfolio for the client. But the day-to-day management of the assets allocated to our management is solely at our discretion. Sub-Adviser Agreement Unaffiliated investment advisers can engage us to manage a portion of their clients’ assets, with a focused investment strategy, by entering into a sub-advisory agreement with RWR. As a sub-adviser, the agreement is between us and the primary wealth manager, and we take direction from the manager with regard to their clients’ assets. In accordance with the terms of the sub-advisory agreement, we will manage a portion of the assets of the adviser’s underlying client. The agreement will specify the type of asset(s) and the investment strategy to be employed. We will liaise with and report to the client’s primary adviser, who will provide final reports and communicate with their underlying client. Family Office Services Our comprehensive approach to asset management includes family office services tailored to the needs of the individual client. Integrated financial independence planning allows us to develop long-term investment strategies with the flexibility to evolve as our clients’ needs may change. We evaluate the needs of each individual client to determine which, if any, family office services are appropriate in light of their needs and goals. Family office services may include but not be limited to the following: • Personal financial planning, budgeting, and cash flow forecasting • Estate planning and wealth transfer • Asset acquisition and refinancing strategies 6 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 • Establishment and management of trusts and corporate entities • Foundation management and philanthropic planning • Bookkeeping and creation of personal financial statements • Cash management, wire transfers, and bill processing • Assistance with identity verification, investor qualifications, and KYC requests • Education planning, including saving and/or financing costs • Tax planning and coordination of tax return preparation and filing • Business investment analysis and succession planning • Coordination of experts, including accounting and tax professionals, legal counsel, insurance agents and brokers, and other professional advisors Family office services may be undertaken by clients on a comprehensive or modular basis. RWR may provide these services and/or coordinate with unaffiliated professionals that provide them. At the client’s request, we can also recommend professional advisors that provide these services. TAILORED SERVICES AND CLIENT-IMPOSED RESTRICTIONS Our singular focus on helping clients create and preserve wealth allows us to invest time in truly understanding the needs and goals of each client. We tailor our services to individual client needs by asking a series of questions that focus, among other things, on client goals, investment objectives, risk tolerances, time horizons, cash needs, and tax situations. Through this dialogue with clients, we can craft an investment approach uniquely designed to meet the client’s needs at each stage in their life. Clients are permitted to provide direction and/or place restrictions on the investments we make for them. In these cases, we adjust the recommended asset allocation to include client-specific preferences within their investment mandate. Clients may impose restrictions on investing in certain securities or industries in accordance with their values or beliefs. Such restrictions may include a prohibition against investment or a cap on the investment size or value. For instance, certain clients may wish to prohibit or limit their investment in publicly traded companies in the tobacco, alcohol, gambling, firearms, and cannabis sectors (“sin stocks”). WRAP FEE PROGRAMS A wrap fee program is an investment program where the client pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. RWR does not participate in any wrap fee programs. CLIENT ASSETS UNDER MANAGEMENT As of December 31, 2025, RWR had $170,892,730 of discretionary assets under management. We do not manage any client assets on a non-discretionary basis. Item 5. Fees and Compensation COMPENSATION FOR ADVIS ORY SERVICES Below is a discussion of how RWR is compensated in connection with providing Full-Service Asset Management and Outsourced Chief Investment Officer services. We may enter into different fee arrangements on a client-by-client basis. Our fees are negotiable, taking into consideration factors such as the amount of assets we will manage for a client, the complexity of the client’s financial goals, the type and amount of services requested, and any special 7 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 circumstances. It is therefore possible that clients receiving similar services from us may pay different fees. Advisory fees are generally calculated at the end of the calendar quarter and debited from each client’s account(s) within the first ten (10) business days of the subsequent quarter. We may waive or reduce these fees for any client at our discretion. Managed Account Clients For advisory services provided to our Managed Account Clients, we receive a “management fee” equal to a percentage of the client’s total assets under management. Management fees range from 0.25% (25 basis points) to 1.00% (100 basis points) and vary based on the type of asset and the complexity of the services we provide with respect to its management. For real assets owned by our clients and managed by RWR, we charge an asset management fee equal to 0.50% (50 basis points), calculated using the current value of the asset. For all other assets, clients are charged a tiered management fee based on their assets under our management. The management fee decreases with each AUM hurdle reached, as illustrated by our standard fee schedule below. Fee Schedule Assets Under Management Annual Fee Maximum Fee Tier 1 $1 to $25,000,000 1.00% $250,000 Tier 2 $25,000,001 to $50,000,000 0.50% $125,000 Tier 3 50,000,001 and above 0.25% Each client’s negotiated management fee is detailed in their respective advisory agreement. Our management fee is calculated using the client’s total AUM, which is comprised of the following: • The account balance in each of the client’s custodial accounts managed by RWR; • The fair value of any direct investment managed by RWR; • The fair market value of the client’s investment in any Private Fund managed by RWR; • The fair market value of any non-RWR private investment which RWR is managing for the client; and • The fair market value of any real asset which RWR is managing for the client. A client’s AUM is calculated using the gross value of the assets and accounts generally without any offset for margin or debt balances, except for real estate, for which the value used is net of debt. . Assets are priced using an independent pricing service, based on the value reported by a third-party manager, or in the case of investments for which third party values are not readily available, in good faith by RWR. Quarterly management fees are charged in arrears based on the client’s AUM as of market close on the last business day of the preceding calendar quarter; provided no valuations for private investments are provided to RWR on a delayed basis. In such instances, fee calculations will be determined using the most recently available quarter-end value of such investments. Managed Account Clients pay all custody fees and brokerage commissions incurred on behalf of their accounts as well as any management fees for outside managers. 8 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Private Funds For advisory services provided to the Private Funds, we receive an annual management fee equal to 0.25% (25 basis points), charged pro rata on a quarterly basis (.0625% per quarter). Because we receive management fees for the Private Funds in addition to the management fee from our Managed Account Clients, our recommendation to invest in these funds creates a potential conflict of interest. We mitigate this risk by disclosing the existence of these fees in this brochure and the governing documents for each Private Fund. Clients are under no obligation to invest in a Private Fund. Each Private Fund bears all costs of its organization and operation, expenses incurred in the purchase and sale of investments, and accounting and audit fees. For further details, please see the governing documents for the respective Private Fund. OTHER FEES AND EXPENSES Managed Account Clients In addition to the fees described above, Managed Account Clients will incur additional fees and expenses in their custodial accounts charged by third parties including custodians, brokers, mutual fund companies, separate account managers, and pooled investment vehicles. These fees may include brokerage commissions, transaction fees, mark-ups and mark-downs, dealer spreads, wire transfer and ACH fees, margin interest, exchange or custodial fees, and other fees and taxes on brokerage accounts and securities transactions. For further details regarding the custodial relationship, please refer to Item 12. Brokerage Practices. We may recommend one or more third-party investment managers to manage a portion of the client’s assets, in particular when the third-party manager has an expertise managing certain types of assets. Clients will pay the management fees for services provided by third parties engaged to manage a portion of the client’s assets as a sub- adviser, separate account manager, or an investment manager for a private fund. When we recommend the use of a third-party manager, clients will pay our management fees in addition to the management fees charged by the third- party manager. In addition, mutual funds and exchange traded funds charge internal management fees that are disclosed in each fund’s prospectus, in addition to other expenses that a custodian may charge for providing access to a particular mutual fund family. Not all mutual fund trades we make incur this additional custodial transaction fee on mutual fund trades. We advise clients to read the prospectus for a mutual fund and/or ETF for a full list of associated expenses. When recommending mutual funds for client portfolios, we only recommend no-load, load-waived, or institutional share class mutual funds. We also advise clients to read the offering documents of each pooled investment vehicles or other type of private investment for a description of the additional fees and expenses associated with such an investment. Neither RWR nor any of our employees accept any compensation for the sale of securities or other investment products. Private Funds The expenses of a Private Fund are outlined in its governing documents but generally include the expenses of its organization and the offering of its interests (including legal and accounting fees, printing costs, travel, “Blue Sky” and other regulatory filing fees, and out-of-pocket expenses, but not including placement fees). A Private Fund will also bear all costs and expenses related to its investment program, administration, regulatory and licensing fees, taxes, and legal fees, as further defined in its private offering documents. Investors in a Private Fund will pay a pro rate share of these expenses in accordance with their respective ownership percentages. Investors should carefully review the Private Fund’s offering documents for detailed information regarding fees and the methodology for calculation with 9 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 respect to investors’ capital accounts. FEES PAID IN ADVANCE AND REFUNDS Managed Account Clients A client’s investment advisory agreement includes provisions for termination of the contract and generally allows both RWR and the client to terminate the agreement by providing written notice to the other party thirty (30) days in advance. Should a Managed Account Client terminate the relationship intra-quarter, RWR will return any prepaid but unearned fees. As management fees are generally calculated and charged in arrears, such a circumstance is unlikely. RWR will prorate the management fee to be charged based on the number of days remaining in the quarter following the termination date. Private Funds The termination provisions applicable to investors in a Private Fund are outlined in the governing documents for the fund. Liquidity will vary based on the structure of a Private Fund and its portfolio assets. Certain Private Funds prohibit investor withdrawals or redemptions until the Private Fund is liquidated. Managed Account Clients invested in a Private Fund may terminate their client agreement with RWR but be unable to redeem their capital from a Private Fund. Therefore, some Private Funds may include investors who are no longer Managed Account Clients. Item 6. Performance-Based Fees and Side-By-Side Management We may recommend or allocate a portion of a client’s assets to one or more unaffiliated private funds and/or third- party managers (“underlying managers”) that charge performance-based allocations or fees, which are shared or supplemented by our fees. Performance-based fees and/or allocations could motivate the underlying managers to make investment decisions that are riskier or more speculative than would be the case if these arrangements were not in effect. In addition, because many performance-based fees or allocations may be calculated on a basis that includes both realized and unrealized appreciation in portfolios, based upon values assigned by the underlying managers, those managers face a conflict of interest in valuing such portfolios. RWR generally attempts to ensure that these conflicts are addressed by the underlying managers in a fair and equitable manner. We attempt to address any known conflicts of interest by providing full and fair disclosures to our clients, including in this brochure. To ensure that RWR does not give preferential treatment to any underlying manager(s), we evaluate all underlying managers in a consistent, fair, and equitable manner. We select underlying managers that we believe are best for the client in light of the facts and circumstances. Item 7. Types of Clients We provide investment advisory services to: Individuals and families, including Family Offices • • High-net-worth and ultra-high-net-worth individuals • Trusts, estates, and charitable organizations • Corporate entities and limited partnerships • Pooled investment vehicles, including private funds 10 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 MINIMUM ASSETS UNDER MANAGEMENT We generally require Managed Account Clients to maintain a minimum of $10,000,000 in assets under our management. However, we may reduce or waive this minimum at our discretion. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Our primary service is to provide investment advice to our clients. As a part of this service, we select public equity and debt securities for clients using bottom-up, fundamental research and in accordance with each individual client’s risk profile. We also perform diligence and select third party managers to manage a portion of our clients’ assets. When performing due diligence on prospective third-party managers, we divide our research into three areas: quantitative, qualitative, and operational. Quantitative analysis of a potential third-party managers consists of analysis of the manager’s underlying investments, past performance, management fees, incentive structure, liquidity, and other terms. We seek managers who have performed strongly on a stand-alone basis, relative to competitors and relative to their respective benchmarks. Qualitative analysis of a potential third-party manager is an analysis of factors that are not directly measurable or quantifiable. This includes but is not limited to judgments about the strength of an manager’s investment philosophy, research process, risk management process, and professional experience. Operational analysis includes the examination of a third-party manager’s front and back-office team, past legal and regulatory actions, the manager’s choice of outside service providers (or lack thereof), and the general strength of the underlying advisory business. Clients should note that investing in securities or allocating assets to third party advisers who might invest in securities involves the risk of loss, which clients should be prepared to bear. INVESTMENT STRATEGIES We intend to provide the primary service described above and will generally follow the outlined investment strategies if such strategies are in accord with our investment program. We may also formulate new approaches for carrying out the overall objective of our clients. We believe in a long-term strategy with a balanced, well-diversified portfolio of public securities and alternative investments including real estate, private equity, credit, and hedge funds. In some but not all cases, we utilize third-party managers who may manage portfolios of alternative investments on behalf of our clients in partnerships and separately managed accounts. Investment strategies utilized by RWR and third-party managers we select may include short-term trading, long-term trading, short sales, margin transactions, currency trading, and various option strategies and other forms of derivatives. RISK OF LOSS Clients should be aware that investing in any security entails risk of loss which they should be willing to bear. We do not guarantee the future performance of a client’s portfolio or any specific return, the success of any investment decision or strategy that we may use, or the success of our overall management of any client’s account or participation in a private fund. The investment decisions made by us, third-party managers selected by us, and private investment fund managers for our clients’ accounts are subject to various market, economic, political, and business risks, and those investment decisions will not always be profitable. The following is a list of risks associated with the investment strategies we employ, though this list is not exhaustive. It does not include every potential risk associated with each investment strategy or type of security we may purchase or sell for our clients. Clients are urged to ask questions regarding risk factors applicable to a particular investment strategy or security, read all product-specific risk disclosures, and determine whether a particular strategy or type of 11 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 security is suitable for their own account in light of the circumstances, investment objectives, and financial circumstances of the particular client. Risks Related to Certain Securities and Investment Strategies Concentration. Some strategies used by third-party managers involve investments in a relatively small number of securities. Losses incurred in such securities could have a disproportionate effect on the account’s overall financial condition. Leverage. Interest costs on borrowings may fluctuate with changing market rates of interest and may partially offset or exceed the return earned on borrowed funds. To the extent a client account is leveraged, the value of its assets will tend to increase more when its portfolio securities increase in value, and decrease more when its portfolio securities decrease in value, than if its assets were not leveraged. Short Selling. Short sales by third-party managers that are not part of a hedging strategy are speculative and involve special risk considerations. Short sales theoretically involve unlimited loss potential as the market price of securities sold short may continuously increase. Equity Securities. By investing in stocks, we may expose a client account to a sudden decline in the share price or to an overall decline in the stock market. The value of investments held in a client account will fluctuate daily and cyclically based on changes in the issuer’s financial condition and prospects and on overall market and economic conditions. Fixed Income Securities. The prices of fixed income securities respond to economic developments, particularly interest rate changes, as well as to perceptions of an issuer’s creditworthiness. The duration of these securities affects risk as well, with longer term securities generally more volatile than shorter term securities. Foreign Securities. Foreign investments may be adversely affected by changes in currency rates and exchange control regulations, unfavorable political, social, and economic developments and the possibility of seizure or nationalization of companies or imposition of withholding taxes on income. Moreover, less information may be publicly available concerning certain foreign issuers than is available concerning U.S. companies. Foreign markets tend to be more volatile than the U.S. market due to economic and political instability, social unrest, and regulatory conditions in some countries. High Yield Bonds. Fixed income securities that are below investment grade or unrated involve greater risks of default and are more volatile than investment grade securities. High yield bonds involve a greater risk of price declines than investment grade securities due to actual or perceived changes in an issuer’s creditworthiness. In addition, issuers of high yield bonds may be more susceptible than other issuers to economic downturns, which may result in a weakened capacity of the issuer to make principal or interest payments. Commodities. The value of commodity-related instruments may be affected by changes in overall market movements, commodity index volatility, changes in interest rates, or risks affecting a particular industry or commodity, such as drought, flood, weather, livestock disease, embargoes, tariffs, and international economic, political, and regulatory developments. Energy Price Volatility. The performance of energy-focused investments may be substantially dependent upon prevailing prices of oil and natural gas. Historically, the markets for oil and natural gas have been volatile, and such markets are likely to continue to be volatile in the future. Prices for oil and natural gas are subject to wide fluctuation in response to relatively minor changes in the supply of and demand for oil and natural gas, market uncertainty, speculation, and a variety of additional factors that are beyond the control of RWR. 12 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Real Estate-Related Investments. Property values may fall due to increasing vacancies or declining rents resulting from economic, legal, cultural, or technological developments. Real estate companies are subject to legislative or regulatory changes, adverse market conditions, and increased competition. The general performance of the real estate industry has historically been cyclical and particularly sensitive to economic downturn. Changes in prevailing real estate values, interest rates, and changing demographics may affect the value of securities of issuers in the real estate industry. Reinsurance Investments. The principal risk of investments in a reinsurance-related security is that a triggering event (e.g., certain natural disasters like hurricanes or earthquakes or non-natural disasters like aviation disasters) of the underlying policies will occur and the investment will lose all or a significant portion of the principal that it has invested in the security and the right to additional interest payments with respect to the security. If multiple triggering investments occur that impact a significant portion of the portfolio of the investment, the investment could suffer substantial losses, and an investor would lose money. Risks Related to Use of Third-Party Managers Analysis. Our method of analysis poses three general risks: making an investment decision based on inaccurate or fraudulent information, making an investment decision based on incomplete or inaccurate due diligence, or making an investment decision based on complete and accurate due diligence that still results in poor investment performance. By investing with RWR, clients expose themselves to these risks. Underlying Investments. When we allocate client capital to third-party managers, clients assume all of the risks related to the manager’s underlying investment holdings, strategies and analytical methods, including compliance with the governing documents of any private fund investments. Clients are also exposed to risks regarding the financial and operational strength of an manager’s business as well as the risk of the manager engaging in insider trading or other illegal practices. To the extent investments are made in outside investment vehicles, the investment vehicles will generally not be registered as investment companies under the Investment Company Act of 1940. Neither limited partners nor the adviser will have the benefit of the protections afforded by the Investment Company Act to investors in registered investment companies. Compensation. Private fund investment managers that we recommend to clients generally are entitled to two forms of compensation (through a managed account arrangement or through their managed private funds): a fee based on net assets under management (typically up to 2% annually) AND performance compensation based on the appreciation (usually including unrealized appreciation) in the value of the investment account with the manager (typically up to 20% of net profits). While performance compensation arrangements may call for realized or unrealized losses to be carried forward as an offset against net profits in subsequent periods, investment managers generally are not otherwise penalized for realized losses or decreases in the value of investment accounts they oversee. These performance compensation arrangements may create an incentive for those investment managers to effect transactions that are particularly risky or speculative. Investments with private fund managers will also be subject to the expenses incurred by managing the client’s capital. These include, but aren’t limited to, costs related to the audit and administration of the accounts overseen by the investment managers or their advised private funds. Given the above, placing client assets with third party private fund investment managers will occasionally result in an additional layer of fees and expenses that will be incurred by our clients. Private Funds. We allocate client capital to third-party managers that manage private funds, which presents certain risks. These include but include but are not limited to the following considerations. Investments in private funds generally have restrictions on liquidity and often times make “in-kind” distributions of liquid and illiquid securities. Private funds also frequently have stale or delayed prices as such securities are not publicly traded and/or are more 13 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 difficult to value. Hedge funds and private equity firms in which we might invest may hold such assets. The price or NAV (Net Asset Value) of the private fund could be higher or lower than the market value of a similar publicly traded security. Though the risk of this occurrence is somewhat mitigated by private funds issuing annual audited financial statements, we make no guarantee that such mitigation will continue, fully or partially, in the future. Hedge Funds. For some of our clients, we recommend allocations to hedge funds. Such allocations have a number of risks which include but are not limited to the following considerations. The securities a hedge fund manager can trade and the manner in which a fund manages the money under its authority can create the risk of significant loss. We might recommend hedge funds that engage in short selling (which creates the potential for unlimited loss), utilize overt leverage through bank borrowings, or invest in esoteric securities that like CDS, futures, options, and swaps, all of which carry covert leverage. Also, hedge funds can hold concentrated positions in underlying investments which increases the risk of significant losses. In periods of high negative market volatility, such as 2008, hedge funds can fail to meet the high volume of redemption requests, which produces a “run on the bank.” In these situations, a hedge fund might establish gates or side-pockets to allow for capital to be returned in an orderly manner. Gates can significantly extend redemption schedules and side-pocket creation frequently makes securities more difficult to price, which causes any previously provided NAV statements to become outdated. The lack of regulation and the opaque nature of the hedge fund structure create the risk of possible misrepresentation, mispriced securities, or outright securities fraud. We have developed due diligence processes for hedge funds as well as their service providers (accountants, law firms, prime brokers, and administrators) to minimize this risk inherent with hedge fund investments on behalf of our clients. However, it cannot eliminate all forms of the risk of fraud. Private Equity Investments. For some of our clients, we recommend allocations to private equity investments. Such allocations have a number of risks which include but are not limited to the following considerations. Private equity allocations are very illiquid, long-term investments where capital is called gradually until the cumulative capital commitment is completed. This often requires a five to ten-year investment horizon. In cases where clients have unexpected liquidity needs, clients may have difficulty getting capital redemptions or selling their investment in a secondary market. Additionally, private equity investments often have investment returns that do not perform well during the fund’s early years, when capital is being called and put to work. This is sometimes referred to as the “J- Curve,” where private equity funds deliver negative returns in the beginning followed by increasingly strong investment gains as both the fund and the underlying portfolio companies mature. This risk combined with the liquidity risk reinforces the need for a long- term investment window for client investments in private equity. Item 9. Disciplinary Information Neither RWR, nor any of its directors, officers, or principals have been involved in any of the following: 1) criminal or civil actions in a domestic, foreign, or military court; 2) administrative proceedings before the Securities and Exchange Commission, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority; or 3) any self-regulatory organization proceedings. Item 10. Other Financial Industry Activities and Affiliations Neither RWR, nor any of its directors, officers, or principals are: 1) registered as a broker-dealer or a representative of a broker-dealer, or have an application pending to register as a broker-dealer or a registered representative of a broker- dealer; or 2) registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or are an associated person of any of the above. 14 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Relationships Material to this Advisory Business and Possible Conflicts of Interests RWR Investments has no material relationships or arrangements with any of the following: • broker-dealer, municipal securities dealer, or government securities dealer or broker; investment company or other pooled investment vehicle; • • other investment adviser or financial planner; futures commission merchant, commodity pool operator, or commodity trading advisor; • • banking or thrift institution; accountant or accounting firm; • lawyer or law firm; • insurance company or agency; • • pension consultant; OR real estate broker or dealer. • Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CODE OF ETHICS AND PERSONAL TRADING RWR has adopted a Code of Ethics which describes the general standards of conduct that we expect of all employees and focuses on three specific areas where employee conduct has the potential to adversely affect the client: • Misuse of nonpublic information • Personal securities trading • Outside business activities Failure to uphold the Code of Ethics may result in disciplinary sanctions, including termination of employment with RWR. Any client or prospective client may request a copy of our Code of Ethics which will be provided at no cost. The following basic principles guide all aspects of our business and represent the minimum requirements to which we expect employees to adhere: • Clients' interests must be placed above the interests of our firm and employees, unless otherwise stipulated in the applicable advisory agreement. • Our firm and our employees must comply with all applicable federal and state laws and regulations. • Employees must comply with all policies and procedures established by RWR to ensure compliance with applicable federal and state laws and regulations. • We must disclose all material facts, of which we are aware, about conflicts of interest between us or our employees and our clients. • Employees must disclose any activities that may create an actual or potential conflict of interest between our employees, our firm, and/or any client. • Employees must not take inappropriate advantage of their positions of trust and responsibility with clients or 15 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 RWR. • Employees must maintain the confidentiality of all information obtained in the course of employment with RWR. Material Non-Public Information RWR prohibits employees from trading on the basis of material non-public information for their own personal accounts or for our clients’ accounts. We further prohibit employees from communicating material non-public information to anyone outside RWR. Personal Securities Trading The principal and employees of RWR may buy and sell, in their personal accounts, the same securities that they also buy and sell for RWR clients. This creates a potential conflict of interest if RWR’s principal and employees receive more favorable execution prices than our clients. To mitigate this conflict, and to eliminate the potential for trading in advance of clients (front-running), we require all personnel to either 1) trade simultaneously with clients to ensure they receive the same price; or 2) place their trades at least one day after clients’ trades have been effected. All personnel are required to obtain pre-clearance before participating in an initial public offering or a private placement. Personnel are required to submit periodic reports of personal securities transactions and holdings, and to promptly report any Code of Ethics violations. Robert “Willing” Ryan III is the sole portfolio manager and principal of RWR and is responsible for administering our trading policies. He maintains records reflecting compliance with such policies. Outside Business Activities RWR personnel are required to obtain the approval of the CCO prior to engaging in any outside business activity. Outside business activities may include, but not be limited to, employment or contract work, teaching assignments, speaking engagements, publication of articles or books, radio or television appearances, and any other activity that involves a substantial time commitment. The CCO may prohibit activities that he believes may pose a significant conflict of interest with RWR or our clients. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS RWR personnel may not engage in principal transactions between a personal account and an account maintained by or for the benefit of any RWR client. RWR personnel may not arrange a cross transaction between one client account and another account if RWR, any employee, or affiliate will receive any compensation for acting as the broker (agency cross transaction.) Neither RWR’s principal, nor any of its employees, may recommend securities to clients in which they have a material financial interest. Item 12. Brokerage Practices SELECTING BROKER DEALERS We generally recommend that our clients establish custodial accounts at, and therefore receive custody, clearing, brokerage, and other services from Charles Schwab & Co., Inc. (“Schwab”). Schwab is a registered broker-dealer. RWR is independently owned and operated and not affiliated with Schwab. We consider a number of factors in selecting a broker and determining the reasonableness of its commissions for clients’ transactions, including, but not limited to, execution capability, experience and financial stability, cost and quality of services provided, generation of investment ideas, ease of correcting errors, quality of reports, access to 16 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 research, commission structure, accuracy and speed of execution. We periodically assess our broker dealer relationships to monitor quality of executions. Schwab Schwab is a member SIPC and provides RWR with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisers’ clients’ assets are maintained in accounts at Schwab Advisor Services and are not otherwise contingent upon RWR committing to Schwab any specific amount of business (assets in custody or trading). Schwab’s services include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Schwab enables RWR to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. For RWR’s client accounts maintained in its custody, Schwab generally does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab. RESEARCH AND OTHER SOFT-DOLLAR BENEFITS RWR does not receive soft dollars generated by transaction fees incurred in placing trades at Schwab. While we do not receive compensation from Schwab for recommending that our clients open accounts with Schwab, we do receive certain benefits including access to (i) client account data; (ii) electronic duplicate statements and confirmations; (iii) pricing and market data; (iv) dedicated institutional, administrative, and trading staff; (v) practice management information and publications; (vi) conferences and educational sessions; and (vii) institutional mutual funds that are not available to retail investors. These benefits may create a potential conflict of interest because clients will pay higher transaction fees than they might pay at other discount brokers. Though there are no known costs to clients resulting from these discounts and services that are provided by Schwab to RWR, there is a financial benefit to RWR. This creates an incentive for RWR to recommend Schwab over another custodian. It is RWR’s policy, however, not to consider the value of such services when recommending a custodian. The factors above are monitored informally on an on-going basis by our investment and operations personnel and by performing an assessment of these and other factors on a periodic basis. Based upon the factors listed above, we are responsible for making a good faith determination that the allocation of business and fees paid is reasonable in relation to the value of the transactions and services provided by counterparties that are used in connection with our clients’ investments. RWR May Consider Referrals in Selecting or Recommending Broker Dealers Subject to our obligation to seek best execution, we may consider client referrals in selecting broker dealers. To avoid this potential conflict of interest, we select brokers based on the criteria set forth above and may enter into a separate referral or similar agreement with such broker so that the brokerage activities are separate from any client referral activities. RWR Clients Do Not Direct Brokerage Clients are not permitted to direct RWR to execute transactions through a specified broker dealer. Trade Aggregation Transactions of the same security for multiple managed accounts are aggregated whenever possible. When trades are 17 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 aggregated, the average execution price will be applied to each participating client account. Ultimately, clients may benefit when we aggregate trades because they may receive volume discounts on execution costs. We do not enter into soft dollar arrangements with broker dealers. Item 13. Review of Accounts Client accounts are reviewed daily for trade accuracy. Additionally, accounts are reviewed regularly for investment strategy, style, balance, and exposure. Robert “Willing” Ryan III, the principal and sole portfolio manager of RWR, conducts these reviews. Additional reviews may be triggered by material market, economic, or political events. RWR provides regular performance reports to clients on a monthly and quarterly basis. Clients receive monthly reports directly from their custodian and quarterly reports from RWR and an independent third party. Item 14. Client Referrals and Other Compensation RWR does not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. We do not compensate any third party for client referrals. Item 15. Custody While it is RWR’s practice not to accept or maintain physical possession of any client assets, we are deemed to have custody of clients’ assets under Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended, because we have the authority to deduct fees from clients’ accounts. Clients sign separate contracts with custodians that are independent of their contracts with RWR. Clients receive account statements each month directly from their custodians with the required information, such as month-end security positions and transactions during that month. The managed account assets under RWR’s management are held with a qualified custodian who sends monthly account statements to the managed account holders. With respect to the Private Funds, RWR serves as the manager to one or more Private Funds. In its capacity as manager, RWR has the authority to move money for a Private Fund’s account. Therefore, RWR has custody of the Private Fund Client’s assets. Item 16. Investment Discretion RWR accepts discretionary authority to manage clients’ securities accounts. Essentially, this means that RWR has the authority to determine, without obtaining specific client consent, which securities to buy or sell and the amount of securities to buy or sell. Additionally, RWR has discretionary authority to determine the broker-dealer used and the commission rates to be paid when executing client transactions. Despite this broad authority, RWR is committed to adhering to the investment strategy and program set forth in the client’s investment management agreement, investment objectives, and risk tolerance parameters. In particular, RWR’s principal and portfolio manager reviews client accounts regularly to ensure that RWR is observing clients’ investment strategies and objectives. Item 17. Voting Client Securities RWR treats the voting rights of clients in a manner consistent with each client’s best interest. We first determine whether it is in a client’s best interest for RWR to exercise voting rights with respect to each particular security. If we determine that it is appropriate to vote, we consider our vote in light of the client’s particular investment objectives. As a general rule, we will vote if our clients own more than 3% of the common stock of the company and the issue being voted on is of material importance to the value of the investment. For client interests in private funds, we will also vote if we determine that the vote concerns an issue of material importance, regardless of the level of client 18 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 ownership of the private fund. Determination of material importance will be decided on a case-by-case basis. The portfolio manager makes all determinations as to whether and how to vote proxies or other voting rights of RWR clients. Factors the Adviser Considers When Determining Whether to Vote Proxies The portfolio manager considers the following factors, and any other factors he determines are relevant when deciding whether to vote a client proxy: the holding period of a security’s position; • the economic value of a security’s position; • • whether the cost of voting (e.g., required in-person voting at a distant location) will likely exceed the value of any potential benefits of voting; and • whether voting is impracticable due to timing or mechanics. When the portfolio manager determines that voting a proxy is in a client’s best interest, he uses all relevant factors and information at his disposal to determine how to vote in a client’s best interest. Clients cannot direct the portfolio manager’s proxy votes. Potential Conflicts of Interest RWR will identify any conflicts that exist between our interests and our clients by reviewing our relationship with the issuer of each security to determine if RWR or any of our employees have any financial, business, or personal relationship with the issuer. If a material conflict of interest exists, the portfolio manager will determine whether it is appropriate to disclose the conflict to the client, to give the client an opportunity to vote the proxy itself, or to address the voting issue through other objective means such as voting in a manner consistent with a predetermined voting policy or receiving an independent third-party voting recommendation. RWR will maintain a record of the voting resolution of any conflict of interest. Recordkeeping RWR maintains the following records relating to proxy voting: copies of RWR’s proxy voting policies and procedures and any amendments; • • proxy statements received for client securities; records of proxy votes cast on behalf of RWR clients; • • records of written requests from clients for proxy voting information and our written responses to any such written or oral requests; • any documents that RWR employees prepared that were material to deciding how to vote proxies or that memorialize the basis for a proxy vote; and • documentation of exceptions to the RWR’s proxy voting policies. Item 18. Financial Information RWR does not require or solicit prepayment of client fees more than six months in advance. We are not aware of any financial condition likely to impair RWR or any employees’ ability to meet our contractual commitments to our clients. RWR has never been the subject of a bankruptcy petition. 19 RWR Investments LLC | Form ADV, Part 2A: Brochure | April 2026 Item 1. Cover Page 3131 Turtle Creek Blvd, Suite 301 Dallas, Texas 75219 (214) 308-1970 www.rwrinvestments.com CRD #157966 Form ADV, Part 2B | Brochure Supplement Robert Willing Ryan III CRD #5937759 March 31, 2026 This Form ADV, Part 2B (this “brochure supplement”) provides information about Robert Willing Ryan III (CRD# 5937759) and supplements the RWR Investments LLC (“RWR”) brochure. You should have received a copy of that brochure. Please contact Mr. Ryan at the telephone number above if you did not receive the brochure or if you have any questions about the contents of this supplement. information about Mr. Ryan and RWR is available on the SEC’s website at Additional www.adviserinfo.sec.gov. RWR Investments LLC | Form ADV, Part 2B: Brochure Supplement | March 2026 1 Robert Willing Ryan III Managing Director & CIO RWR Investments LLC 3131 Turtle Creek Blvd, Suite 301 Dallas, Texas 75219 wryan@rwrinvestments.com Item 2. Educational Background and Business Experience Robert Willing Ryan III was born in 1979. He is the President and Chief Investment Officer of RWR Investments LLC (“RWR”), which he founded in March 2011. Mr. Ryan has more than twenty years of experience in the financial industry and over $1 billion in corporate finance and real estate transaction experience, on and off Wall Street. Prior to RWR, Mr. Ryan was a senior associate in the Capital Markets Group of the Lone Star Funds (2010- 2011). Together with its integrated asset manager, Hudson Advisors, Lone Star is one of the largest global private equity firms in the U.S. Previously, Mr. Ryan was an associate with Covalent Capital, LLC, a boutique private equity firm focused on middle market companies in the southwestern United States (2007- 2010). Mr. Ryan began his investment career at J.P. Morgan, where he was an analyst in the Mid-Corporate Investment Banking Group providing analysis on M&A and debt and equity placements (2004-2006). Mr. Ryan received a Bachelor of Arts degree in Economics, with a minor in Business, from The University of Texas (2002) and a Master of Business Administration from Southern Methodist University (2009). Item 3. Disciplinary Information Mr. Ryan has been involved in no legal or disciplinary events that are material to a current or prospective client’s evaluation of this advisory business. Item 4. Other Business Activities Mr. Ryan is not engaged in any investment-related business or occupation outside of RWR. Item 5. Additional Compensation Other than any additional compensation outlined in Item 4, RWR is the sole source of compensation for Mr. Ryan’s business activities. Item 6. Supervision All investments which may be recommended to clients, as well as the use of any third-party adviser, are subject to the approval of Mr. Ryan, as RWR’s Chief Investment Officer, under the supervision of Parit Patel, Chief Financial Officer and Chief Compliance Officer. Mr. Patel is responsible for supervising the advisory activities of Mr. Ryan, as well as monitoring the investment advice that is provided to RWR’s clients. In addition, Mr. Ryan must comply with RWR’s compliance policies and procedures. The compliance policies and procedures are designed to detect and prevent violations of the Investment Advisers Act of 1940, the Securities Act of 1933, and other laws RWR Investments LLC | Form ADV, Part 2B: Brochure Supplement | March 2026 2 applicable to RWR. All personnel are required to comply with applicable securities laws. Appropriate disciplinary action will be taken for failure to comply with the requirements of RWR’s compliance policies and procedures, as well as applicable federal, state, and local securities laws and regulations. Parit Patel serves as RWR’s Chief Compliance Officer and is responsible for supervising each of RWR’s personnel (including, without limitation, Mr. Ryan), in accordance with RWR’s policies and procedures. Mr. Patel can be reached at (214) 308-1970. RWR Investments LLC | Form ADV, Part 2B: Brochure Supplement | March 2026 3