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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.
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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.
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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
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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
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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
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• 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
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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.
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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
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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
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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
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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.
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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
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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.
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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
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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
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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
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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
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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.
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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