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Form ADV Part 2A: Firm Brochure
RYAN INVESTMENTS
22860 Two Rivers Road, Suite 200
Basalt, CO 81621
Telephone: (970) 429-1100 Facsimile: (970) 429-9495 E-mail: info@ryaninvest.com
Web Address: www.ryaninvest.com
Revised 04/01/2026
This brochure provides information about the qualifications and business practices of Ryan Investments
(hereinafter “RI” or “firm” or “we”). If you have any questions about the contents of this brochure, please
contact us at (970) 429-1100, or at info@ryaninvest.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about RI is available on the SEC’s website at www.adviserinfo.sec.gov. You can search
this site by a unique identifying number, known as a CRD number. The CRD number for RI is 115755.
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Item 2. Summary of Material Changes
On April 1, 2026, Ryan Investments (CRD#115755) and Yule Creek Wealth Management, LLC
(CRD# 322800) combined businesses in a statutory merger. The surviving entity will be Ryan
Investments, and it will continue to operate under CRD #115755, as it has for the past 25 years.
The purpose of the merger was to provide both of the prior firms with a bigger and stronger team of
professionals and a firm with more continuity and sustainability to better serve clients for decades
to come. All personnel were retained in the merger.
Ryan Investments now offers municipal bond portfolio management services in addition to its
existing iFolios active allocation strategy. The firm revised certain disclosures regarding ownership,
fees, advisory business, brokerage practices, new advisory personnel, and account review
responsibilities.
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Item 3. Table of Contents
Item
Section
Page Number
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Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance-Based Fees and Side-by-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in
Client Transactions, and Personal Trading
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14.
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18.
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
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Item 4. Advisory Business
Ryan Investments is a fee-based SEC-registered investment advisor. Our SEC file number is 801-
60589 and our CRD# is 115755. Our principal office is in Basalt, Colorado. We have been in
business since 2001. Christopher S. Ryan, CFA, CEO/CIO, is the firm’s principal owner. Matthew A.
Owings, CFA, CFO, and Nathaniel L. Kaup, CFA, CCO, own minority interests.
Assets Under Management
Ryan Investments currently manages approximately $272,033,000 of client assets with
discretionary investment authority.
Wealth Management and Portfolio Management
Our process starts with a conversation and an inventory of our clients’ net worth. We have
discussions with our clients about their goals and objectives, needs for growth, income, and
liquidity, their tax issues, views about risk, and any other unique circumstances. As wealth
managers, we strive to understand how our clients’ assets and debts are titled, how they allocate
strategies to taxable and tax-deferred accounts, their beneficiary designations, their current and
expected cash flow needs, and how their estate plan is designed. We may, depending on client
demand, prepare written statements and analysis to facilitate providing clients with comprehensive
wealth advice, primarily, a written net worth statement. Based on our understanding of our client,
we can then assess and recommend a suitable, overall global allocation. For the portion of assets
that we manage in-house at Ryan Investments, which could include global equities, global fixed
income, some alternative asset classes, and some hedging strategies, we will outline our
recommendations for client approval.
We manage most of our clients’ global equity, global fixed income, alternative assets, and hedging
strategies, using our iFolios® strategy on a discretionary basis. That means that once we have
agreed with the client about which iFolio model is appropriate, we will execute the day-to-day
transactions without seeking prior client consent. Account management and trading are guided by
the objectives and selected iFolio model of that client. We build iFolios using index funds and index
exchange traded funds (ETFs). Our decision to buy or sell a holding is primarily based on the
current price trend of that holding. Our iFolios investment strategy is fully explained in Item 8,
below. On occasion, one of our iFolios models is not the best fit for a client and we will develop a
custom investment strategy.
In addition to our iFolios strategy, we offer municipal bond portfolio management services. These
services may be provided as a standalone service or as a component of a broader client portfolio
managed by RI. Our municipal bond strategy is well suited for high-net-worth clients seeking tax-
efficient income and/or capital preservation. We may occasionally incorporate taxable fixed-income
securities depending on each client’s circumstances.
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We may, rarely, accept portfolios with certain restrictions, less than full discretion, or
nondiscretionary capabilities if circumstances warrant.
Item 5. Fees and Compensation
Equity/Balanced Portfolios:
Fees for equity and balanced portfolios are based on Assets Under Management (AUM) in the equity
and/or balanced portfolio(s). The management fee schedule is as follows:
AUM $
Fee %
First $2 million 1.00%
Next $3 million 0.75%
Over $5 million 0.60%
As an example, a $5m householded equity/balanced portfolio(s) would pay a blended rate of 0.85%
per year.
Municipal Bond Portfolios:
Fees for customized municipal bond portfolios are based on AUM in the bond portfolio(s). The
municipal bond management fee schedule is as follows:
AUM $
Fee %
First $2 million 0.60%
Next $3 million 0.45%
Over $5 million 0.35%
As an example, a $5m householded municipal bond portfolio(s) would pay a blended rate of 0.51%
per year.
Under certain limited circumstances, we may negotiate account minimums and fees.
Fees in General
Clients that have multiple accounts that are included in one household (e.g., spouse, IRAs, trusts,
and children under age 26) may be aggregated for fee purposes within the same fee schedule, as
described below. Each account is assigned to one of our two fee schedules above. For purposes of
calculating management fees, we aggregate (“household”) all accounts held by a client or related
client accounts that are assigned to the same fee schedule. Accounts assigned to different fee
schedules are not combined for purposes of determining fee break points or calculating
management fees. As a result, if a client maintains accounts under both fee schedules, each fee
schedule is applied and billed separately based on the assets assigned to that schedule.
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Management fees are charged in arrears at the end of each month, based upon the value of the
managed assets in your account(s) on the last business day of the month. With your written
authorization, we will directly debit your account(s) for portfolio management fees. Clients may
terminate the investment advisory agreement at any time by providing us with notice or by
notifying the independent custodian. Fees are payable through the termination date, and there is no
additional cancellation fee.
Mutual Fund and ETF Fees and Expenses
RI only earns fees based on portfolio management fees, discussed above. Our fees are separate and
distinct from any other fees and expenses that may be embedded in mutual funds and ETFs. These
fees and expenses are described in each fund's prospectus. These fees are typically embedded into
the price of the index fund or ETF, and so are not paid for with cash. Rather, these fees reduce the
gross performance of the fund. These fees may include a fund manager fee, other fund expenses,
and a possible distribution fee. RI uses low-cost index funds and ETFs. Fund expenses of these index
ETF are typically low, in the 0.04% to 0.20% range. RI receives no part of these fund-level fees.
You could invest in a mutual fund or ETF directly, without the services of our firm. In that case, you
would not receive the services provided by us which include fund selection, allocation decisions,
trading decisions, and performance review. You should review both the fees charged by RI as well
as fees charged by the funds and ETFs to evaluate the advisory services being provided.
Brokerage and Custodial Fees
In addition to management fees paid by you to our firm, clients will also be responsible for all
transaction, brokerage, prime-broker, trade-away, and custodial fees incurred as part of their
account management, if any. Currently, our chosen custodian, Charles Schwab & Co., does not
charge for custodian or online trading services. Please see Item 12 of this Brochure for important
disclosures regarding our brokerage practices.
Item 6. Performance-Based Fees and Side-By-Side Management
We do not charge any fees based on a share of capital gains or capital appreciation of the assets of a
client.
Item 7. Types of Clients
Our firm provides wealth management services to high-net-worth investors and non-profits. We
have a minimum investment requirement of $1 million for equity/balanced portfolios, and $2
million for customized municipal bond portfolios. Our firm occasionally works with family offices
and other advisory firms to provide portfolio management services to their end-clients in a sub-
advisory capacity.
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We seek clients who are looking for a wealth management team to meet their overall financial goals.
By taking a comprehensive view of our clients’ overall wealth, we can better coordinate their total
portfolio and work better with their CPAs and attorneys. We feel it is important for us to fully
explain our recommendations and strategies, and to educate our clients about our investment
strategies, including iFolios and municipal bonds. For every portfolio that we manage, we are
always mindful of a dual objective to provide growth and income, while always being mindful of
drawdown risk. Our clients tend to appreciate this dual objective.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Our iFolios Strategy Explained: We subscribe to the basic premise of defining objectives, matching
objectives to an appropriate asset allocation, using global diversification to construct portfolios, and
providing risk management. We’ll get to know you, your goals, and concerns, and then we’ll develop
a personalized asset allocation plan that is appropriate for your needs. Your allocation plan will be
globally diversified with various asset classes depending on your needs. We’ll build your portfolio
primarily with low-cost and tax-efficient index funds and exchange traded index funds (ETFs), one
for each asset class in your asset allocation plan. Typically, a portfolio might hold 6 to 12 different
and diversified index funds and/or ETFs.
The key to our strategy, and what makes us unique, is that we actively manage each portfolio using
price trend-following discipline. Trend-following is a systematic and disciplined method to
determine whether an asset price is trending up or down. We have developed our own set of rules
for determining the price trend, which is based on factors like moving averages and other technical
indicators. Trend-following differs from “market timing” in that we aren’t guessing about what the
market is going to do; we’re just determining what it is doing right now. It differs from “value
investing” in that we aren’t estimating that a holding is “under-valued” using some metric and
hoping that it will rise in price as others discover its value. Our iFolios strategy, based on trend-
following, simply acknowledges what prices are factually doing, and invests accordingly.
To summarize, we manage money using active allocation strategies. We’re trying to improve upon a
buy & hold passive strategy by diversifying globally, reducing costs by using index funds, being fully
invested in a holding when its price is trending up (capturing growth) and selling or trimming back
a holding when its price is trending down (providing protection). We’re not focused on making
predictions and being “right”; we’re focused solely on your portfolio’s performance in both up and
down markets. On occasion, when suitable for each client, we may use inverse index ETFs to further
hedge a portfolio and add downside protection. Inverse ETFs are designed to track the daily
performance of an index and do not track an index over the long term. For this reason, we use
inverse ETFs for short-term hedging purposes, generally for several weeks to several months at a
time.
By following our strategy, our portfolios will be well diversified, fully invested in uptrending markets,
and under-weight in downtrending markets, capturing the available growth and reducing major
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losses. Your plan will be discussed with you in advance, so you will always know that your portfolio
is invested according to the terms you’ve agreed to.
Our Municipal Bond Strategy Explained: In addition to the iFolios strategy described above, we
manage municipal bond portfolios consisting primarily of municipal bonds and other fixed income
securities. These portfolios may be managed on a standalone basis or as part of a broader client
allocation.
Our strategy uses both portfolio-level and security-level analysis. At the portfolio level, we consider
factors such as interest rates, yield curve positioning, credit conditions, and the client’s objectives
for income, liquidity, and preservation of capital. At the security level, we evaluate factors such as
issuer quality, bond structure, maturity, duration, credit risk, and market liquidity.
While primarily focused on municipal bonds for tax-efficient income, we may invest in individual
corporate, treasury and agency bonds, fixed-income ETFs, or a combination of both, depending on
the client’s objectives and circumstances.
Fixed income investing involves certain additional risks. These risks include interest rate risk, call
risk, reinvestment risk, liquidity risk, credit risk, and the risk of issuer default. Municipal bonds may
also be affected by changes in tax law or other legislative developments that could reduce the value
of their tax-exempt status. In certain cases, municipal bonds purchased at a discount may also
involve adverse tax consequences.
Clients should understand that investing in any securities, including index mutual funds and exchange traded
funds (ETFs), involves a risk of loss of both income and principal that a client must be prepared to bear.
Item 9. Disciplinary Information
Our firm has no reportable disciplinary events to disclose.
Item 10. Other Financial Industry Activities and Affiliations
We have no other financial industry activities and / or affiliations.
Item 11. Code of Ethics, Participation in Client Transactions, and Personal Trading
As required by the SEC, our firm has adopted a Code of Ethics which sets forth high ethical
standards of business conduct that we require of our employees, including compliance with
applicable federal securities laws. Our Code of Ethics includes policies and procedures for the
review of our employees’ personal trading accounts. The review includes quarterly securities
transactions reports as well as initial and annual securities holdings reports that must be submitted
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by all employees. Our code provides for oversight, enforcement, and recordkeeping provisions. A
copy of our Code of Ethics is available to our advisory clients and prospective clients upon request.
For our clients’ portfolios, we primarily trade exchange-listed funds and individual fixed income
securities. It is possible that individual employees associated with our firm may buy or sell
securities identical to those purchased for customers in their personal accounts. In addition,
employees may have an existing interest or position in certain securities which may also be held by
clients. This practice results in a potential conflict of interest, as employees could have an incentive
(to the extent possible) to manipulate the timing of such purchases to obtain a better price for
themselves or more favorable allocation in rare cases of limited availability.
To mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary
responsibilities, we have established the following restrictions:
1.
No principal or employee of our firm may buy or sell securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of
his or her employment unless the information is also available to the investing public on
reasonable inquiry. No principal or employee of our firm may prefer his or her own
interest to that of the advisory client.
2.
It is the policy of our firm that no person employed by us may, without the express
consent of the firm’s Chief Compliance Officer, purchase or sell any security prior to a
transaction(s) being implemented for an advisory account, and therefore preventing such
employees from benefiting from transactions placed on behalf of advisory accounts.
3. We maintain a list of all reportable securities holdings for our firm, and anyone associated
with this advisory practice with access to advisory recommendations. These holdings are
reviewed on a regular basis by Nathaniel L. Kaup, Chief Compliance Officer.
4. We maintain a list of fixed income securities that require written pre-clearance before any
employee may place or execute transactions. This list primarily serves to mitigate conflicts
of interest with less liquid asset classes we trade in, primarily, individual municipal bonds.
5. We may aggregate employee trades with client trades, ensuring identical and fair
execution.
6. We emphasize the unrestricted right of the client to decline to implement any advice
rendered, except in situations where our firm is granted discretionary authority.
7.
All principals and employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
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8.
Any individual not in observance of the above may be subject to disciplinary action or
termination.
Item 12. Brokerage Practices
We do not have any formal or informal soft-dollar arrangements and do not receive any soft-dollar
benefits.
RI has authority to select the custodian and broker-dealer for accounts and will base our choice
based on financial security, best execution, commission and fees, and benefit to our clients. We do
not normally accept advisory clients’ instructions for directing a client’s brokerage transactions to a
particular broker-dealer. At this time, we have chosen Schwab Institutional as our broker-dealer. RI
executes certain fixed-income transactions through 3rd party broker-dealers in order to access
specific bond offerings, improve execution, or obtain more favorable pricing. We transact with 3rd
party broker-dealers utilizing Schwab’s prime brokerage relationship service. Schwab charges a flat
dollar amount per trade as a “Prime Broker” or “Trade Away” fee for trades executed at another
brokerage firm, paid by the client.
Our firm participates in the Schwab Institutional (SI) services program offered to independent
investment advisors by Charles Schwab & Company, Inc. (“Schwab”), an unaffiliated FINRA-
registered broker dealer. Clients in need of brokerage and custodial services will have Schwab
recommended to them. As part of the SI program, our firm receives benefits from Schwab. These
benefits include: receipt of duplicate client confirmations and bundled duplicate statements; access
to a trading desk serving SI participants exclusively; access to block trading which provides the
ability to aggregate securities transactions and then allocate the appropriate shares to client
accounts; ability to have investment management fees deducted directly from client account;
access, for a fee, to an electronic communication network for client order entry and account
information; receipt of compliance publications; and access to mutual funds which generally
require significantly higher minimum initial investments or are generally available only to
institutional investors. The benefits received through participation in the SI program may or may
not depend upon the number of transactions directed to, or amount of assets custodied by, Schwab.
Participation in the SI program may result in a potential conflict of interest for our firm, as the
receipt of the above benefits creates an incentive for us to recommend Schwab to clients. It should
be noted that we receive no fees, rebates, or any kind of monetary compensation from Schwab.
Nonetheless, we have reviewed the services of Schwab and recommend their services based on
several factors. These factors include the professional services offered, commission rates, and the
custodial platform provided to clients. While, based on our business model, we will not seek to
exercise discretion to negotiate trades among various brokers on behalf of clients, we will, however,
periodically attempt to negotiate lower commission rates for our clients with Schwab.
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If a client, when undertaking an advisory relationship with our firm, already has a pre-established
relationship with a broker other than Schwab and asks us to execute all transactions through that
broker, it should be understood that under those circumstances we may not have the ability to
negotiate commissions, obtain volume discounts and best execution may not be achieved. In
addition, under these circumstances a disparity in commission charges may exist between the
commissions charged to other clients since our firm may not be able to aggregate orders to reduce
transaction costs or the client may receive less favorable prices.
We reserve the right to decline acceptance of any client account for which the client directs the use
of a broker if we believe that this choice would hinder our fiduciary duty to the client and/or our
ability to service the account.
Trade Aggregation: We may aggregate client trades when doing so is advantageous to our clients.
Mostly, we will batch client transactions to receive volume discounts and to obtain better and more
uniform pricing across client accounts. If we determine that aggregation of trades in a certain
situation will be beneficial to our clients, transactions will be averaged as to price and will be
allocated among our clients in proportion to the purchase and sale orders placed for each client
account on any given day. Any exceptions from the pro-rata allocation procedure will be carefully
explained and documented. Such exceptions may occur due to varying cash availability across
accounts, divergent investment objectives and existing concentrations, and desire to avoid “odd
lots” (an amount of a security that is less than the normal unit of trading for that particular
security). Certain fixed income securities may be available only in limited quantities. When that
occurs, we will allocate those securities among eligible client accounts in a manner that we believe
is consistent and fair, considering factors such as suitability, account size, portfolio structure,
available cash, and existing exposures.
Item 13. Review of Accounts
Portfolio Management/Model Portfolio Management Services
The following individuals are primarily responsible for client account reviews:
Christopher S. Ryan, CFA, CEO & CIO, Sr. Wealth Advisor
Matthew A. Owings, CFA, CFO, Sr. Wealth Advisor
Nathaniel L. Kaup, CFA, CCO, Wealth Advisor
William T. Van Domelen, CFP, Manager, Portfolio Trading
The above individuals work as a team to continuously monitor the underlying securities in client
accounts and perform regular reviews of account holdings for all clients. All accounts are reviewed
for consistency with client investment strategy, asset allocation, risk tolerance and performance
relative to the appropriate benchmark. More frequent reviews may be triggered by changes in an
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account holder’s personal, tax, or financial status. Geopolitical and macroeconomic specific events
may also trigger reviews.
In addition to the monthly statements and confirmations of transactions that clients receive from
their broker dealer, our firm will provide periodic Portfolio Review reports which review
investment objective, asset allocation, investment holdings, and portfolio performance.
Item 14. Client Referrals and Other Compensation
Other than items already described in this Brochure, our firm does not receive any additional
compensation from third parties for providing investment advice to its clients and does not
compensate anyone for client referrals.
Item 15. Custody
Custody is defined as any legal or actual ability by our firm to access client funds or securities. Since
all client funds and securities are maintained with a qualified custodian, we do not take physical
possession of client assets. However, under the current SEC rules, our firm is deemed to have
constructive custody of client assets solely due to our ability to debit management fees in arrears
directly from client accounts. We urge clients to carefully review and compare their Portfolio
Review reports received from us to reports they receive from their custodian(s). Should you notice
any discrepancies, please notify us and/or your custodian as soon as possible.
Item 16. Investment Discretion
For clients granting us discretionary authority to determine which securities and the amounts of
securities that are to be bought or sold for their account(s), we request that such authority be
granted in writing, typically in the executed investment advisory agreement and custodial
paperwork.
Should the client wish to impose reasonable limitations on this discretionary authority, such
limitations shall be included in this written authority statement. Clients may change/amend these
limitations as desired. Such amendments must be submitted to us by the client in writing.
Item 17. Voting Client Securities
Advisory clients generally elect to delegate their proxy voting authority to us. Alternatively, clients
may, at their election, choose to receive proxies related to their own accounts. To direct us to vote a
proxy in a particular manner, clients should contact Nathaniel L. Kaup, Chief Compliance Officer, by
telephone, electronic mail, or in writing. We only accept proxy voting responsibility for portfolios
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we manage with discretionary authority. Please note that index funds and ETFs require the index
fund provider (iShares, Vanguard, etc.) to vote proxies. Since Ryan Investments uses index funds
and ETFs almost exclusively, we rarely vote any proxies.
When we have discretion to vote proxies for our clients, we will vote those proxies in the best
interests of our clients and in accordance with our established policies and procedures. Our firm
will retain all proxy voting books and records for the requisite period of time, including a copy of
each proxy statement received, a record of each vote cast, a copy of any document created by us
that was material to making a decision how to vote proxies, and a copy of each written client
request for information on how the advisor voted proxies. If our firm has a conflict of interest in
voting a particular action, we will notify the client of the conflict and retain an independent third
party to cast a vote.
Clients may obtain a copy of our complete proxy voting policies and procedures by contacting
Nathaniel L. Kaup directly. Clients may request, in writing, information on how proxies for his/her
shares were voted. If any client requests a copy of our complete proxy policies and procedures or
how we voted proxies for his/her account(s), we will promptly provide such information to the
client.
Item 18. Financial Information
RI charges fees in arrears, rather than in advance, and therefore it is not required to include our
firm’s balance sheet with this brochure. That said, RI has no financial impairments that would
preclude the firm from meeting contractual commitments to clients nor has RI or its principals ever
been the subject of a bankruptcy petition.
ACKNOWLEDGMENTS
This is to acknowledge that I/We have read and understood this General Information and
Disclosure Statement of Ryan Investments, Registered Investment Advisor.
x_________________________________________
Client
x_____________________
Date
x_________________________________________
Client
x_____________________
Date
x_________________________________________
Ryan Investments
x_____________________
Date
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Privacy Policy
On November 12, 1999, President Clinton signed into law financial modernization legislation, entitled
the Gramm-Leach-Bliley Act (GLBA). GLBA establishes the first comprehensive federal privacy mandate
for all financial institutions. On March 2, 2000 the Securities & Exchange Commission proposed
Regulation S-P, which now passed, requires Investment Advisors (as well as other investment
companies and broker-dealers) to provide clear and conspicuous notice regarding their privacy policies
and practices, to describe to consumers the conditions under which the firm may disclose “nonpublic
personal information” to nonaffiliated third parties, to provide a method for consumers to “opt out” of
the disclosure of non-public personal information to third parties, to adopt policies and procedures
reasonably designed to ensure the confidentiality of customer records and information, to protect
against threats or hazards to the security of customer records and information, and to protect against
unauthorized access or use of customer records or information that could result in “substantial harm or
inconvenience” to any consumer.
Ryan Investments understands that protecting your financial privacy is just as important as protecting
your financial assets. We are committed to the responsible use of personal information to provide you
with the services that you want, and to help you achieve your financial goals. This statement of our
privacy policy is intended to help you understand the ways in which we gather, use, and protect your
financial information.
This Privacy Policy describes the way that we treat nonpublic personal information that we may obtain
from our customers or from consumers generally.
Collection of Nonpublic Personal Information
We collect information to provide financial advisory and investment management services to you, to
protect you from fraud, and to make available products and services that may be of interest to you. We
collect nonpublic personal information about you from the following sources:
Information you relay directly to us. This most often is comprised of verbal descriptions of your
financial circumstances and goals, as well as investment account statements, tax returns, estate
planning documents, and other items you may provide. Additionally, you may direct others, such
as your accountant or attorney, to provide information about you to us.
Information we receive from you through transactions, correspondence, and other
communications with us: and
Information we otherwise obtain from you in connection with providing you with a financial
product or service.
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Information Sharing with Non-Affiliate Third Parties
We do not share any nonpublic personal information about our customers or former customers with
anyone, unless required by law or permitted by law, directed by you, or enumerated below. For
example, you may ask us to supply certain information directly to your accountant, attorney or perhaps
to your banker. Additionally, we may disclose limited information to companies or organizations that
help us maintain and service your account. For instance, we will share limited information with our
primary custodian, Charles Schwab & Co., if it is required by them to properly service or update your
account. In addition, we may share nonpublic personal information to protect against fraud. Finally, we
may share limited information with our accountants, auditors or other service providers as required by
us to responsibly operate and monitor our business and comply with regulatory requirements.
Security
For your protection, Ryan Investments maintains security standards and procedures that we continually
update to safeguard against unauthorized disclosure of information or access to information about you.
We restrict access to nonpublic personal information about you to those individuals who need to know
that information to provide products and services to you. We maintain physical, electronic and
procedural safeguards that comply with federal regulations to guard your nonpublic personal
information.
Ryan Investments continuously reminds its employees of the importance of protecting confidential
information. All employees of Ryan Investments are required to sign a Non-Disclosure Agreement as a
condition of their employment and continued employment with the company.
In securing electronic records, we make extensive use of password protection. Our computers reside
behind a firewall to protect against unauthorized access. Backups of client data occur periodically and
are stored in an appropriate medium. This data is stored in an offsite location. All documents containing
client identification or non-public personal information that are being discarded are shredded, first.
Transmission of client data to Schwab Institutional is encrypted using special encryption with Secure
Server Certification Authority from RSA Data Security, Inc.
Email: Ryan Investments uses email to communicate with certain consumers and customers. While we
do not share non-public personal information conveyed via email, except as described above, it is
possible that email transmissions can be read by unauthorized third parties, including internet service
providers or computer hackers.
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