Overview
Assets Under Management: $288 million
Headquarters: SAN DIEGO, CA
High-Net-Worth Clients: 128
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (DEAN ROLAND RUSSELL - PART 2A)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $2,000,000 | 1.00% |
$2,000,001 | $3,000,000 | 0.50% |
$3,000,001 | $5,000,000 | 0.40% |
$5,000,001 | and above | 0.30% |
Minimum Annual Fee: $7,500
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $10,000 | 1.00% |
$5 million | $33,000 | 0.66% |
$10 million | $48,000 | 0.48% |
$50 million | $168,000 | 0.34% |
$100 million | $318,000 | 0.32% |
Clients
Number of High-Net-Worth Clients: 128
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 95.45
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 561
Discretionary Accounts: 561
Regulatory Filings
CRD Number: 109480
Last Filing Date: 2024-03-15 00:00:00
Website: HTTP://WWW.DRRWEALTH.COM
Form ADV Documents
Primary Brochure: DEAN ROLAND RUSSELL - PART 2A (2025-03-24)
View Document Text
Part 2A of Form ADV
Brochure
Item 1
Cover Page
16880 West Bernardo Drive, Suite 170
San Diego, CA 92127
858.485.8547
drrwealth.com
March 19, 2025
This Brochure provides information about the qualifications and business practices of Dean Roland Russell, LLC
(“Dean Roland Russell”). If you have any questions about the contents of this Brochure, please contact Marc
Roland by email marc@drrwealth.com or phone, 858.485.8547. 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.
Dean Roland Russell is a registered investment advisor. Registration as an investment adviser does not imply any
level of skill or training. The oral and written communications of an Investment Advisor provide you with
information from which you determine whether to hire or retain an investment advisor.
Additional information about Dean Roland Russell also 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 Dean Roland Russell is 109480. You can also search for our firm “Dean Roland Russell.”
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Form ADV Part 2A
Item 2 | Material Changes
These changes are only those since our last year’s Annual Amendment dated March 15,
2024.
No Material Changes were made in this update.
Pursuant to SEC rules, we will ensure that you receive a summary of any material changes to this
and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may
provide other disclosure information about material changes as necessary.
We will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Our brochure may be requested by contacting us and is also available on our website
www.drrwealth.com. It is always free of charge.
Additional information about Dean Roland Russell is available via the SEC’s website
www.advisorinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with Dean Roland Russell who are registered, or required to be registered, as investment
advisor representatives of Dean Roland Russell.
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Item 3 | Table of Contents
Cover Page
1
Item 1
Material Changes
2
Item 2
Table of Contents
3
Item 3
Advisory Business
4
Item 4
Fees and Compensation
5
Item 5
Performance-Based Fees and Side-By-Side Management
6
Item 6
Types of Clients
6
Item 7
Methods of Analysis, Investments Strategies and Risk of Loss 7
Item 8
Disciplinary Information
9
Item 9
Other Financial Industry Activities and Affiliations
9
Item 10
Code of Ethics
10
Item 11
Brokerage Practices
10
Item 12
Review of Accounts
15
Item 13
Client Referrals and Other Compensation
16
Item 14
Custody
16
Item 15
Investment Discretion
17
Item 16
Voting Client Securities
18
Item 17
Financial Information
19
Item 18
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Item 4 | Advisory Business
We are a fee-only (we are solely compensated by our clients, sell no products and receive no
commissions or referral fees), SEC-registered investment advisor located in San Diego, California.
We, including predecessor firms (Dean Consulting & Associates), have been in business since
1988. Currently, we have approximately 169 clients/families and manage $314,070,000.
Marc Roland and Andrew Russell have worked together for over twenty years and are the firm’s
managing members. Marc and Andrew each own a 50 percent interest in the firm.
We offer fee-only wealth management services primarily to high net-worth individuals and
families to help them meet their short-term and long-term personal financial goals. Our niche is
providing personalized, customized services. In order to perform our wealth management services
well, we meet with our clients and work with them to outline their financial circumstances and
investment objectives. Each client’s portfolio is tailored for that client’s specific needs, goals and
risk tolerances.
Our services can include reviewing and making recommendations on some or all the following
(the below areas are reviewed as needed or on request during ongoing monitoring):
• Defining and quantifying goals and priorities;
•
Insurance/risk management.
Investment strategies/advisory – may include some or all of the following: an evaluation
of current portfolio, education on investments, development of a personalized asset
allocation (investment mix), trade execution and rebalancing in accordance with your
asset allocation;
• Retirement planning;
• Personal income tax and cash flow planning;
• Educational funding;
• Estate planning, multi-generational planning, legacy charitable planning;
•
Once you choose an overall investment mix (“asset allocation”), we select the specific securities
that will make up the desired mix of assets. We will use mutual funds, stocks, bonds, exchange-
traded funds (ETFs), cash-equivalents, and other instruments. We will consider your personal
situation, income and liquidity needs, time horizon, legal and tax constraints, and other special
circumstances. Many times, our recommendations are determined primarily from tax, cash flow,
and estate planning considerations rather than the intrinsic merits of the specific security as an
investment.
The financial planning items mentioned may include the preparation of financial plans and
analyses as well as financial statements showing net worth, cash flow, and income tax projections.
We develop models that test how well your desired expenses match your expected financial
resources.
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Item 5 | Fees and Compensation
Fees for Ongoing Wealth Management Services
We charge fees based on a standard fee schedule, as described below, that we believe is market-
based and competitive. Our standard fee schedule, ranges from 1% to 0.3% of the value of your
portfolio, per annum, with a minimum annual fee of $7,500. All fees are subject to negotiation.
The way we charge for ongoing wealth management services is established in your written
agreement with us. We bill our fees quarterly, in arrears. Your quarterly fee is calculated as one
quarter of the percentage outlined in the agreed-upon fee schedule. Fees are based on the value of
the managed portfolio on the last day of the calendar quarter (excluding any self-managed accounts
or securities) without reduction for margin borrowing and regardless of whether the assets are in
cash or other securities. You authorize us to directly debit the fees from specific client accounts
designated by you. The wealth management fee accrues daily and is payable on the last day of the
calendar quarter or on the effective date of termination.
Investable Assets
annually
$2,000,001 to $3,000,000
$0 to $2,000,000*
$3,000,001 to $5,000,000
Greater than $5,000,000
Annual Fee
1.0% (0.01)
0.5% (0.005) annually
0.4% (0.004) annually
0.3% (0.003) annually
*Minimum annual fee = $7,500
Example: If we are managing $3,000,000 of assets for you, $2,000,000 @ 1.0%
($20,000), plus $1,000,000 @ 0.5% ($5,000) would equal an annual average fee of
0.83%, or $25,000.
Depending on the existing agreement, some clients could have wealth management fees calculated
based on the value of the managed portfolio on June 30 of each year.
We do not receive any fees or compensation related to the sale of purchase of securities or other
investment products. Neither we nor any of our employees or partners receive any commissions
from sponsors of investment products.
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses charged by others, and which are paid by you. You may incur certain charges imposed
by custodians, brokers, third party investments and other third-party activities such as fees charged
by managers or custodians, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Mutual funds and exchange-traded funds also charge internal management fees,
which are disclosed in each fund’s prospectus. Such charges, fees and commissions are exclusive
of and in addition to our fees, and we shall not receive any portion of these commissions, fees, and
costs.
Item 12, Brokerage Practices, further describes the factors that we consider in selecting or
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recommending broker-dealers for client transactions and determining the reasonableness of their
compensation (e.g., their commissions).
We do not independently value the securities held in your accounts, the value of which determines
our fees. For marketable securities (those that are traded on public exchanges), the prices provided
to us by custodians and/or third-party pricing services are used for reporting performance to you,
and for calculating our fees. Please see additional information below regarding Valuation in Item
12.
In some instances, precise account balances are unavailable on a timely basis. Billing in those
situations is therefore based on the most current information available when fees are calculated, or
as otherwise outlined in our valuation procedures.
While we make every effort to obtain account balances directly from custodians, for reporting
purposes we may request that you regularly provide us with copies of account statements.
Hourly Fees
When either extensive work outside of our standard wealth management services (solely at our
discretion) or consulting services (if we do not have a Wealth Advisory Services Agreement with
you) is requested, a separate engagement will be negotiated. For these special projects or
consulting services, fees are based on expected service time and hourly fees ranging from $100 to
$400 per hour. These projects generally range from $2,000 to $10,000. While we have standard
billing rates for these services, all fees are subject to negotiation. If the engagement is terminated
before it is complete for any reason, any unused portion of the deposit will be refunded.
Either we or you may terminate the Agreement at any time. Notice of termination may be given to
the other party either verbally or in writing. You are responsible to pay for services rendered until
the termination of the agreement. You can cancel the Agreement without penalty within the first
five days after the signing of the Agreement.
Item 6 | Performance-Based Fees and Side-By-Side Management
We do not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client) nor do we offer side-by-side management (charging
performance-based fees and another type of fee such as hourly or asset based).
Item 7 | Types of Clients
Our focus is on families often extending several generations. We provide services for individuals,
pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or
other types of business entities. Most of our clients are individuals, trusts established by our clients
(or deceased clients), and executors of our deceased clients. We do not have an absolute minimum
for investment portfolios or a minimum account size. We have a minimum wealth management
fee of $7,500, although exceptions may be made for certain situations.
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Item 8 | Methods of Analysis, Investment Strategies and Risk of Loss
At the beginning of our relationship, we will first try to determine your financial goals to ensure
that we have a mutual understanding of what you want to accomplish with your investments. We
then suggest an investment program personalized to your needs and your ability to handle market
volatility (ups and downs).
Our investment advice is generally based on our analysis, which include returns for, and risks to,
various types of investments (asset classes): global public equity (stocks, large and small, domestic
and overseas companies that are traded on an exchange); fixed income (bonds); real estate, etc.
We believe that worldwide investments can provide positive portfolio growth over time. We
expect your portfolio’s return to compare favorable over time to the return by a portfolio of relevant
benchmarks, and each investment’s benchmark will be the return of a recognized investment index
such as the US Aggregate Bond Index or the All Country World Index (ACWI) or a 60% ACWI
and 40% US Aggregate Bond Index. This comparison to benchmarks is referred to as “relative
performance”.
Our market expectations are developed from internal analysis and research from third parties,
including financial services firms, governments, academics, and non-governmental institutions.
Our return expectations represent our expectations for returns and risks to various asset classes
(large company domestic stocks, small company, international, etc.) and then build investment
portfolio which aim to have the lowest possible overall risk for a given level of expected return.
This portfolio design considers how the various asset classes are expected to perform relative to
each other, their correlations, as well as how the various asset classes’ risk relates to the other asset
classes. It also includes an ongoing analysis of market conditions such as current and historical
valuations.
The investment advice given to you is based on many factors, including your investment objectives
and financial goals, risk tolerance, asset class choices, investment time horizon, cash needs, taxes,
historical returns, expected returns and general economic conditions. We use various types of
reviews pertaining to markets, investment strategies, and individual investments when providing
investment advice. Those reviews usually include historic, current, and anticipated: economic
sector, industry, company, financial market and investment return information. Regardless of the
methods used in providing investment advice, investing in securities involves risk of loss that you
should be prepared to bear.
Our standard portfolios that target the lowest volatility/risk will be more heavily weighted to fixed
income (bonds), while portfolios that target higher volatility/risk will be weighted towards equities
(stocks). Within each asset class, the securities are generally the same for portfolios with different
risk and return targets; it is the overall asset allocations that differ.
A substantial material risk for clients is forecasting errors in our market return expectations. In
the event that our expectations for returns are significantly different than actual long-term
experiences, you could be substantially disadvantaged as these estimates help to guide our asset
allocation and financial planning recommendations. Additionally, there are material risks in our
mutual fund manager selection process. There are general business and operational risks associated
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with the firms that manage money on your behalf that could lead to unexpected and unfavorable
developments including but not limited to: unethical or unlawful behavior by the manager, staff
turnover that disrupts the investment decision making process of the manager, and/or a change in
control of the manager including sale or dissolution. Other material risks include returns being
significantly different than a corresponding benchmark as well as the risk of underperforming the
benchmark in any time period and currency risk.
We often use Kwanti and ETF Action software packages to help with the comparison of investment
performance of mutual funds, exchange traded funds and individual securities to market
benchmarks. These software packages help with asset allocation by computing risk and return
characteristics of securities or indexes, given our assumptions about risk and return of those
portfolio elements. We also use numerous sources of information both public and private,
including but not limited to Bloomberg, The Wall Street Journal, Morgan Stanley, JP Morgan
Asset Management, Charles Schwab & Co., Inc., the Financial Times, the US Federal Reserve,
etc.
We use economic, financial and market data from third-party sources that we believe to be reliable.
We generally do not seek to independently confirm the accuracy of such information. Similarly,
we rely on a variety of third-party financial applications to perform numerous financial
calculations related to asset allocation, financial planning projections, and investment manager
evaluations. Although we review the quality of these services, there can be no guarantee the
calculations will be performed correctly going forward.
Investments are made across a wide range of markets and strategies. You should carefully read
the prospectus, statement of additional information and periodic shareholder reports for further
detail on specific risks associated with investing in any of these securities.
Our investment process is made up of the following steps:
1. Allocation across asset classes (e.g. stocks, bonds, domestic, international, large
companies, small companies, real estate, commodities, etc.);
2. Security selection within each asset class; and
3. Implementing the portfolio.
We actively review and monitor the investments chosen for you and make sure they are meeting
our criteria. Most investments are made using mutual funds and exchange traded funds. We also
invest in or make recommendations regarding certain stocks and individual bonds.
We periodically rebalance or recommend rebalancing our clients’ portfolios because studies show
that rebalancing increases returns and/or lowers risk over the long-term. Rebalancing involves
trading securities to bring your portfolio back toward your original asset mix. This becomes
necessary, because, over time, the distribution of your portfolio may become out of alignment with
your investment goals. And, in the near term, you will find that some of your investments will
grow faster than others. You might experience some additional transaction costs due to the
rebalancing. You also may have lower returns if the assets sold have higher returns in the future
than those being purchased.
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We generally do not make recommendations to purchase non-liquid securities because these
investments typically lack transparency or accessible accounting records.
Material Risks and Risk Reduction
● Markets are unpredictable, and our analysis is not able to predict future investment returns.
● All investments can lose value and certain asset classes and/or specific securities which
we choose may have poor returns for an extended period.
● A focus on long-term returns could cause us to ignore or be less concerned with near-term
economic or market events.
● The investment managers we choose may underperform their benchmarks, resulting in a
worse return than investing in a single index fund or a portfolio of index funds.
● While we believe our approach will result in a lower tax bill than a traditional actively
managed portfolio, our portfolios may incur higher taxes than an index fund, making any
of our managers’ underperformance of the benchmarks worse.
Investing in stocks, bonds, and other types of investments inherently involves a certain level of
risk. No matter how well designed a portfolio is, it contains some potential for losing value. We
therefore employ certain techniques in assisting clients to manage that risk, such as:
● Investing in a variety of asset classes which react differently to the irregular, unpredictable
up and down movements in the economy, both in the US and internationally.
● Allocating assets across asset classes which react differently to the business cycle (an
ongoing cycle of growth, decline, recession, and recovery in the economic activity of a
particular economy), rather than relying completely on statistical measures of risk (like
correlation).
● Constantly monitoring and attempting to reduce fees and expenses (e.g., negotiating
trading fees and margin rates with custodians).
With the above being said, investing in securities involves risk of loss that clients should be
prepared to bear.
Item 9 | Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us. We have no information
applicable at this time.
Item 10 | Other Financial Industry Activities and Affiliations
We have no affiliations with any company and therefore have no information applicable to this
Item. We are only in the business of providing wealth management services to our clients.
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Item 11 | Code of Ethics
We have adopted a Code of Ethics for all employees of the firm describing its high standard of
business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating
to the confidentiality of client information, prohibition of insider trading, restrictions on the
acceptance of significant gifts and the reporting of certain gifts and business entertainment items,
and personal securities trading procedures, among other things. All our employees must
acknowledge the terms of the Code of Ethics annually, or as amended.
Our Code of Ethics requires, among other things, that employees: act with integrity towards all,
place the interests of the clients above their own, attempt to avoid actual and potential conflicts of
interest, use reasonable care and comply with applicable federal and state securities laws.
Our Code of Ethics also requires employees to: 1) pre-clear certain personal securities transactions,
2) report personal securities transactions on at least a quarterly basis, and 3) provide the firm with
a detailed summary of certain holdings and securities accounts (both initially upon commencement
of employment and annually thereafter) over which such employees have a direct or indirect
beneficial interest.
A complete copy of our Code of Ethics is available to you upon request at no cost.
Our employees and persons associated with us are required to follow our Code of Ethics. We may
trade securities in our own accounts that are recommended to and/or purchased for our clients. The
Code of Ethics is designed to assure that the personal securities transactions, activities, and
interests of our employees will not interfere with those of our clients. Under the Code, certain
classes of securities have been designated as exempt transactions such as open-ended mutual
funds, based upon a determination that these would materially not interfere with the best interest
of our clients. In addition, the Code requires pre-clearance of many transactions, and restricts
trading ahead of client trading activity. Employee trading is regularly monitored under the Code
of Ethics, and to reasonably prevent conflicts of interest between our clients and us.
In the normal course of business, we may provide gifts and gratuities to various individuals or
entities such as clients, vendors, consultants, and service providers. These gifts are in no way tied
to specific client referrals or any expectation of any other type of benefit to us. The gifts are
generally immaterial in nature.
Item 12 | Brokerage Practices
The Custodians and Brokers We Use
We do not maintain physical custody of your assets that we manage or advise on. However, we
may be deemed to have custody of your assets if you give us authority to withdraw assets from
your account (see Item 15 – Custody, below) other than debiting our fees, or we possess similar
control with respect to your assets. When we are deemed to have custody over an account because
of this authority, we are required to have an independent third-party accounting firm conduct a
“surprise audit” of those accounts, no less than annually, to verify the assets and activity in such
accounts. Regardless of whether we are deemed to have custody, your assets must be maintained
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in an account at a qualified custodian, generally a broker- dealer or bank.
We generally recommend that our clients use Charles Schwab (FINRA-registered broker-dealer,
member SIPC) referred to below as “Recommended Custodian”.
We are independently owned and operated and are not affiliated with any custodian. The custodian
will hold your assets in a brokerage account and buy and sell securities when we instruct them to.
While we suggest that you use the previously mentioned custodian/broker, you will decide whether
to do so and will open your account by entering into an account agreement directly with them. We
do not open the account for you, although we assist you in doing so. Even though your account is
maintained at a particular custodian, we can still use other brokers to execute trades for your
account as described below (see Your Brokerage and Custody Costs below).
How We Select Brokers/Custodians
We seek to select a custodian/broker who will hold your assets and execute transactions on terms
that are, overall, most advantageous when compared to other available providers and their services.
We consider a wide range of factors, including, among others:
● Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
● Capability to execute, clear, and settle trades (buy and sell securities for your account)
● Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
● Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], etc.)
● Availability of investment research and tools that assist us in making investment decisions
● Quality of services
● Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate prices they charge you
● Reputation, financial strength, and stability
● Prior service to us and our other clients
● Availability of other products and services that benefit us, as discussed below (see
“Products and Services Available to Us From Custodian”)
Because we consider all the above factors in our selection of recommended Custodians, you may
not receive the lowest possible commission rate or fee for a particular transaction on a particular
day. Our annual “best execution” review considers many factors as noted above and seeks to ensure
the best overall arrangement for the cost of brokers’ services and trade execution – over many
trades and over time – for the majority of clients. As a fiduciary, DRR is required to act in its
clients’ best interests, however our recommendation that clients maintain their assets in accounts
at a preferred custodian may be based in part on the benefit to DRR of the availability of some
products and services and not solely on the nature, cost or quality of custody and brokerage
services provided by the custodian, which may create a potential conflict of interest.
Your Brokerage and Custody Costs
For our clients’ accounts that a Recommended Custodian maintains, the Custodian generally does
not charge you separately for custody services but is compensated by charging you commissions
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or other fees on trades that it executes or that settle into your account. Commission rates are
reviewed no less than annually as part of our review of custodians and broker dealer services (“best
execution review”).
In addition to commissions, our Recommended Custodians generally
charge you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have
executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your account at the Custodian. These fees are in addition
to the commissions or other compensation you pay the executing broker- dealer. Because of this,
in order to minimize your trading costs, we have the Custodian where your account is held execute
most trades for your account. We have determined that having the Custodian where your accounts
are held execute most trades is consistent with our duty to seek “best execution” of your trades.
Best execution means the most favorable terms for a transaction based on all relevant factors,
including those listed above (see How We Select Brokers/Custodians above).
The following is a more detailed description of support services we receive from one or all of our
Recommended Custodians:
Services That Benefit You
Our Recommended Custodian’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The
investment products available through the Custodians include some to which we might not
otherwise have access or that would require a significantly higher minimum initial investment by
our clients. The services described in this paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Our Recommended Custodians also make available to us other products and services that benefit
us but may not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts. They include investment research, both the
Custodian’s own and that of third parties. We may use this research to service all or a substantial
number of our clients’ accounts, including accounts not maintained at a Recommended Custodian.
In addition to investment research, our Recommended Custodians also make available software
and other technology that:
● Provide us with access to your account data (such as duplicate trade confirmations and
account statements)
● Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
● Provide pricing and other market data
● Facilitate payment of our fees from our clients’ accounts
● Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Our Recommended Custodians also offer other services and software intended to help us manage
and further develop our business enterprise. These services include:
● Educational conferences and events
● Consulting on technology, compliance, legal, and business needs
● Publications and conferences on practice management and business succession
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● Access to employee benefits providers, human capital consultants, and insurance
providers
The Custodian may provide some of these services and software itself. In other cases, it will
arrange for third-party vendors to provide the services to us. Custodians may also discount or
waive fees for some of these services or pay all or a part of a third party’s fees. Custodians may
also provide us with other benefits, such as occasional business entertainment.
Recommended Custodians - Products and Services Available to Us
They provide us and our clients with access to its institutional brokerage—trading, custody,
reporting, and related services—many of which are not typically available to retail customers.
They also make available various support services. Some of those services help us manage or
administer your accounts, while others help us manage and grow our business. Support services
generally are available on an unsolicited basis (we don’t have to request them) and at no charge to
us if our clients collectively maintain a total of at least $10 million of their assets in accounts at
Schwab. Currently our assets maintained at Schwab are nearly $280 million.
Our Interest in Custodian Services
The availability of these services from our custodian benefits us because we do not have to produce
or purchase them. The benefits we receive, that you may also benefit from, may give us an
incentive to recommend that you maintain your account with them, based on our interest in
receiving services that benefit our business rather than based solely on your interest in receiving
the best value in custody services and the most favorable execution of your transactions. This is a
potential conflict of interest. We believe, however, that our selection of custodians and brokers is
in the best interests of our clients. Our selection is primarily supported by the scope, quality, and
price of services (see How We Select Brokers/Custodians above) and not services that benefit only
us. The fact that we need $10 million at Schwab to avoid paying fees, we do not believe that this
is a material conflict of interest.
Soft Dollars
Section 28(e) of the Securities and Exchange Act of 1934 provides a “safe harbor” to investment
advisers who use “commission dollars” of their advised accounts to obtain investment research
and brokerage services that provide lawful and appropriate assistance to the adviser in performing
investment decision-making responsibilities. Conduct outside of the safe harbor of Section 28(e)
is subject to the traditional standards of fiduciary duty under state and federal law. As noted above
in our Brokerage Practices section, we occasionally receive services provided free of charge from
custodians and or investment providers that generally used to further our business enterprise. The
non-cash items we receive could take the form of fee waivers at conferences, consulting services
provided by employees of the firms, etc. These types of “soft dollars” do not fall within the
provisions of 28(e). We use commission dollars to pay only for products and services we
reasonably believe fall within the safe harbor of 28(e).
We may receive allocations of soft dollar credits from custodians that may be used to offset the
cost of research provided by them. You do not incur higher costs because of these allocations, and
such allocations are not a material consideration when a particular custodian is selected or
recommended to you. While we generally recommend Schwab, clients may choose to use service
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providers other than those recommended by us.
Our relationships with custodians that provide soft dollar services may influence our judgement
and create conflicts of interest in choosing a custodian. We may have an incentive to select or
recommend a custodian based on our interest in receiving soft dollar services. These conflicts of
interest are particularly influential to the extent that we use soft dollars to pay expenses we would
otherwise be required to pay ourselves.
We acknowledge these conflicts of interest. We evaluate, at least annually, the trade execution
and other services that we and our clients receive from the custodian (our “Best Execution” review,
discussed above. Soft dollar benefits are used across DRR for the benefit of all clients and are not
limited to clients that may have generated such benefit.
Valuation
We will value securities in your accounts that are listed on a national securities exchange or on
NASDAQ at the last quoted sales price on the principal market where the securities are traded. We
receive this information from your qualified custodian and/or independent third-party pricing
services.
Currently, we do not hold any private investments for our clients. Since all investments are public
and on exchanges, they are able to valued as described above.
Brokerage Trading
We are not a broker-dealer. We rely on the custodian of your securities to execute transactions on
your behalf. Because of this fact we must instruct the custodian of the securities to execute any
transactions you provide to us. We will only accept verbal instructions given to a live person, not
via voicemail or email. We will follow up with a confirmation via a phone call or email. We can’t
ensure and do not warrant the timing of receipt of such directions or the timeliness of execution of
such transactions by the custodian. As a result, you may receive less favorable prices for the
transaction than if you had given the instructions directly to the custodian.
Trade Errors
From time-to-time, we may make an error in submitting a trade order. When this occurs, we will
correct the trade in one of two ways, described more fully below, depending on the facts and
circumstances associated with the trade error itself and the time we discover the error. We attempt
to minimize trade errors by promptly performing electronic reconciliation procedures with order
tickets and intended orders, and by reviewing past trade errors to understand whether internal
control breakdowns, if any, caused the errors. Trading errors will be corrected at no cost to you.
Broker-dealers are not permitted to assume responsibility for trade error losses caused by us. Nor
may there be any reciprocal arrangements with respect to the trade in question or any subsequent
trade to encourage the broker to assume responsibility for such losses.
In most cases, we will correct trade errors via the executing broker-dealer’s trade error desk. This
process effectively cancels the original trade and replaces it with the correct trade by moving the
original trade into our omnibus account and putting the correct trade into your account. In other
words, the original trade is removed from your account and has no impact on you. If there is a cost
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associated with the correction, such cost is borne by us. Note that we do not credit accounts for
market losses unrelated to error. Occasionally, this method of correcting an error results in a gain
when the cost of the correct trade is lower at the time of correction than it would have been when
originally placed. Because the gain occurs in our omnibus account, we do not credit such gains to
your account. Depending on the rules and procedures at the executing broker-dealer, the gains and
losses are either reconciled by the custodian within our trade error settlement accounts, or the gross
amount of the gains are donated to charity and the losses are entirely borne by us.
Depending on the facts and circumstances, we may correct an error by placing a new trade rather
than cancelling the original trade. If this method of correction results in a gain, such gain is
retained by you since the error correction occurs directly in your account. You will then be
responsible for any taxes and/or trading costs associated with this additional trade. Since any trade
error losses are covered by us, we generally do not correct errors that would result in a loss by
placing an additional trade but rather we would cancel the original trade as described above.
We will reimburse accounts for losses resulting from trade errors, but will not credit accounts for
market losses unrelated to its error, or its error resulting in market gains. The gains and losses are
reconciled by the custodian within our trade error settlement accounts.
Trade Order Aggregation
We will aggregate purchases where possible to increase efficiency, consistency and timeliness. In
most cases, investment transactions are implemented by client. Each client’s portfolio is
customized.
Directed Brokerage
If you restrict us to using a particular broker-dealer (or direct us to use a particular broker-dealer)
for executing transactions, you will generally be unable to participate in aggregated orders and will
be precluded from receiving the benefits, if any, of an aggregation which other clients may receive.
We will generally execute aggregated orders for “non-directed” clients (those who use our
recommended custodians noted above) before we execute orders for clients that direct brokerage.
We may also execute trades for non-directed clients through the same broker-dealer to which other
client’s direct brokerage.
Under certain circumstances, you may receive different pricing for the same security on the same
day compared to pricing received by another client in order to accommodate your needs or another
client’s specific needs or instructions to us.
Item 13 | Review of Accounts
We review your accounts regularly based on our review of market conditions and your specific
situation. We continually monitor the general conditions in the stock and bond markets. Situations
that generally would trigger a review of your accounts are a change in your specific situations of
which we are made aware of, a change in the general conditions of the stock and bond markets and
a change to an investment that you own. A Partner of the firm reviews accounts.
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Our general practice is to provide you with quarterly investment monitoring reports (electronically
in most cases). The preparation of the quarterly report involves numerous checks and is ultimately
reviewed by a Partner of the firm. It is your responsibility to review the reports when they are
made available to you, and we encourage you to bring any questions about the reports and/or your
fees to our attention.
More in depth reviews are triggered by events like big changes in your financial circumstances
and significant changes in conditions in the stock and bond markets, such as large price
movements, big economic surprises and abnormal or unusual trading volumes. Reviews of your
accounts are also triggered by significant changes in the management or policies of other
investment vehicles, such as mutual funds or individual securities. These in-depth reviews can
also be triggered by a request for cash from your account, a large deposit of cash into your account,
or an adjustment to your portfolio recommended during certain market conditions. To properly
execute this type of a request our normal and expected procedure is to consider tax, estate planning,
and trading issues amongst other factors prior to executing transactions. This careful consideration
may take a few days and there is a risk of markets rising or falling during this time.
Financial Planning may be reviewed at various times in our relationship. The exact process will
depend on the nature of our relationship. Reports are prepared for you for financial planning
services on an “as needed” or “as requested” basis.
Your accounts are reviewed to confirm that the recommendations we make, and your investment
plans are consistent with your financial goals. Periodic on-going reviews are conducted on an “as
needed” basis depending on your needs and the nature of the financial issue. We expect to meet
with you at least once annually as well as have other contact by voice or email more frequently
throughout the year.
Item 14 | Client Referrals and Other Compensation
We often receive referrals from our existing clients as well as from other professional service
providers, such as lawyers and accountants. While this might provide an incentive for us to
discount fees for clients who refer business to us, it is our strict policy not to do so. Referrals from
other professional service providers could cause us to want to return the referrals, however we are
careful to refer our business, and that of our clients, in as unbiased a way as possible. We therefore
frequently provide multiple names when asked for referrals to professional service providers. None
of these individuals or firms are compensated in any way for providing client referrals.
Item 15 | Custody
You should receive statements, at least quarterly, from the broker dealer, bank or other qualified
custodian that holds and maintains your investment assets. We urge you to carefully review such
statements and compare such official custodial records to the information we provide to you such
as our quarterly performance reports. Our statements may vary slightly from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
We encourage you to ask questions about any discrepancies that you identify.
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Item 16 | Investment Discretion
Discretionary Investment Management
We prefer to receive discretionary authority from our clients at the outset of an advisory
relationship. This authority makes us responsible for selecting the identity and amount of securities
to be bought or sold in your accounts. In all cases, however, such discretion is exercised in a
manner consistent with your stated investment objectives. You will need to execute a limited
power of attorney to permit us to trade in your accounts.
When selecting securities and determining amounts to buy or sell, we observe your investment
objective, limitations and restrictions that you and we have discussed and agreed upon.
It is your responsibility to promptly notify us if there is ever any change in your financial situation
or investment objectives. It is necessary that you keep us promptly informed about changes in your
financial circumstances for the purpose of reviewing, evaluating, and/or revising our previous
recommendations to you.
Because we manage more than one account and have many clients with varying circumstances,
there may be conflicts of interest over time devoted to managing any one account and allocating
investment opportunities among all the accounts we manage. For example, we may select
investments for a particular client based solely on the investment strategy being pursued for that
client. Different clients may have differing investment strategies and expected levels of trading.
We may buy or sell a security for you but not for another client or may buy (or sell) a security for
one type of client while simultaneously selling (or buying) the same security for another type of
client. We attempt to resolve all such conflicts in a manner that is generally fair to all our clients.
We may give advice to, and take action on behalf of, any of our clients that differs from the advice
given to another client so long as it is our policy, to the extent practicable, to allocate investment
opportunities to our clients fairly and equitably over time. We are not obligated to acquire for any
account any security that we may acquire for our own accounts or for any other client, if in our
absolute discretion, it is not practical or desirable to acquire a position in such security for that
account.
We may provide investment management services with respect to assets held in your 401k,
deferred compensation, and/or 529 Plan accounts with various mutual fund companies. Because
we might be responsible for effecting the transactions in these accounts and/or reporting
investment performance, we might request your username and password that permits online access
to the account for informational purposes only. We may also use third-party data aggregators to
obtain this information. It is our policy not to accept usernames and password credentials that
would permit us to withdraw funds or would otherwise cause us to have custody under government
regulations.
Non-Discretionary Investment Management
Non-Discretionary investment management is similar to discretionary management in many
respects, except that we are not given a limited power of attorney by you that permits us to trade
securities on your behalf. This will impact the timing and logistics of implementing any advice we
may give you in as much as you will be responsible for effecting the transaction with the custodian
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and/or broker, and this could result in adverse pricing in comparison to a discretionary client
trading the same security(ies) on the same day.
It is your responsibility to promptly notify us if there is ever any change in your financial situation
or investment objectives. It is necessary that you keep us promptly informed about changes in your
financial circumstances for the purpose of reviewing, evaluating, and/or revising our previous
recommendations to you.
Because we manage more than one account and have many clients with varying circumstances,
there may be conflicts of interest over time devoted to managing any one account and allocating
investment opportunities among all the accounts we manage. For example, we may select
investments for a particular client based solely on the investment strategy being pursued for that
client. Different clients may have differing investment strategies and expected levels of trading.
We may buy or sell a security for you but not for another client or may buy (or sell) a security for
one type of client while simultaneously selling (or buying) the same security for another type of
client. We attempt to resolve all such conflicts in a manner that is generally fair to all our clients.
We may give advice to, and take action on behalf of, any of our clients that differs from the advice
given to another client so long as it is our policy, to the extent practicable, to allocate investment
opportunities to our clients fairly and equitably over time. We are not obligated to acquire for any
account any security that we may acquire for our own accounts or for any other client, if in our
absolute discretion, it is not practical or desirable to acquire a position in such security for that
account.
Whether we are engaged to provide discretionary or non-discretionary investment management,
we are never given authority to change or amend your investment objective, nor your selected asset
allocation. You will always retain control over such critical decisions that guide our advice to you.
Item 17 | Voting Client Securities
As a matter of firm policy and practice, we do not, vote proxies on your behalf. You retain the
responsibility for receiving and voting proxies for any and all securities maintained in your
portfolios. We may provide advice to you regarding the voting of proxies in special circumstances;
however, we shall not be deemed to have voting authority with respect to such shareholder matters
as a result of providing such advice even if you have instructed the custodian or broker dealer to
deliver such issuer communication directly to us.
We will assist you with the election into class actions only when requested even if you have
instructed the custodian or broker dealer to deliver such issuer communication directly to us. When
advising you, we will assess any potential recovery against the cost to comply with the rules of the
class action and advise you accordingly. Any general or specific class action election guidelines
provided by you or your designated agent in writing will supersede this policy.
With regard to all matters (other than proxies) for which shareholder action is required or solicited
with respect to securities beneficially held in clients’ accounts, such as (i) all matters relating to
class actions
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Item 18 | Financial Information
Registered Investment Advisors are required, under certain conditions, to provide you with
financial information or disclosures about our financial condition. We do not meet the required
conditions for disclosure.
With that being said, we have no financial commitment that impairs our ability to meet contractual
and fiduciary commitments to clients and have not been the subject of a bankruptcy proceeding.
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