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RS Crum, Inc. Form ADV Part 2A Brochure
ADV PART 2
Financial Advice and Representation
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Item 1 – Cover Page
R. S. Crum, Inc.
4 Upper Newport Plaza Drive
Suite 201
Newport Beach, CA 92660
(949) 428-9696
www.rscrum.com
This Brochure provides information about the qualifications and business practices of R. S.
Dated: March 27, 2025
Crum, Inc. If you have any questions about the contents of this Brochure, please contact us at
(949) 428-9696 or by email at rscrum@rscrum.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.
R. S. Crum, Inc. is a registered investment adviser. Registration of an Investment Adviser does
not imply any level of skill or training. The oral and written communications of an Adviser
provides you with information, which you may use to determine to hire or retain an Adviser.
Additional information about R. S. Crum, Inc. also is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Material Changes
The purpose of this page is to inform you of any material changes to this brochure. If you are receiving
this brochure for the first time, this section may not be relevant to you.
RS Crum, Inc. reviews and updates our brochure at least annually to confirm that it remains current. Since
the previous annual update to our brochure, dated March 20, 2024, we have made the following material
changes:
Item 5 Fees and Compensation - RS Crum, Inc. has updated information on our standard tiered fee
schedule. While some legacy clients may still be assessed fees under a previous tiered fee schedule as
agreed upon within the clients’ investment management agreements, the updated schedule is relevant for
new clients.
If you wish to receive a complete copy of our Form ADV Part 2A brochure, please send a written request
to our office.
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Item 3 – Table of Contents
Item 1 – Cover Page .................................................................................................................................... 2
Item 2 – Material Changes ......................................................................................................................... 3
Item 3 – Table of Contents ......................................................................................................................... 4
Item 4 – Advisory Business ........................................................................................................................ 6
Types of Advisory Services ...................................................................................................................... 6
Services that are Limited in Duration ....................................................................................................... 6
Continuous (On-Going) Advisory Services .............................................................................................. 7
New Clients (Limited Duration and Continuous Advisory Clients) ......................................................... 7
Investment Management ........................................................................................................................... 8
Non-managed Accounts ............................................................................................................................ 9
Financial Planning .................................................................................................................................... 9
Retirement Investment Advice .................................................................................................................. 9
Assets Under Management ..................................................................................................................... 10
Item 5 – Fees and Compensation ............................................................................................................. 10
Cancellation of Services (Limited Duration or Continuous) .................................................................. 11
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 11
Item 7 – Types of Clients .......................................................................................................................... 12
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 12
Methods of Analysis ............................................................................................................................... 12
Investment Strategies .............................................................................................................................. 12
Investing Involves Risk ........................................................................................................................... 13
General Risks of Owning Securities ....................................................................................................... 13
Specific Security Risks ........................................................................................................................... 13
Other Business Risks .............................................................................................................................. 14
Item 9 – Disciplinary Information ........................................................................................................... 15
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 15
Item 11 – Code of Ethics ........................................................................................................................... 15
Item 12 – Brokerage Practices ................................................................................................................. 16
How We Select Brokers/Custodians ....................................................................................................... 17
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Your Brokerage and Custody Costs ........................................................................................................ 17
Products and Services Available to Us from Schwab ............................................................................. 17
Services That Benefit You ...................................................................................................................... 18
Services That May Not Directly Benefit You ......................................................................................... 18
Services That Generally Benefit Only Us ............................................................................................... 18
Our Interest in Schwab’s Services .......................................................................................................... 19
Directed Brokerage Transactions ............................................................................................................ 19
Aggregation and Allocation of Transactions .......................................................................................... 19
Item 13 – Review of Accounts .................................................................................................................. 21
Managed Account Reviews & Reporting ............................................................................................... 21
Financial Plan Reviews & Reporting ...................................................................................................... 22
Item 14 – Client Referrals and Other Compensation ............................................................................ 22
Schwab Support Products and Services .................................................................................................. 22
Recommendation of Unaffiliated Professionals...................................................................................... 22
Item 15 – Custody ..................................................................................................................................... 23
Item 16 – Investment Discretion .............................................................................................................. 23
Discretionary Management ..................................................................................................................... 23
Non-Discretionary Management ............................................................................................................. 24
Item 17 – Voting Client Securities ........................................................................................................... 24
Item 18 – Financial Information .............................................................................................................. 24
Form ADV, Part 2B Brochure Supplement ............................................................................................... i
Description of Professional Designations Used in this Brochure Supplement ......................................... ii
Mark Rylance, CFP® ............................................................................................................................. iii
Jon Theriault, CFP® ............................................................................................................................... v
Daniel Sexton, CFP® ............................................................................................................................. vii
Eric Papa, CFP® .................................................................................................................................... ix
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Item 4 – Advisory Business
In 1976, Richard S. Crum founded RS Crum Advisory Services, which was incorporated in 2003 as R. S.
Crum, Inc. (“RS Crum, Inc.,” the “Firm,” “we,” “our,” or “us”). In July 2011, the Firm completed a
transfer of ownership to senior employees. Currently, RS Crum, Inc.’s principal owners are Mark
Rylance, Jon Theriault, and Daniel Sexton. RS Crum, Inc. is an SEC registered investment adviser.
Registration with the SEC does not in any way constitute an endorsement by the SEC of an investment
adviser's skill or expertise.
Since our beginning, RS Crum, Inc. has provided investment management, financial planning, and
business consulting services on a FEE ONLY basis to individuals, pension and profit sharing plans, trusts,
estates, charitable organizations and small businesses. The Firm does not participate or offer product sales
(or accept commissions) in connection with services. We believe this enhances objectivity to our clients.
The client always maintains control of their assets as their accounts are held by a qualified custodian. The
Firm does not act as a custodian of client assets, providing additional security for the client.
Types of Advisory Services
RS Crum, Inc. manages investments primarily on a discretionary and, in limited circumstances, on a non-
discretionary basis. On a more than an occasional basis, the Firm provides advice to clients on matters
not involving securities as further described below. The scope of financial advice and/or planning services
differs from client to client depending on their specific need.
RS Crum, Inc. provides services on a continuous (ongoing) and limited engagement basis. RS Crum, Inc.
offers both comprehensive financial services and services that are limited in scope. Areas that could be
covered include:
• Budget, Cash Flow, and Net Worth Assessment
• Summary of Client Goals
•
Investment Management
• Retirement Analysis
• Transitional Event Planning
• Real Estate Analysis
• Business Consulting
The Firm might also work with a client’s other advisors as they generally relate to estate planning, tax
planning, and / or insurance. See below Item 14 – Client Referrals and Other Compensation.
Services that are Limited in Duration
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RS Crum, Inc. offers engagements of limited duration up to one year.
The cost of a limited engagement does not include the follow up or monitoring of future activities. In
addition, the limited engagement does not include periodic review nor is there any obligation on the part
of the client to re-utilize RS Crum, Inc.
Clients who previously received services on a limited engagement may choose to have such services
updated and/or modified. This decision is solely that of the client. RS Crum, Inc. does not send periodic
reminders or advocate any specific time frame wherein a “financial check-up” may become advantageous.
However, the client is told that time and economic circumstances do change and that every financial plan
will need modification and/or revision at some future time.
The policy of RS Crum, Inc. is to charge a flat fee for such services.
Continuous (On-Going) Advisory Services
Clients may engage RS Crum, Inc. for financial services on an ongoing basis (i.e., month to month).
A fee, paid monthly or quarterly, is determined and agreed upon by both parties prior to entering any
service arrangement. The fee and billing schedule are included in a formal engagement contract. This
contract is signed by parties and retained on file before work begins. An electronic copy is also retained.
A fee might be determined that may not relate purely to asset management. This fee might be based on
estimated work and responsibilities attributable to the service provided in other financial areas such as
estate planning, income tax planning, retirement analysis, business consulting, etc.
Ongoing investment management is normally conducted on a discretionary basis. Although clients
participate in identifying specific goals, they usually are not involved in the “day-to-day” specificity of
investment selection.
Clients receive periodic statements and confirmations of trading activity from independent account
custodian(s) or third-party administrator(s). RS Crum, Inc. receives duplicate account statements and
confirmations. RS Crum, Inc. DOES NOT maintain general powers of attorney over client accounts.
New Clients (Limited Duration and Continuous Advisory Clients)
An initial consultation is given free of charge to potential clients. This meeting may include a general
discussion of their financial options, alternatives, and goals in one or more of the following financial
areas, but not limited to:
• Budget, Cash Flow, and Net Worth
•
Investments
•
Income Tax
• Retirement
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• Estate
• Real Estate
• Business Consulting
A copy of the ADV Part 2A (Brochure) is generally delivered to any potential new client(s) prior to the
initial conference or it is provided at the initial meeting, but otherwise no later than at time of contract
signing.
Prospective clients are normally asked to provide the following at or prior to the initial meeting:
• Most recent year’s income tax returns
• Brief description of assets and liabilities (or a financial statement if available)
• Brief written description of goals or special questions or matters to be covered during that session
• Any additional data that may be relevant to the discussions
The initial interview session generally lasts from 1 to 2 hours.
No decision is required to engage RS Crum, Inc. at the initial meeting or to the cost, duration, or scope of
services that might be provided. Prospective clients are typically contacted within several business days
of the initial consultation to discuss such matters.
A written engagement letter is prepared for each client prior to commencing any specified activity. In
part, this letter discusses the cost and duration of services as well as specific areas the client wishes to be
included. Financial areas not specified in the Advisory/Engagement Letter are not included.
Generally, a portion of the fee is due on signing, to pay for services in advance. Such advanced fees
usually cover the first quarter of services.
A signed copy of this letter is required in advance of any work and is retained on file. An electronic copy
is also retained.
Investment Management
RS Crum, Inc. manages client accounts on an individual basis separate from other client portfolios.
Our goal is to manage risk and accumulate wealth safely for our clients. Individual portfolios are based on
an asset allocation invested across an array of asset classes that may include cash, stocks, bonds, and
alternative investments. RS Crum, Inc. provides continuous and regular investment services on a
discretionary basis. We have the ongoing responsibility to select and/or make recommendations, based
upon the objectives of the client, as to specific securities and / or asset allocation.
Our investment management services include designing, implementing, and continued monitoring of
client accounts, limited only by the client’s individual needs and any restrictions imposed on the account.
Our asset allocation models and recommendations for new portfolios consist of various types of
securities, depending on the investment objective of each model, the client’s objectives, and/or the size of
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the account.
Below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss we discuss the types
of securities that we recommend.
Non-managed Accounts
Assets or securities that are identified as non-managed are removed from managed accounts or designated
as non-managed within RS Crum, Inc.’s portfolio management platform. RS Crum, Inc. will only be
responsible for the supervision and management of securities we recommend. RS Crum, Inc. will not be
responsible for the supervision or management of non-managed assets. Non-managed assets are not
included in the calculation of portfolio investment performance or fees, nor does RS Crum, Inc. monitor
non-managed assets. Non-managed assets may include securities held in a client’s account that is under
management with RS Crum, Inc. that were:
1. Delivered into the account by the client;
2. Purchased by the client;
3. Purchased by RS Crum, Inc. at the request of the client as an accommodation; or
4. Designated by the client to be non-managed securities.
Clients are instructed to keep RS Crum, Inc. informed of changes in their financial situation.
Financial Planning
RS Crum, Inc. offers advice through written financial plans and/or consultations. Written plans may
involve analysis and discussions with the client, and usually involve cash flow projections to model the
potential outcomes of retirement, estate planning, and other decisions. This might include examining
different retirement dates, real estate or business sales, evaluating employee stock options, educating
children or grandchildren, support of parents or heirs with special needs, inheritances or other scenarios.
Certain consultations address immediate and specific issues, such as deciding on a pension option, leasing
or buying a car or choosing a mortgage. Analysis or research of such topics may be limited since these are
discussions to resolve a short-term concern.
Financial planning may be the only service provided to the client and does not require that the client use
or purchase the investment advisory services offered by the Firm.
The client is under no obligation to act upon RS Crum, Inc.’s recommendations, and if the client elects to
act on any of the recommendations, the client is under no obligation to implement through the Firm.
Retirement Investment Advice
When we provide investment advice to clients regarding their retirement plan accounts or individual
retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement
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Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which
are laws governing retirement accounts. The receipt of our advisory fee for making a
recommendation creates a conflict of interest under ERISA/IRC between our interests and the clients’
interests, so we operate under a special rule that requires us to act in the clients’ best interests and not
put our interest ahead of theirs. For example, if we recommend that a client roll over assets from one
retirement account to another and receive increased compensation as a result of that recommendation,
we have a conflict that requires us to operate under this special rule.
Assets Under Management
RS Crum, Inc.’s discretionary assets under management as of December 31, 2024, were $604,371,190.
For some clients, RS Crum, Inc. provides investment advice, supervision of, and reporting of accounts on
a non-discretionary basis. As of December 31, 2024, RS Crum, Inc.’s non-discretionary assets under
management were $12,611,268.
Item 5 – Fees and Compensation
Fees are negotiable and are discussed and agreed upon with clients prior to the beginning of services. The
following is RS Crum, Inc’s standard tiered fee schedule applied as a percentage of assets under
management (AUM).
Assets Under Management (AUM)
Up to $1 Million
From $1 Million to $5 Million
From $5 Million to $10 Million
Greater than $10 Million
Annual Percentage
1.0%
0.75%
0.50%
0.25%
This schedule may be discounted depending on several factors, including but not limited to, the scope and
complexity of the services provided, the total value of assets managed, the number of accounts and/or the
individual needs of the client. Discounts may take the form of a lower starting annual percentage and/or
amended AUM break points. Effective AUM rates (the rate paid on your total AUM) range from 0.4% –
1.00% of assets under management (AUM) annually. Accounts may also be subject to a minimum
quarterly fee.
For some legacy clients, RS Crum, Inc. has applied either a fixed or flat fee (retainer) or a different
Annual Percentage of AUM schedule than described above. These fee schedules are documented in the
respective clients’ written Advisory Agreement and may still be in effect for these clients.
The specific manner and frequency fees are charged is established in a client’s written Advisory
Agreement. The Firm will generally bill fees quarterly, in advance, based on the market value of assets in
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the account on the last business day of the previous quarter. The Firm has used a monthly billing
frequency in the past and some legacy clients remain on that cycle. Each client’s specific fee schedule is
documented in the written Advisory Agreement.
For the majority of clients, RS Crum, Inc. accepts the authority to bill (debit) client account(s) directly for
fees. Clients receive an informational invoice prior to fees being debited. Normally, fees are withdrawn
within ten (10) business days after the invoice date. The account custodian withdraws advisory fees from
the client’s account based on our instruction, as outlined in our Advisory Agreement. All clients will
receive brokerage statements from the custodian no less frequently than quarterly that will show the
deduction of the advisory fee.
RS Crum, Inc. will send an invoice to all clients who choose not to have advisory fees withdrawn directly
from their custodian account and clients can pay management fees by check. The invoice is payable upon
receipt and will include the fee calculation and amount due.
Some employees are compensated through an annual salary with bonuses. For some employees, a bonus
is based on the amount of a client’s first year fee. This creates an incentive to charge a higher fee and/or
manage more of a client’s assets.
RS Crum, Inc.’s fees are exclusive of brokerage commissions, transaction fees, and other related costs
and expenses, which shall be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, third party investment providers and other parties such as fees charged by managers,
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and
exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus.
Such charges, fees, and commissions are exclusive of and in addition to RS Crum, Inc.’s fee. RS Crum,
Inc. does not receive any portion of these commissions, fees, and costs.
Later in this brochure, Item 12 – Brokerage Practices further describes the factors that RS Crum, Inc.
considers in selecting or recommending broker-dealers for client transactions and determining the
reasonableness of their compensation (e.g., commissions).
Cancellation of Services (Limited Duration or Continuous)
Services can be cancelled by either party at any time without penalty by written notice. Clients shall be
charged pro rata for services provided through the date of termination. If the client made an advance
payment, RS Crum, Inc. will refund any unearned portion of the advanced payment.
Item 6 – Performance-Based Fees and Side-By-Side Management
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RS Crum, Inc. does not charge any performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client).
Item 7 – Types of Clients
RS Crum, Inc. typically provides services to high income and high net worth individuals, trusts, estates,
or charitable organizations. In addition, we provide services to businesses such as corporations, LLCs,
sole proprietorships or pension and retirement plans.
Other than RS Crum, Inc.’s minimum fee, no account requirement is maintained for portfolio
management services (See Item 5 Fees and Compensation).
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
The main sources of information include financial newspapers and magazines, research materials and
services prepared by others, corporate rating services, annual reports, prospectuses, filings with the
Securities and Exchange Commission, and company press releases. Security analysis methods include
fundamental analysis.
Investment Strategies
RS Crum, Inc. manages client accounts on an individual basis utilizing an allocation model that invests in
a broad spectrum of investment categories. These categories may include cash, bonds, equities (stocks),
ETFs, mutual funds, and alternative investments. Portfolios are globally diversified to manage the risk
associated with traditional markets. RS Crum, Inc. seeks to select securities with characteristics that are
consistent with the investment objectives of each investment category. Since client portfolios are
managed individually, portfolios with a similar investment objective and asset allocation may differ.
Timing, account size and tax factors may also influence our investment decisions.
Our asset allocation models and recommendations include mutual fund only allocations. The mutual
funds recommended may include mutual funds offered by Dimensional Fund Advisors (“DFA”). Our
recommendations are not limited to DFA funds. DFA offers professionally managed mutual funds at
relatively low expense ratios and are not available directly to individual investors but are limited to a
select group of independent financial advisors approved by DFA. We are unaffiliated with DFA.
RS Crum, Inc.’s advisory representatives work with clients to determine their investment objectives, time
horizon, income needs as well as their ability to take risk, need to take risk, tax considerations, and any
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special considerations and/or restrictions in order to develop the asset allocation and portfolio
construction utilized for the client.
We are responsible for the supervision and management of securities we recommend. For information on
the treatment of Non-Managed Accounts and / or Securities, please see above Item 4 Advisory Business.
Investing Involves Risk
Investing in securities involves risk of loss that clients should be prepared to bear.
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response to
certain events taking place around the world. These include events directly involving the issuers of
securities held as underlying assets of mutual funds in a client’s account, conditions affecting the general
economy, and overall market changes. Other contributing factors include local, regional, or global
political, social, or economic instability and governmental or governmental agency responses to economic
conditions. Finally, currency, interest rate, and commodity price fluctuations may also affect security
prices and income.
Specific Security Risks
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in stocks,
bonds, short-term money-market instruments, other securities or assets, or some combination of these
investments. The portfolio of the fund consists of the combined holdings it owns. Each share represents
an investor’s proportionate ownership of the fund’s holdings and the income those holdings generate. The
price that investors pay for mutual fund shares is the fund’s per share net asset value (NAV) plus any
shareholder fees that the fund imposes at the time of purchase.
Exchange-Traded Funds (ETFs)
An ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) containing
a basket of stocks. Typically, the objective of an ETF is to achieve returns similar to a particular market
index, including sector indexes. An ETF is similar to an index fund in that it will primarily invest in
securities of companies that are included in a selected market. Unlike traditional mutual funds, which can
only be redeemed at the end of a trading day, ETFs trade throughout the day on an exchange. Like stock
mutual funds, the prices of the underlying securities and the overall market may affect ETF prices.
Similarly, factors affecting a particular industry segment may affect ETF prices that track that particular
sector.
Equity Securities
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Equity securities represent an ownership position in a company. Equity securities typically consist of
common stocks. The prices of stocks and the income they generate (such as dividends) may fluctuate
based on events specific to the company that issued the shares, conditions affecting the general economy
and overall market changes, changes or weakness in the business sector the company does business in,
and other factors. Further, prices of these securities can be affected by financial contracts held by the
issuer or third parties (such as derivatives) relating to the security or other assets or indices.
Debt Securities (Bonds)
Issuers use debt securities to borrow money. Generally, issuers pay investors periodic interest and repay
the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current
interest, but rather are priced at a discount from their face values and their values accrete over time to face
value at maturity. The market prices of debt securities fluctuate depending on such factors as interest
rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates
rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest
rate risk.
Cash and Cash Equivalents
The account may hold cash or invest in cash equivalents. Cash and cash equivalents are the most liquid of
investments. Cash and cash equivalents are considered very low-risk investments, meaning, there is little
risk of losing the principal investment. Typically, low risk also means low return and the interest an
investor can earn on this type of investment is low relative to other types of investing vehicles.
Other Business Risks
Cybersecurity Risk
Investment advisers and their service providers may be prone to operational and information security risks
resulting from cyber-attacks. Cyber-attacks include, among other behaviors, stealing or corrupting data
maintained online or digitally (including, for example, through cyber- attacks known as “phishing” and
“spear-phishing”), denial-of-service attacks on websites, the unauthorized release of confidential
information and causing operational disruption. Cyber-attacks may interfere with the processing of
transactions, cause the release of private information or confidential information of RS Crum, Inc., cause
reputational damage, and subject RS. Crum Inc. to regulatory fines, penalties or financial losses,
reimbursement or other compensation costs, and/or additional compliance costs. While RS Crum, Inc. has
established business continuity plans and systems designed to prevent such cyber-attacks, there are
limitations in such plans including the possibility that certain risks have not been identified or mitigated
Coronavirus or Pandemic Risk
The global outbreak of the 2019 novel coronavirus (“COVID-19”), together with resulting voluntary and
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U.S. federal and state and non-U.S. governmental actions, including, without limitation, mandatory
business closures, public gathering limitations, restrictions on travel and quarantines, has meaningfully
disrupted the global economy and markets. Although the long-term economic fallout of COVID-19 is
difficult to predict, it has and is expected to continue to have ongoing material adverse effects across
many, if not all, aspects of the regional, national and global economy. A pandemic such as COVID-19
may impact the ability of RS. Crum Inc. to operate effectively, including the ability of its personnel or its
service providers and other contractors to function, communicate and travel to the extent necessary. The
spread of any contagious and debilitating health condition among RS Crum, Inc.’s personnel and its
service providers may also affect RS Crum, Inc.’s ability to properly perform our duties.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose material facts regarding any legal or disciplinary
events that would be material to your evaluation of RS Crum, Inc. or the integrity of the Firm’s
management.
RS Crum, Inc. and our personnel seek to maintain the highest level of business professionalism, integrity,
and ethics. The Firm and its employees have not been involved in any legal or disciplinary events.
Item 10 – Other Financial Industry Activities and Affiliations
RS Crum, Inc.’s principal business is providing investment and financial advice and its only source of
compensation is from fees paid directly to the Firm by clients.
Neither RS Crum, Inc., nor any of its management or other personnel, accepts commissions. Therefore,
they are NOT registered as a securities broker-dealer, futures commission merchant or commodity pool
operator, or commodity trading adviser. Additionally, RS Crum, Inc. does NOT pay, directly or
indirectly, for client referrals or accept any other form of kickback or compensation.
Although RS Crum, Inc. is a member of several industry trade associations, it does not have any
affiliations that are material to its business or present any conflict of interest with its clients.
While we may refer clients to other professionals (see Item 14 below), we receive no compensation and
do not believe that any of these referrals creates a material conflict of interest.
Item 11 – Code of Ethics
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RS Crum, Inc. believes that we owe clients the highest level of trust and fair dealing. As part of our
fiduciary duty, we place the interests of our clients ahead of the interests of the Firm and our personnel.
RS Crum, Inc.’s personnel are required to conduct themselves with integrity and follow the principles and
policies detailed in our Code of Ethics.
RS Crum, Inc.’s Code of Ethics attempts to address specific conflicts of interest that either we have
identified or that could likely arise. Our personnel are required to follow clear guidelines from the Code
of Ethics in areas such as gifts and entertainment, other business activities, prohibitions of insider trading,
and adherence to applicable state and federal securities laws. Additionally, individuals who formulate
investment advice for clients, or who have access to nonpublic information regarding any clients’
purchase or sale of securities, are subject to personal trading policies governed by the Code of Ethics (see
below).
RS Crum, Inc. and its affiliates may trade for their own accounts in securities, which are recommended to
and/or purchased for RS Crum, Inc.’s clients. The Code of Ethics is designed to assure that the personal
securities transactions, activities and interests of the employees of RS Crum, Inc. will not interfere with
(i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at
the same time, allowing employees to invest for their own accounts.
The Code of Ethics requires pre-clearance of many employee transactions and restricts trading in close
proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would
permit employees to invest in the same securities as clients, there is a possibility that employees might
benefit from market activity by a client in a security held by an employee. Employee trading is monitored
under the Code of Ethics, and to reasonably prevent conflicts of interest between RS Crum, Inc. and its
clients. The Chief Compliance Officer of RS Crum, Inc. is Daniel Sexton. He reviews employee trades
each quarter, except for his own trading activity that is reviewed by another principal or officer of the
Firm. Under the Code of Ethics, certain classes of securities (i.e., open-end mutual funds and U.S.
Government Securities) have been designated as exempt transactions, based upon a determination that
trading in these would not materially interfere with the best interest of RS Crum, Inc.’s clients.
RS Crum, Inc.’s clients or prospective clients may request a copy of the Firm's Code of Ethics by
contacting our office.
Item 12 – Brokerage Practices
Investment Management
RS Crum, Inc. requires clients to open one or more custodian accounts in their own name at a qualified
custodian of the client’s choice. We encourage the use of a discount type broker and often recommend
that clients custody assets through Charles Schwab & Co., Inc. (“Schwab”). A client is not under any
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obligation to effect trades through any recommended broker or custody their assets with any broker-dealer
we recommend. All clients are free to select any broker-dealer of his or her choice. The client will enter
into a separate agreement with the broker-dealer/custodian to custody the assets. For clients that we
provide investment management services to we require that clients grant us limited power of attorney to
execute client transactions. RS Crum, Inc. is independently owned and operated, and unaffiliated with any
broker-dealer/custodian.
How We Select Brokers/Custodians
We seek to recommend 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. This
does not require us to solicit competitive bids and does not have an obligation to seek the lowest available
commission price. We consider a wide range of factors, including, among others:
1. Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
2. Capability to execute, clear, and settle trades (buy and sell securities for your account)
3. Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
4. Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
[ETFs], etc.)
5. Availability of investment research and tools that assist us in making investment decisions
6. Quality of services
7. Competitiveness of the price of those services (commission rates and other fees) and willingness
to negotiate the prices
8. Reputation, financial strength, and stability
9. Prior service to us and our other clients
10. Availability of other products and services that benefit us, as discussed below (see Products and
Services Available to Us From Schwab)
Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services. However, Schwab receives compensation by charging you commissions or other fees on
trades that it executes or that settle into your Schwab account. This commitment benefits you because the
overall commission rates you pay are lower than they would be otherwise. We have determined that
having Schwab 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 relevant factors, including those
listed above (see How We Select Brokers/Custodians).
Products and Services Available to Us from Schwab
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Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving
independent investment advisory firms like us. They provide RS Crum, Inc. and our clients with access to
its institutional brokerage, trading, custody, reporting, and related services, many of which are not
typically available to Schwab retail customers. Schwab also makes available various support services.
Some of those services help us manage or administer our clients’ accounts; others help us manage and
grow our business. Schwab’s support services generally are available on an unsolicited basis (we don’t
have to request them) and at no charge to us as long as our clients collectively maintain a total of at least
$10 million of their assets in accounts at Schwab. If our clients collectively have less than $10 million in
assets at Schwab, Schwab may charge us quarterly service fees of $1,200.
Following is a more detailed description of Schwab’s support services:
Services That Benefit You
Schwab’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 Schwab include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. Schwab’s services described in this
paragraph generally benefit you and your account.
Services That May Not Directly Benefit You
Schwab also makes 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 Schwab’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 Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
1. Provide access to client account data (such as duplicate trade confirmations and account
statements)
2. Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
3. Provide pricing and other market data
4. Facilitate payment of our fees from our clients’ accounts
5. Assist with back-office functions, recordkeeping, and client reporting
Services That Generally Benefit Only Us
Schwab also offers other services intended to help us manage and further develop our business enterprise.
These services include:
1. Educational conferences and events (which may include Schwab paying for related travel
expenses, entertainment and meals associated with attending)
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2. Consulting on technology, compliance, legal, and business needs
3. Publications and conferences on practice management and business succession
4. Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab may also discount or waive its fees for some of these services or pay
all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional
business entertainment of our personnel.
Our Interest in Schwab’s Services
The availability of these services from Schwab benefits us because we do not have to produce or purchase
them. We do not have to pay for Schwab’s services so long as our clients collectively keep a total of at
least $10 million of their assets in accounts at Schwab. Beyond that, these services are not contingent
upon us committing any specific amount of business to Schwab in trading commissions. The $10 million
minimum may give us an incentive to recommend that you maintain your account with Schwab, based on
our interest in receiving Schwab’s services that benefit our business rather than based 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 Schwab as custodian and broker
is in the best interests of our clients.
We primarily support our selection of Schwab by the scope, quality, and price of Schwab’s services (see
How We Select Brokers/Custodians, above) and not Schwab’s services that benefit only us.
Directed Brokerage Transactions
We are prepared to work with any broker-dealer that the client chooses, and the client may direct the RS
Crum, Inc. to use a particular broker-dealer to execute some or all transactions for the client. In that case,
the client will negotiate terms and arrangements for the account with that broker-dealer, and RS Crum,
Inc. will not seek better execution services or prices from other broker-dealers or be able to “batch” client
transactions for execution through other broker-dealers with orders for other accounts managed by RS
Crum, Inc. As a result, the client may pay higher commissions or other transaction costs or greater
spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the
case. Subject to RS Crum, Inc.’s duty of best execution, the Firm may decline a client’s request to direct
brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in
additional operational difficulties.
Aggregation and Allocation of Transactions
RS Crum, Inc. sometimes aggregates transactions in like securities among client accounts as well as with
accounts of RS Crum, Inc. and our personnel. Aggregation presents a conflict of interest as we may have
an incentive to allocate more favorable executions to our own accounts or the accounts of our personnel.
Our policies to address this conflict are as follows:
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1. We will disclose our aggregation policies in this brochure;
2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty
to seek best execution (which includes the duty to seek best price) for our clients. The trade also
needs to be consistent with the terms of our investment advisory agreement with each client that
has an account included in the aggregation;
3. We will not favor any account over any other account. This includes accounts of RS Crum, Inc.
or any of our personnel. Each account in the aggregated order will participate at the average share
price for all of our transactions in a given security on a given business day (per custodian). All
accounts will pay their individual transaction costs;
4. Before entering an aggregated order, we will prepare a written statement (the “Allocation
Statement”) specifying the participating accounts and how we intend to allocate the order among
those accounts;
5. If the aggregated order is filled entirely, we will allocate shares among clients according to the
Allocation Statement; if the order is partially filled, we will generally allocate it pro-rata
according to the Allocation Statement. However, we may allocate the order differently than
specified in the Allocation Statement if all client accounts receive fair and equitable treatment.
Examples include but are not limited to:
a. When only a small percentage of the order is executed, with respect to purchase
allocations, allocations may be given to accounts high in cash;
b. With respect to sale allocations, allocations may be given to accounts low in cash;
c. We may allocate shares to the account with the smallest order, or to the smallest position,
or to an account that is out of line with respect to security or sector weightings, relative to
other portfolios with similar mandates;
d. We may allocate to one account when that account has limitations in its investment
guidelines prohibiting it from purchasing other securities that we expect to produce
similar investment results and that can be purchased by other accounts in the block;
e.
If an account reaches an investment guideline limit and cannot participate in an
allocation, we may reallocate shares to other accounts. For example, this may be due to
unforeseen changes in an account’s assets after an order is placed;
In any case, we will explain the reasons for a different allocation in writing, which the CCO must
approve;
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6. If an aggregated order is partially filled and we allocate it differently than the Allocation
Statement specifies, no participating account may purchase or sell the security for a reasonable
period following the execution of the block trade. This only applies when the participating
account sells or receives more shares than it would have if the aggregated order been completely
filled;
7. Our books and records will separately reflect each aggregated order and the securities held by,
bought, and sold for each client account;
8. Funds and securities of clients participating in an aggregated order will be deposited with one or
more qualified custodians. Clients’ cash and securities will not be held collectively any longer
than is necessary to settle the trade on a delivery versus payment basis. Following settlement,
cash or securities held collectively for clients will be delivered out to the qualified custodian as
soon as practical;
9. We do not receive additional compensation or remuneration of any kind as a result of aggregating
orders; and
10. We will provide individual investment advice and treatment to each client’s account.
Item 13 – Review of Accounts
Managed Account Reviews & Reporting
RS Crum, Inc.’s Advisers are responsible for assigning an investment model to each account or, on
occasion, assigning a model to a household of client accounts. With the use of a third-party trading
software/service, accounts are monitored for trading opportunities due to, but not limited to, cash needs,
deposits and withdrawals, and deviation from model allocation. The monitoring of accounts and the
creation of trade tickets is delegated to our Trader. The Trader will exercise diligence in entering and
executing trades for clients. When necessary, trades identified by the Trader are reviewed by the Adviser
for consistency with client goals and/or tax considerations.
We will provide reports per the terms outlined in the client Advisory Agreement. Generally, we compile
periodic investment reports and Statement of Assets and provide these to clients. Most clients receive a
Statement of Assets semi-annually. Some clients receive reports as frequently as quarterly. RS Crum,
Inc.’s Statement of Assets report contains portfolio performance for the period, portfolio value, and a
listing of individual securities.
Each client receives a written statement from the custodian that includes an accounting of all holdings and
transactions in the account for the reporting period.
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Financial Plan Reviews & Reporting
RS Crum, Inc. provides financial planning services on a comprehensive and limited basis. We work with
clients on an ongoing basis to review the plan as needed or as requested by the client.
Item 14 – Client Referrals and Other Compensation
Schwab Support Products and Services
We receive an economic benefit from Schwab in the form of the support products and services they make
available to us and other independent investment advisors whose clients maintain their accounts at
Schwab. These products and services, how they benefit us, and the related conflicts of interest are
described above (see Item 12 – Brokerage Practices). We do not base particular investment advice, such
as buying particular securities for our clients, on the availability of Schwab’s products and services to us.
Recommendation of Unaffiliated Professionals
We may refer clients to unaffiliated professionals for a variety of services such as insurance, mortgage
brokerage, real estate sales, legal, and/or tax/accounting services. In turn, these professionals may refer
clients to RS Crum, Inc. for investment management/financial planning needs. We will not refer clients to
financial planners and other investment advisers unless they are licensed, registered, or exempt from
registration as an investment adviser. We do not have any arrangements with individuals or companies
that we refer clients to, and we do not receive any compensation for these referrals. However, it could be
concluded that RS Crum, Inc. is receiving an indirect economic benefit from this practice, as the
relationships are mutually beneficial. For example, there could be an incentive for us to recommend
services of firms who refer clients to RS Crum, Inc.
We refer clients to professionals we believe are competent and qualified in their field. It is ultimately the
client’s responsibility to evaluate the provider. We will generally provide the client with a list of
professionals that the client can contact, and it is solely the client’s decision whether to engage a
recommended firm. Clients are under no obligation to purchase any products or services through these
professionals, and RS Crum, Inc. has no control over the services provided by another firm. Clients who
choose to engage these professionals will sign a separate agreement with the other firm. Fees charged by
the other firm are separate from and in addition to fees charged by RS Crum, Inc.
If the client desires, RS Crum, Inc. will work with these professionals or the client’s other advisers (such
as an accountant, attorney, or other investment adviser) to help ensure that the provider understands the
client’s financial plan/investments and to coordinate services for the client. RS Crum, Inc. does not share
information with an unaffiliated professional unless first authorized by the client.
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Item 15 – Custody
Clients will engage an independent broker-dealer/custodian to maintain their account(s) and, as such, RS
Crum, Inc. will not have physical custody of Client assets, monies or securities. However, RS Crum, Inc.
maintains a limited power of attorney over clients’ accounts when clients authorize us to deduct our
management fees directly from the client’s account. Since RS Crum, Inc. may withdraw investment
advisory fees directly from Clients’ accounts, RS Crum, Inc. is considered to have custody in a limited
capacity. All checks or wire transfers for deposit to client accounts are required to be made out to or sent
to the account custodian.
Clients will receive statements directly from their qualified custodian at least quarterly. The statements
will reflect the client’s funds and securities held with the qualified custodian as well as any transactions
that occurred in the account, including the deduction of our fee.
Clients should carefully review the account statements they receive from the qualified custodian. When
clients receive statements from RS Crum, Inc. as well as from the qualified custodian, they should
compare these two reports carefully. Clients with any questions about their statements should contact us
at the address or phone number on the cover of this brochure. Clients who do not receive a statement from
their qualified custodian at least quarterly should also notify us.
RS Crum, Inc. is deemed to have custody of clients’ funds or securities when clients have a standing letter
of authorization (“SLOA”) with their custodian to move money from a client’s account to a third-party
and, under that SLOA, authorize us to designate the amount or timing of transfers to those specifically
authorized account(s) with the custodian. The SEC has set forth a set of standards intended to protect
client assets in such situations, which we follow.
Item 16 – Investment Discretion
Discretionary Management
RS Crum, Inc. usually receives discretionary trading authority (via a Limited Power of Attorney) from the
client at the outset of an advisory relationship to select the identity and amount of securities to be bought
or sold. RS Crum, Inc. does not contact clients before placing trades in their account, but clients will
receive confirmations directly from the broker for any trades placed. Clients grant us discretionary
authority in the agreement they sign with us. Clients also give us trading authority over their accounts
when they sign the custodian paperwork.
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However, certain client-imposed conditions may limit our discretionary authority, such as where the
client prohibits transactions in specific security types or industries or directs RS Crum, Inc. to execute
transactions through specific broker-dealers.
Non-Discretionary Management
For non-discretionary accounts, RS Crum, Inc. will contact the client before making recommendations we
deem appropriate for the client. Non-discretionary clients should be aware that recommendations are
typically time sensitive and the following circumstances may cause market movements to work against
the client:
• When we have trading authority, RS Crum, Inc. will not effect the transaction until we receive
verbal or written instructions from the client;
• When we do not have trading authority, the client is responsible for placing the trade;
• RS Crum, Inc. generally will not aggregate transactions for non-discretionary accounts with
discretionary accounts; and
• Transactions for non-discretionary accounts will generally be effected after transactions in
discretionary accounts.
Item 17 – Voting Client Securities
As a matter of Firm policy and practice, RS Crum, Inc. does not vote proxies on behalf of advisory
clients. Clients retain the responsibility for receiving and voting proxies for any and all securities
maintained in client portfolios. Clients will receive their proxies or other solicitations directly from their
custodian or a transfer agent.
RS Crum, Inc. might provide advice, if requested, regarding the clients’ voting of proxies. RS Crum, Inc.
will not be deemed to have proxy voting authority solely as a result of providing advice or information
about a particular proxy vote to a client.
For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974
(“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any
proxies for securities held in the plan accounts.
Item 18 – Financial Information
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RS Crum, Inc. has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
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Form ADV, Part 2B Brochure Supplement
Mark Rylance, CFP®
Jon Theriault, CFP®
Daniel Sexton, CFP®
Eric Papa, CFP®
RS Crum, Inc.
4 Upper Newport Plaza Drive
Suite 201
Newport Beach, CA 92660
(949) 428-9696
www.rscrum.com
March 27, 2025
This Brochure Supplement provides information about Mark Rylance, Jon Theriault, Daniel
Sexton, and Eric Papa that supplements the RS Crum, Inc. Brochure. You should have received a
copy of that Brochure. Please contact our office if you did not receive a copy or if you have any
questions about the contents of this supplement.
Additional information about Mark Rylance, Jon Theriault, Daniel Sexton, and Eric Papa is
available on the SEC’s website at www.adviserinfo.sec.gov.
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Supervised Persons
RS Crum, Inc.’s Supervised Persons are its officers (or other persons occupying a similar status or
performing similar functions) and employees, as well as other persons who provide advice on behalf of
the Firm and are subject to RS Crum, Inc.’s supervision and control.
Description of Professional Designations Used in this Brochure Supplement
CERTIFIED FINANCIAL PLANNER™
The CERTIFIED FINANCIAL PLANNER™ and CFP® (collectively, the “CFP® marks”) are professional
certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc.
(“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. The CFP® is recognized in the United States and a
number of other countries for its (1) high standard of professional education; (2) stringent code of conduct
and standards of practice; and (3) ethical requirements that govern professional engagements with clients.
To earn the credential, each CFP® candidate must have a bachelor’s degree (or higher) from an
accredited college or university and three years of full-time personal financial planning
experience. In addition, candidates must take the CFP® Certification examination and complete
a CFP® board- registered program or hold an accepted designation, degree, or license. Every
two years, CFP® certificate holders must complete a minimum of 30 hours of continuing
education. More information regarding the CFP® is available at http://www.cfp.net/default.asp.
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Mark Rylance, CFP®
Item 2 - Educational Background and Business Experience
Born:
1968
Education:
University of Arizona - BS Business Administration
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Background:
RS Crum, Inc., Lead Advisor / Owner – 2011 to Present
RS Crum, Inc., Lead Advisor – 2003 to 2011
Prior to coming to RS Crum, Inc., Mr. Rylance worked for 6 years at Merrill Lynch
as a financial consultant for their Private Client Group.
Professional Designations:
CERTIFIED FINANCIAL PLANNER™
Item 3 - Disciplinary Information
Registered investment advisers and their supervised persons are required to disclose material facts
regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr.
Rylance or the integrity of RS Crum, Inc.’s management.
Not applicable; Mr. Rylance has no legal or disciplinary action applicable to his status and / or
registration.
Item 4 - Other Business Activities
RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of
compensation are fees paid to the Firm directly by the client.
Neither RS Crum, Inc. nor Mr. Rylance accepts commissions. Therefore, they are NOT registered as a
securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading
adviser.
Although Mr. Rylance is a member of several industry trade associations, he does not have any
affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients.
Item 5 - Additional Compensation
Mr. Rylance receives no other compensation besides his salary, bonus, and other customary employment
benefits.
Item 6 - Supervision
RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in
accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance
is responsible for the general supervision of Supervised Persons of the Firm; however, he is not
supervised.
Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of
others will exercise reasonable supervision over those subject to their supervision or authority to prevent
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violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons
may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such
violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to
them.
RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and
allocate resources for client care, services, and business priorities. In addition, the Firm requires
Supervised Persons and employees to complete regular financial disclosures and review, at least annually,
the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility.
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Jon Theriault, CFP®
Item 2 - Educational Background and Business Experience
Born:
1972
Education:
University of Arizona - BS Business Administration
Pepperdine University – MBA (Finance)
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Background:
RS Crum, Inc., Lead Advisor / Owner – 2011 to Present
RS Crum, Inc., Lead Advisor – 2008 to 2011
Prior to coming to RS Crum, Inc. Mr. Theriault worked for 13 years providing
consulting, valuation, and merger and acquisition advisory services to privately held
business owners.
Professional Designations:
CERTIFIED FINANCIAL PLANNER™
Item 3 - Disciplinary Information
Registered investment advisers and their supervised persons are required to disclose material facts
regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr.
Theriault or the integrity of RS Crum, Inc.’s management.
Not applicable; Mr. Theriault has no legal or disciplinary action applicable to his status and / or
registration.
Item 4 - Other Business Activities
RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of
compensation are fees paid to the Firm directly by the client.
Neither RS Crum, Inc. nor Mr. Theriault accepts commissions. Therefore, they are NOT registered as a
securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading
adviser.
Although Mr. Theriault is a member of several industry trade associations, he does not have any
affiliations that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients.
Item 5 - Additional Compensation
Mr. Theriault receives no other compensation besides his salary, bonus, and other customary employment
benefits.
Item 6 - Supervision
RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in
accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance
is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling
949-428-9696.
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Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of
others will exercise reasonable supervision over those subject to their supervision or authority to prevent
violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons
may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such
violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to
them.
RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and
allocate resources for client care, services, and business priorities. In addition, the Firm requires
Supervised Persons and employees to complete regular financial disclosures and review, at least annually,
the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility.
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Daniel Sexton, CFP®
Item 2 - Educational Background and Business Experience
Born:
1966
Education:
California State University, Long Beach
BS Business (Finance), Minor Business Economics
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Background:
RS Crum, Inc., Lead Advisor / Owner – 2011 to Present
RS Crum, Inc., Lead Advisor – 2003 to 2011
RS Crum, Inc. (formerly RS Crum Advisory Services), Employee 1996 to 2003
Prior to coming to RS Crum, Inc. Mr. Sexton was employed in the aerospace industry
as a technical writer.
Professional Designations:
CERTIFIED FINANCIAL PLANNER™
Item 3 - Disciplinary Information
Registered investment advisers and their supervised persons are required to disclose material facts
regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr.
Sexton or the integrity of RS Crum, Inc.’s management.
Not applicable; Mr. Sexton has no legal or disciplinary action applicable to his status and / or registration.
Item 4 - Other Business Activities
RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of
compensation are fees paid to the Firm directly by the client.
Neither RS Crum, Inc. nor Mr. Sexton accepts commissions. Therefore, they are NOT registered as a
securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading
adviser.
Although Mr. Sexton is a member of several industry trade associations, he does not have any affiliations
that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients.
Item 5 - Additional Compensation
Mr. Sexton receives no other compensation besides his salary, bonus, and other customary employment
benefits.
Item 6 - Supervision
RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in
accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance
is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling
949-428-9696.
vii
RS Crum, Inc. Brochure Supplement
Revised March 27, 2025
RS Crum Inc. Form ADV Part 2A Brochure Supplement
Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of
others will exercise reasonable supervision over those subject to their supervision or authority to prevent
violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons
may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such
violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to
them.
RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and
allocate resources for client care, services, and business priorities. In addition, the Firm requires
Supervised Persons and employees to complete regular financial disclosures and review, at least annually,
the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility.
viii
RS Crum, Inc. Brochure Supplement
Revised March 27, 2025
RS Crum Inc. Form ADV Part 2A Brochure Supplement
Eric Papa, CFP®
Item 2 - Educational Background and Business Experience
Born:
1995
Education:
UCSB – BA Economics
American College of Financial Services – CFP® Certification Education Program
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Background:
RS Crum, Inc., Associate Advisor – 2024 to Present
Prior to coming to RS Crum, Inc., Mr. Papa worked for 2 1/2 years as a Financial
Planning Specialist and 2 years as a Private Wealth Associate providing financial
planning service and analysis for individuals.
Professional Designations:
CERTIFIED FINANCIAL PLANNER™
Item 3 - Disciplinary Information
Registered investment advisers and their supervised persons are required to disclose material facts
regarding any legal or disciplinary events that would be material to your evaluation of RS Crum, Inc., Mr.
Papa or the integrity of RS Crum, Inc.’s management.
Not applicable; Mr. Papa has no legal or disciplinary action applicable to his status and / or registration.
Item 4 - Other Business Activities
RS Crum, Inc.’s principal business is providing investment and financial advice and their only source of
compensation are fees paid to the Firm directly by the client.
Neither RS Crum, Inc. nor Mr. Papa accepts commissions. Therefore, they are NOT registered as a
securities broker-dealer, futures commission merchant or commodity pool operator, or commodity trading
adviser.
Although Mr. Papa is a member of several industry trade associations, he does not have any affiliations
that are material to RS Crum, Inc.’s business or present any conflict of interest with its clients.
Item 5 - Additional Compensation
Mr. Papa receives no other compensation besides his salary, bonus, and other customary employment
benefits.
Item 6 - Supervision
RS Crum, Inc. expects its supervised persons to conduct themselves with integrity and professionalism, in
accordance with the Firm’s fiduciary duty to clients and standards of business conduct. Mark K. Rylance
is responsible for the general supervision of Supervised Persons of the Firm and can be reached by calling
949-428-9696.
Supervised Persons with supervisory responsibility, authority, or the ability to influence the conduct of
others will exercise reasonable supervision over those subject to their supervision or authority to prevent
violation of applicable statutes, regulations, or provisions of the Code. In so doing, Supervised Persons
ix
RS Crum, Inc. Brochure Supplement
Revised March 27, 2025
RS Crum Inc. Form ADV Part 2A Brochure Supplement
may rely on procedures established by RS Crum, Inc. that are designed to prevent and detect such
violations. Supervised Persons are responsible for the reasonable supervision of the persons who report to
them.
RS Crum, Inc. conducts periodic and special meetings, when warranted, to update, review, plan, and
allocate resources for client care, services, and business priorities. In addition, the Firm requires
Supervised Persons and employees to complete regular financial disclosures and review, at least annually,
the Firm’s Code of Ethics and Policy and Procedures as part of its compliance responsibility.
x
RS Crum, Inc. Brochure Supplement
Revised March 27, 2025