Overview
Assets Under Management: $326 million
High-Net-Worth Clients: 77
Average Client Assets: $4 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (ADV FORM 2A)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 1.00% |
$1,000,001 | $2,000,000 | 0.75% |
$2,000,001 | $10,000,000 | 0.50% |
$10,000,001 | and above | 0.25% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $10,000 | 1.00% |
$5 million | $32,500 | 0.65% |
$10 million | $57,500 | 0.58% |
$50 million | $157,500 | 0.32% |
$100 million | $282,500 | 0.28% |
Clients
Number of High-Net-Worth Clients: 77
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 98.77
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 363
Discretionary Accounts: 363
Regulatory Filings
CRD Number: 163057
Last Filing Date: 2024-04-02 00:00:00
Website: HTTPS://WWW.RATIONALIM.COM
Form ADV Documents
Primary Brochure: ADV FORM 2A (2025-03-27)
View Document Text
Rational Investment Management, LLC
Firm Brochure - Form ADV Part 2A
660 Amaranth Blvd
Mill Valley, CA 94941
(415) 379-0749
dan@rationalim.com
www.rationalim.com
This brochure provides information about the qualifications and business practices of Rational Investment
Management, LLC. If you have any questions about the contents of this brochure, please contact us at
(415) 379-0749 or by email at: dan@rationalim.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about Rational Investment Management, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov. Rational Investment Management, LLC’s CRD number is: 163057.
Registration does not imply a certain level of skill or training.
Version Date: 03/26/2025
Item 2: Material Changes
No material changes have been made.
i
Item 3: Table of Contents
Table of Contents
Item 1: Cover Page
Item 2: Material Changes ......................................................................................................................................................................................... i
Item 3: Table of Contents ........................................................................................................................................................................................ ii
Item 4: Advisory Business ...................................................................................................................................................................................... 1
A. Description of the Advisory Firm ................................................................................................................................................................... 1
B. Types of Advisory Services ........................................................................................................................................................................... 1
Investment Supervisory Services ............................................................................................................................................................... 1
Services Limited to Specific Types of Investments ..................................................................................................................................... 1
C. Client Tailored Services and Client Imposed Restrictions ............................................................................................................................ 2
D. Wrap Fee Programs ..................................................................................................................................................................................... 2
E. Amounts Under Management ....................................................................................................................................................................... 2
Item 5: Fees and Compensation ............................................................................................................................................................................ 2
A. Fee Schedule ................................................................................................................................................................................................ 2
Investment Supervisory Services Fees ...................................................................................................................................................... 2
B. Payment of Fees ........................................................................................................................................................................................... 3
Payment of Investment Supervisory Fees .................................................................................................................................................. 3
C. Clients Are Responsible For Third Party Fees ............................................................................................................................................. 3
D. Prepayment of Fees ..................................................................................................................................................................................... 3
E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................................ 3
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................................................................... 3
Item 7: Types of Clients ......................................................................................................................................................................................... 4
Minimum Account Size ............................................................................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ............................................................................................... 4
A. Methods of Analysis and Investment Strategies ......................................................................................................................................... 4
Methods of Analysis .................................................................................................................................................................................... 4
Investment Strategies ................................................................................................................................................................................. 4
B. Material Risks Involved ............................................................................................................................................................................... 4
C. Risks of Specific Securities Utilized ............................................................................................................................................................ 5
Item 9: Disciplinary Information .............................................................................................................................................................................. 6
A. Criminal or Civil Actions .............................................................................................................................................................................. 6
B. Administrative Proceedings ........................................................................................................................................................................ 6
C. Self-regulatory Organization (SRO) Proceedings ....................................................................................................................................... 6
Item 10: Other Financial Industry Activities and Affiliations ................................................................................................................................... 6
A. Registration as a Broker/Dealer or Broker/Dealer Representative ............................................................................................................. 6
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ...................................... 6
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............................................................ 7
D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .................................................. 7
ii
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................................................ 7
A. Code of Ethics ............................................................................................................................................................................................ 7
B. Recommendations Involving Material Financial Interests ........................................................................................................................... 8
C. Investing Personal Money in the Same Securities as Clients ..................................................................................................................... 8
Item 12: Brokerage Practices ................................................................................................................................................................................. 8
A. Factors Used to Select Custodians and/or Broker/Dealers ........................................................................................................................ 8
1. Brokerage for Client Referrals .............................................................................................................................................................. 8
2. Clients Directing Which Broker/Dealer/Custodian to Use .................................................................................................................... 8
Item 13: Reviews of Accounts ................................................................................................................................................................................ 8
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ........................................................................................... 8
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ......................................................................................................... 9
C. Content and Frequency of Regular Reports Provided to Clients ................................................................................................................ 9
Item 14: Client Referrals and Other Compensation ............................................................................................................................................... 9
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .......................... 9
B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................................................................... 9
Item 15: Custody .................................................................................................................................................................................................... 9
Item 16: Investment Discretion ............................................................................................................................................................................... 9
Item 17: Voting Client Securities .......................................................................................................................................................................... 10
Item 18: Financial Information .............................................................................................................................................................................. 10
A. Balance Sheet .......................................................................................................................................................................................... 10
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .................................................. 10
C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................. 10
Item 19: Requirements For State Registered Advisers ........................................................................................................................................ 11
A. Principal Executive Officers and Management Persons; Their Formal Education and Business Background ......................................... 11
B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) ................................. 11
C. How Performance Based Fees are Calculated and Degree of Risk to Clients ......................................................................................... 11
D. Material Disciplinary Disclosures for Management Persons of this Firm .................................................................................................. 11
E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) .................................................................. 11
PRIVACY POLICY ............................................................................................................................................................................................... 12
iii
Item 4: Advisory Business
A. Description of the Advisory Firm
Rational Investment Management, LLC (hereinafter, “RIM”) is a limited liability company
organized in the state of California.
This firm has been in business since March 2012. RIM’s managers and principal owners
are Daniel S. Sinton and Brian C. Proses.
B. Types of Advisory Services
RIM offers the following services to advisory clients:
Investment Supervisory Services
RIM offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. RIM typically creates an
Investment Policy Statement for each client, which outlines the client’s current situation
(income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment
Policy Statement) to aid in the selection of a portfolio that matches each client’s specific
situation. Investment Supervisory Services include, but are not limited to, the following:
•
•
•
Investment strategy
Asset allocation
Risk tolerance
•
•
•
Personal investment policy
Asset selection
Regular portfolio monitoring
RIM evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. RIM will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in each client’s Investment Policy
Statement.
Services Limited to Specific Types of Investments
RIM generally invests on behalf of client accounts in mutual funds and ETFs. RIM may
use other securities as well to help diversify a portfolio when it deems applicable.
1
C. Client Tailored Services and Client Imposed Restrictions
RIM generally offers the same suite of services to all of its clients. However, specific client
financial plans and their implementation depend upon the client’s Investment Policy
Statement, which outlines each client’s current situation (income, tax levels and risk
tolerance levels) and is used to construct a client specific plan to aid in the selection of a
portfolio that matches restrictions, needs and targets.
Clients may impose restrictions on investing in certain industries, in accordance with their
values or beliefs. RIM may end the relationship, however, if the restrictions prevent RIM
from properly servicing the client account, or if the restrictions would require RIM to deviate
from its standard suite of services.
D. Wrap Fee Programs
fees,
transaction costs,
A wrap fee program is an investment program where the investor pays one stated fee that
includes management
fund expenses, and any other
administrative fees. RIM does not participate in any wrap fee programs.
E. Amounts Under Management
RIM’s assets under management are:
Discretionary Amounts:
Date Calculated:
Non-discretionary
Amounts:
$351,343,543
$0.00
12/31/2024
Item 5: Fees and Compensation
A. Fee Schedule
Investment Supervisory Services Fees
Fees for portfolio management services are typically calculated as an annual percentage
of managed assets, paid quarterly in arrears based on the average value of all assets in
the client’s account for that quarter. Fees are generally debited from client accounts by
the account custodian after the end of each quarter. Clients may request to be billed
directly. The fee schedule is:
1.00% annually on the first $1,000,000
0.75% annually on the next $1,000,000
0.50% annually from $2,000,001 to $10,000,000
0.25% thereafter
2
These fees are computed on a “blended rate” basis. For example, an account of
$3,000,000 will be charged 0.75% per year (1% on the first $1,000,000, 0.75% on the next
million, and 0.50% on the next million).
These fees are negotiable depending upon the needs of the client and complexity of the
situation, and the final fee schedule is attached as Schedule A of the Investment
Management Agreement. Clients may terminate their contracts with written notice.
Because fees are charged in arrears, no refund policy is necessary. If a client account is
terminated within 30 days of signing the Investment Management Agreement, any
advisory fees are refunded.
Lower fees for comparable services may be available from other sources.
B. Payment of Fees
Payment of Investment Supervisory Fees
RIM typically deducts advisory fees directly from the client’s account, although it may
invoice and bill a client directly on request. Fees are paid quarterly in arrears.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third-party fees, such as mutual fund fees
and trade commissions. Those fees are separate and distinct from the fees charged by
RIM. Please see Item 12 of this brochure regarding broker/custodians.
D. Prepayment of Fees
RIM collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation for the Sale of Securities to Clients
Neither RIM nor its supervised persons accept any compensation for the sale of securities
or other investment products, including asset-based sales charges or services fees from
the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side
Management
RIM does not accept performance-based fees or other fees based on a share of capital gains on
or capital appreciation of the assets of a client.
3
Item 7: Types of Clients
RIM generally provides management supervisory services to the following types of clients:
Individuals
High-Net-Worth Individuals
Minimum Account Size
$1,000,000 is the minimum account size, but in special situations, exceptions may be made.
Item 8: Methods of Analysis, Investment Strategies, and Risk
of Investment Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
RIM relies on several sources of information to analyze investment securities and to
develop portfolio management strategies and allocations. RIM uses Dimensional Fund
Advisors (“DFA”) white papers, research publications, and the Returns 2.0 Program of
historical asset class returns; Schwab Institutional and other brokerage firm research
reports and white papers; financial websites, newspapers, financial trade journals, and
periodic discussions with professional colleagues.
Investment Strategies
RIM primarily utilizes the institutional asset class mutual funds of DFA and various
Exchange Traded Funds (ETFs) in the management of client portfolios. RIM has
determined that DFA mutual funds, ETFs and Avantis ETFs in many cases effectively
capture the returns of targeted asset classes and provide an opportunity to effectively
implement the investment policies of client portfolios. DFA and other companies provide
clients with prospectuses that identify potential risks involved in investing in the mutual
funds and ETFs used in client portfolios.
B. Material Risks Involved
Client accounts may not achieve their investment objectives. A strategy may not be
successful and clients may lose some or all of their investment.
Investor sentiment on the market, an economic sector, an industry, an individual stock,
fixed income or other securities is not predictable and can adversely affect an account’s
investments.
4
RIM may not be able to obtain complete or accurate information about an investment and
may misinterpret the information that it does receive. RIM also may receive material, non-
public information about an issuer that prevents it from trading securities of that issuer for
a client when the client could make a profit or avoid losses.
An account may have higher portfolio turnover and transaction costs than a similar
account managed by another investment adviser. These costs reduce investments and
potential profit or increase loss.
Counterparties such as brokers, dealers, futures commission merchants, custodians and
administrators with which RIM does business on behalf of clients may default on their
obligations. For example, a client may lose its assets on deposit with a broker if the broker,
its clearing broker or an exchange clearing house becomes bankrupt.
Changes in economic conditions can adversely affect investment performance. At times,
economic conditions in the U.S. and elsewhere have deteriorated significantly, resulting
in volatile securities markets and large investment losses. Government actions
responding to these conditions could lead to inflation and other negative consequences to
investors.
RIM and its affiliates and agents generally are not responsible to any client or investor for
losses incurred in an account unless the conduct resulting in such loss constituted a
knowing violation of applicable law, gross negligence or willful misconduct.
The attorneys who represent RIM or its managers do not represent clients. Clients must
hire their own counsel for legal advice and representation.
C. Risks of Specific Securities Utilized
RIM generally seeks investment strategies that do not involve significant or unusual risk
beyond that of the general domestic and/or international equity markets.
Mutual Funds and Exchange Traded Funds (ETFs): Investing in mutual funds and ETFs
carries the risk of capital loss. These funds are not guaranteed or insured by the FDIC or
any other government agency. You can lose money investing in these funds. All mutual
funds and ETFs have costs that lower investment returns, including fees that client
accounts will pay in addition to the fees they pay to RIM.
Fixed Income is an investment that makes fixed periodic payments in the future that may
involve economic risks such as inflationary risk, interest rate risk, default risk, repayment
of principal risk, etc.
Debt securities carry risks such as the possibility of default on the principal, fluctuation in
interest rates and counterparties being unable to meet obligations.
REITs have specific risks including valuation difficulties due to cash flows, dividends paid
in stock rather than cash and the payment of debt resulting in dilution of shares.
5
Long-term investing is designed to capture market rates of both return and risk. Due to
its nature, the long-term investment strategy can expose clients to various other types of
risk that will typically surface at various intervals during the time the client owns the
investments. These risks include but are not limited to inflation (purchasing power) risk,
interest rate risk, economic risk, market risk and political/regulatory risk.
Short-term investing risks include liquidity, economic stability and inflation.
Non-U.S., private and government securities include risks such as political risks;
economic conditions of the country in which the issuer is located; limitations on foreign
investment in any such country; currency exchange risks; withholding taxes; limited
information about the issuer; limited liquidity; and limited regulatory oversight.
Past performance is not a guarantee of future returns. Investing in securities
involves a risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer
Representative
Neither RIM nor its representatives are registered as or have pending applications to
become a broker/dealer or as representatives of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Adviser
6
Neither RIM nor its representatives are registered as or have pending applications to
become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity
Trading Adviser.
C. Registration Relationships Material to this Advisory
Business and Possible Conflicts of Interests
The principal business of Brian C. Proses is the practice of accountancy as a certified
public accountant with Proses Accountancy Corp, an accountancy corporation (“PAC”).
This other business activity provides a substantial source of his income and involves a
substantial amount of his time, though that income and time is gradually being reduced.
This accountancy activity may present a conflict of interest by limiting the amount of time
that he has available for his duties on behalf RIM. RIM does not believe this conflict of
interest is material, however, given the nature of Brian C. Proses’ activities on RIM’s
behalf. RIM addresses any conflict of interest through periodic reviews by RIM’s other
manager, Daniel S. Sinton.
Certain clients of RIM may also be, but are under no obligation to be, clients of PAC.
Those clients have separate agreements with PAC, and pay separate fees to PAC for
accounting services. RIM does not provide accounting services and is not licensed by the
California Board of Accountancy.
All material conflicts of interest under Section 260.238 (k) of the California Corporations
Code are disclosed regarding the investment adviser, its representatives or any of its
employees, which could be reasonably expected to impair the rendering of unbiased and
objective advice.
D. Selection of Other Advisers or Managers and How This
Adviser is Compensated for Those Selections
RIM does not utilize nor select other advisers or third-party managers. All assets are
managed by RIM management.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
RIM has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service
on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations,
Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance
Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions.
RIM’s Code of Ethics is available on request to any client or prospective client.
7
B. Recommendations Involving Material Financial Interests
RIM does not recommend that clients buy or sell any security in which a related person to
RIM or RIM has a material financial interest, except as set forth in Item 11.C, below.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of RIM may buy or sell securities for themselves that
they also recommend to clients. Such transactions may create a conflict of interest by
providing an opportunity for representatives of RIM to buy or sell the same securities
before or after recommending the same transactions to clients resulting in representatives
obtaining a better price. RIM seeks to document transactions that could be construed as
conflicts of interest and transact client business before its own when similar securities are
being bought or sold. However, given the broad investment nature of the mutual funds
and ETFs used in client portfolios, the likelihood of a conflict is extremely low.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
RIM has selected Charles Schwab & Co., Inc. to serve as the custodian for client accounts
based on its relatively low transaction fees and access to mutual funds and ETFs. RIM
does not charge a premium or commission on transactions, beyond the actual cost
imposed by the custodian.
1. Brokerage for Client Referrals
RIM receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
2. Clients Directing Which Broker/Dealer/Custodian to Use
RIM generally will not allow clients to direct RIM to use a specific broker-dealer to
execute transactions. Clients must use the RIM recommended custodian (broker-
dealer), currently Charles Schwab & Co. Inc.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
Client accounts are reviewed at least quarterly by Daniel S. Sinton, Manager, for
consistency with the accounts’ Investment Policy Statements.
8
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Non-periodic reviews may be triggered by material market, economic or political events,
by changes in a client’s financial situations (such as retirement, termination of
employment, physical move, or inheritance), or at the client’s initiative.
C. Content and Frequency of Regular Reports Provided to
Clients
Each client will receive at least quarterly from the custodian, a written report that details
the client’s account including assets held and asset value which will come from the
custodian.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
RIM does not receive any economic benefit, directly or indirectly from any third party for
advice rendered to RIM clients.
B. Compensation to Non – Advisory Personnel for Client
Referrals
RIM does not engage solicitors to whom it pays cash or a portion of the advisory fees paid
by clients referred to it by those solicitors.
Item 15: Custody
The custodian of each client account sends account statements at least quarterly to the client.
Each client should carefully review those statements and compare them with the statements that
such client receives directly from RIM.
Item 16: Investment Discretion
For those client accounts where RIM provides ongoing supervision, the client has given RIM
written discretionary authority over the client’s accounts with respect to securities to be bought or
sold and the amount of securities to be bought or sold. Details of this relationship are disclosed
to the client before any advisory relationship has commenced. The client provides RIM
discretionary authority via a limited power of attorney in the Investment Management Agreement.
9
RIM’s discretion is limited by the requirement that clients advise RIM of:
•
the investment objectives of the account;
•
any changes or modifications to those objectives; and
•
any specific investment restrictions relating to the account.
A client must promptly notify RIM in writing if the client considers any investments recommended
or made for the account to violate such objectives or restrictions. A client may at any time direct
RIM to sell any securities or take such other lawful actions as the client may specify to cause the
account to comply with the client’s investment objectives. In addition, a client may notify RIM at
any time not to invest any funds in the client’s account in specific securities or specific categories
of securities.
Item 17: Voting Client Securities
RIM will not ask for, nor accept voting authority for client securities. Clients should receive proxies
directly from the issuer of the security or the custodian.
Item 18: Financial Information
A. Balance Sheet
RIM does not require nor solicit prepayment of more than $500 in fees per client, six
months or more in advance and therefore does not need to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither RIM nor its management have any financial conditions that are likely to reasonably
impair its ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
RIM has not been the subject of a bankruptcy petition in the last ten years.
10
Item 19: Requirements For State Registered Advisers
A. Principal Executive Officers and Management Persons; Their
Formal Education and Business Background
RIM currently has two management persons/executive officers: Daniel S. Sinton and Brian
C. Proses. Their education and business background can be found on the Supplemental
ADV Part 2B.
B. Other Businesses in Which This Advisory Firm or its
Personnel are Engaged and Time Spent on Those (If Any)
Daniel S. Sinton’s and Brian C. Proses’ other business activities can be found on the
Supplemental ADV Part 2B.
C. How Performance Based Fees are Calculated and Degree of
Risk to Clients
RIM does not accept performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
D. Material Disciplinary Disclosures for Management Persons
of this Firm
No management person at RIM or RIM has been involved in an arbitration claim or been
found liable in a civil, self-regulatory organization, or administrative proceeding that is
material to the client’s evaluation of the firm or its management.
E. Material Relationships That Management Persons Have with
Issuers of Securities (If Any)
Neither RIM, nor its management persons, has any relationship or arrangement with
issuers of securities.
11
PRIVACY POLICY
RIM collects non-public personal information about its clients from information received from
clients on applications or other forms, and information about clients’ transactions with RIM, its
affiliates or others. RIM does not disclose any non-public personal information about its clients
or former clients to anyone, except as permitted by law. RIM restricts access to non-public
personal information about its clients and investors to its employees who need to know that
information to provide services to clients. RIM maintains physical, electronic and procedural
safeguards that comply with federal standards to guard clients’ personal information.
12
Additional Brochure: ADV FORM 2B FOR DANIEL SINTON (2025-03-27)
View Document Text
This brochure supplement provides information about Daniel Soulis Sinton that
supplements the Rational Investment Management, LLC brochure. You should have
received a copy of that brochure. Please contact Daniel Soulis Sinton, Manager if you
did not receive Rational Investment Management, LLC’s brochure or if you have any
questions about the contents of this supplement.
Additional information about Daniel Soulis Sinton is also available on the SEC’s website
at www.adviserinfo.sec.gov.
Rational Investment Management, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Daniel Soulis Sinton
Personal CRD Number: 2772367
Investment Adviser Representative
Rational Investment Management, LLC
660 Amaranth Blvd
Mill Valley, CA 94941
(415) 379-0749
www.rationalim.com
UPDATED: 03/26/2025
Item 2: Educational Background and Business Experience
Name:
Daniel Soulis Sinton
Born: 1973
Education Background and Professional Designations:
Education:
BA International Affairs, University of Colorado – 1995
MBA Business Administration, Georgetown University – 2006
Chartered Financial Analyst (CFA)
Business Background:
03/2012 – Present
Manager
Rational Investment Management, LLC, a Bay Area,
CA-based investment adviser
09/2011 – 02/2012
Planning and preparation for Rational Investment
Management
11/2006 – 08/2011
Senior Research Analyst
Fisher Investments, a San Mateo, CA-based
investment adviser
Item 3: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business.
Item 4: Other Business Activities
Daniel Soulis Sinton is not engaged in any investment-related business or occupation (other than
this advisory firm).
Item 5: Additional Compensation
Form ADV 2B Version: 03/26/2025
1
Other than salary and a profits interest (as a member), Daniel Soulis Sinton does not receive any
economic benefit from any person, company, or organization, in exchange for providing clients
advisory services through Rational Investment Management, LLC (“RIM”).
Item 6: Supervision
Daniel Soulis Sinton, RIM’s manager, whose telephone number is 415-379-0749, supervises
RIM’s supervised persons by monitoring their compliance with RIM’s policies and procedures
manual, including its Code of Ethics. Daniel Soulis Sinton monitors the securities transactions
that each supervised person enters into on behalf of clients generally using the review process
described in Item 13 of RIM’s Brochure.
Item 7: Requirements For State Registered Advisers
This disclosure is required by California securities authorities and is provided for your use in
evaluating this investment advisor representative’s suitability.
A. Daniel Soulis Sinton has NOT been involved in any of the events listed below.
1. An award or otherwise being found liable in an arbitration claim alleging damages in
excess of $2,500, involving any of the following:
a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
2. An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
B. Daniel Soulis Sinton has NOT been the subject of a bankruptcy petition at any time.
Form ADV 2B Version: 03/26/2025
2
Additional Brochure: ADV FORM 2B FOR BRIAN PROSES (2025-03-27)
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This brochure supplement provides information about Brian C. Proses that supplements the
Rational Investment Management, LLC brochure. You should have received a copy of that
brochure. Please contact Daniel Soulis Sinton, Manager, if you did not receive Rational
Investment Management, LLC’s brochure or if you have any questions about the contents of
this supplement.
Additional information about Brian C. Proses is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Rational Investment Management, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Brian C. Proses
Personal CRD Number: 6388165
Investment Adviser Representative
Rational Investment Management, LLC
660 Amaranth Blvd
Mill Valley, CA 94941
(415) 379-0749
www.rationalim.com
UPDATED: 03/26/2025
Item 2: Educational Background and Business Experience
Name:
Brian C. Proses
Born: 1976
Education Background and Professional Designations:
Education:
BS Accounting, University of San Francisco – 1998
MS Taxation, Golden Gate University – 2001
MS Financial Planning, Golden Gate University – 2009
Certified Public Accountant (CPA)
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Business Background:
08/2014 – Present
Manager
Rational Investment Management, LLC, a Bay Area,
CA-based investment adviser
10/2002– Present
Certified Public Accountant
Charles W. Proses, a San-Francisco, CA-based
accountancy corporation
Item 3: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business.
Item 4: Other Business Activities
The principal business of Brian C. Proses is the practice of accountancy as a certified public
accountant with Proses Accountancy Corp, an accountancy corporation (“PAC”). This other
business activity provides a substantial source of his income and involves a substantial amount
of his time. This activity may present a conflict of interest by limiting the amount of time that he
has available for his duties on behalf of Rational Investment Management, LLC (“RIM”). RIM
does not believe this conflict of interest is material, however, given the nature of Brian C. Proses’
Form ADV 2B Version: 03/26/2025
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activities on RIM’s behalf. RIM addresses any conflict of interest through periodic reviews by
RIM’s other manager, Daniel Soulis Sinton.
Certain clients of RIM may also be, but are under no obligation to be, clients of PAC. Those
clients have separate agreements with PAC, and pay separate fees to PAC for accounting
services. RIM does not provide accounting services and is not licensed by the California Board
of Accountancy.
Item 5: Additional Compensation
Other than salary and a profits interest (as a member), Brian C. Proses does not receive any
economic benefit from any person, company, or organization, in exchange for providing clients
advisory services through RIM.
Item 6: Supervision
Daniel Soulis Sinton, RIM’s manager, whose telephone number is 415-379-0749, supervises
RIM’s supervised persons by monitoring their compliance with RIM’s Statement of Policies and
Procedures, including its Code of Ethics. Daniel Soulis Sinton monitors the securities transactions
that each supervised person enters into on behalf of clients generally using the review process
described in Item 13 of RIM’s Brochure.
Item 7: Requirements For State Registered Advisers
This disclosure is required by California securities authorities and is provided for your use in
evaluating this investment advisor representative’s suitability.
A. Brian C. Proses has NOT been involved in any of the events listed below.
1. An award or otherwise being found liable in an arbitration claim alleging damages in
excess of $2,500, involving any of the following:
a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
2. An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
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a) an investment or an investment-related business or activity;
b) fraud, false statement(s), or omissions;
c) theft, embezzlement, or other wrongful taking of property;
d) bribery, forgery, counterfeiting, or extortion; or
e) dishonest, unfair, or unethical practices.
B. Brian C. Proses has NOT been the subject of a bankruptcy petition at any time.
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