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Firm Brochure (Form ADV, Part 2A)
rebel Financial LLC
5940 Clyde Moore Dr, Suite C
Groveport, OH 43125
Phone: (614) 441-9605
Fax: (614) 441-4150
Website: https://rebelfinancial.com
Item 1: Cover Page
This brochure provides information about the qualification and business practices of rebel
Financial LLC. If you have any questions about the contents of this brochure, please contact us
at (614) 441-9605, or by email at support@rebelfinancial.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 rebel Financial LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
March 15, 2025
Item 2: Material Changes
Annual Update
rebel Financial LLC is providing this information as part of our annual updating amendment
which will contain material changes from our last annual update.
Material Changes since the Last Update
The Securities and Exchange Commission adopted amendments to Part 2 of Form ADV effective
October 2010. The newly revised Part 2 consists of Part 2A (the “Brochure”) and Part 2B (the
“Brochure Supplement”). Each update of the Brochure must now include a summary of all
material changes since the last annual update dated March 15, 2024. These changes are noted
below:
• There were no material changes since the last annual amendment.
This brochure dated March 15, 2025 replaces the previously published brochure dated March
15, 2024.
Full Brochure Availability
The Firm Brochure for rebel Financial LLC is available on our website: https://rebelfinancial.com
or by contacting W. Phil Ratcliff at (614) 441-9605 or by e-mail at support@rebelfinancial.com.
In 2025, all new clients are being provided a full copy of our brochure.
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Item 3: Table of Contents
Table of Contents
Item 1: Cover Page ................................................................................................................ 1
Item 2: Material Changes....................................................................................................... 2
Annual Update ...............................................................................................................................2
Material Changes since the Last Update ..........................................................................................2
Full Brochure Availability ................................................................................................................2
Item 3: Table of Contents ....................................................................................................... 3
Item 4: Advisory Business ...................................................................................................... 6
Firm Description ............................................................................................................................6
Principal Owners ............................................................................................................................6
Types of Advisory Services .............................................................................................................6
Tailored Relationships ....................................................................................................................7
Wrap Fee Programs ........................................................................................................................7
Client Assets ..................................................................................................................................7
Item 5: Fees and Compensation ............................................................................................. 7
Description ....................................................................................................................................7
Fee Billing ......................................................................................................................................7
Other Fees ................................................................................................................................... 10
Fees Paid in Advance .................................................................................................................... 10
Additional Compensation ............................................................................................................. 11
Item 6: Performance-Based Fees & Side- by-Side Management ............................................ 11
Sharing of Capital Gains or Capital Appreciation............................................................................ 11
Item 7: Types of Clients ........................................................................................................ 11
Description .................................................................................................................................. 11
Account Minimums ...................................................................................................................... 11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................... 12
Methods of Analysis ..................................................................................................................... 12
Investment Strategies .................................................................................................................. 12
Risk of Loss .................................................................................................................................. 12
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Item 9: Disciplinary Information ........................................................................................... 14
Legal and Disciplinary ................................................................................................................... 14
Criminal or Civil Action ................................................................................................................. 15
Administrative Proceeding ........................................................................................................... 15
Self-Regulatory Proceeding ........................................................................................................... 15
Item 10: Other Financial Industry Activities and Affiliations .................................................. 15
Broker-dealer or Registered Representative .................................................................................. 15
Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser or
Associated Person ........................................................................................................................ 15
Material Relationships or Arrangements with Financial Industry ................................................... 15
Recommend or Select Other Investment Advisers ......................................................................... 15
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 16
Code of Ethics .............................................................................................................................. 16
Recommend Securities with Material Financial Interest ................................................................ 16
Invest in Same Securities Recommended to Clients ....................................................................... 16
Personal Trading Policies .............................................................................................................. 16
Item 12: Brokerage Practices ............................................................................................... 17
Selecting Brokerage Firms ............................................................................................................ 17
Research and Soft Dollars ............................................................................................................. 17
Brokerage for Client Referrals ....................................................................................................... 17
Directed Brokerage ...................................................................................................................... 17
Order Aggregation ....................................................................................................................... 17
Item 13: Review of Accounts ................................................................................................ 18
Periodic Reviews .......................................................................................................................... 18
Review Triggers ............................................................................................................................ 18
Regular Reports ........................................................................................................................... 18
Item 14: Client Referrals and Other Compensation ............................................................... 18
Economic Benefits ........................................................................................................................ 18
Third Party Solicitors .................................................................................................................... 18
Item 15: Custody .................................................................................................................. 19
Account Statements ..................................................................................................................... 19
Item 16: Investment Discretion ............................................................................................ 20
Discretionary Authority for Trading ............................................................................................... 20
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Limited Power of Attorney ............................................................................................................ 20
Item 17: Voting Client Securities ........................................................................................... 20
Proxy Voting ................................................................................................................................ 20
Item 18: Financial Information ............................................................................................. 21
Prepayment of Fees ..................................................................................................................... 21
Financial Condition ...................................................................................................................... 21
Bankruptcy .................................................................................................................................. 21
Item 19: Requirements for State- Registered Advisers........................................................... 21
Identify Principal Executive Officers and Management Person ....................................................... 21
Describe Business Other Than Investment Advice ......................................................................... 21
Describe How Supervised Persons are compensated with performance-based fees ........................ 21
Describe if a Management Person has been subject to a Disciplinary Event .................................... 21
Describe any Relationship with an Issuer of Securities ................................................................... 21
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Item 4: Advisory Business
Firm Description
rebel Financial LLC is an investment advisor registered with the State of Ohio. We specialize in
customized portfolio management for individual investors, high net worth investors,
pension/profit sharing plans and corporations. rebel Financial LLC is a full service financial
advisory firm. We offer fee-based advice, investment management, and insurance solutions
through a comprehensive financial planning process.
Principal Owners
William “Phil” Ratcliff founded rebel Financial on May 31, 2013 and is the sole owner.
Types of Advisory Services
The primary service offered by rebel Financial LLC is Investment Advice. We provide
Comprehensive Financial Planning (Fee for planning), Investment Management, Retirement
Planning, Business Planning, Estate Planning, Goal-Based Planning, and miscellaneous fee based
Financial Consulting Services. We offer investment management services at various levels.
a) On-going advice:
Simple rebel - http://simplerebel.com/
eRebel - http://erebeladvisor.com/
Silver rebel - http://silver.rebelfinancial.com/
i)
ii)
iii)
iv) Gold rebel - http://gold.rebelfinancial.com/
b) Financial tools without in person advice:
rFreemium and rFreemium+ - https://rebelfinancial.com/freemium-rebel-financial/
c) 401k/Pension/NQ Employer Sponsored Plans
d) Tax Preparation
•
rebel Financial offers tax preparation services through in house staff and third party
Certified Public Accountants on a referral basis.
e) Bookkeeping Services
•
rebel Financial offers bookkeeping services for its business clients, for an additional fee,
using Quickbooks Online.
f) Payroll Services
•
rebel Financial offers three levels of payroll services (Lite, Full-Service, & HR Suite) for
its business clients, for an additional fee, using Gusto and BambooHR.
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Tailored Relationships
rebel Financial LLC will work with clients to make customized portfolios and provide advice for
special situations and needs.
Wrap Fee Programs
rebel Financial LLC does not offer wrap fee programs.
Client Assets
As of December 31, 2024, rebel Financial LLC had $303,997,042 of assets under management
that are managed on a discretionary basis and had $9,983.799 of assets under management
that are managed on a non-discretionary basis.
Item 5: Fees and Compensation
Description
As of October 2022, rebel Financial LLC offers management fees based on the client’s net-worth
versus assets under management. Our assets under management fee structure remains in effect
for existing clients. New clients’ fees will be based on their net worth and are calculated as a
percentage of net worth under management per the fee schedules below.
Grandfathered assets under management (AUM) fees are based on the value of assets managed
and fees are calculated as a percentage of assets under management.
We reserve the right to negotiate fees for special situations.
Fee Billing
Fees to rebel Financial are based on the custodian chosen and the service selected.
Simple rebel Investment Advisory Services (Net Worth based)
The Advisory monthly Net Worth Fee is based off the following schedule at a rate of 1/12th the
annual fee shown in the schedule for each tier of net worth value. The minimum monthly fee is
$75.00.
Net Worth Management:
Net Worth Value
Preferred Custodian Fee
First $0 - $500,000
Next $500,001 - $1,000,000
Over $1,000,000
0.725%
0.35%
Converted to eRebel or higher
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Simple rebel Investment Advisory Services (AUM-based)
Assets Under Management (AUM) fee schedules for this investment service is not available to
new clients of rebel Financial. Some older clients are "Grandfathered" into their old AUM fee
schedule as noted in their investment management contract(s).
eRebel Investment Advisory Services (Net Worth based)
The Advisory monthly Net Worth Fee is based off the following schedule at a rate of 1/12th the
annual fee shown in the schedule for each tier of net worth value. The minimum monthly fee is
$150.00.
Net Worth Fee:
Net Worth Value
Preferred Custodian Fee
First $0 - $500,000
Next $500,001 - $1,000,000
Next $1,000,001 - $2,000,000
Over $2,000,000
0.80%
0.40%
0.275%
Converted to Silver or higher
eRebel Investment Advisory Services (AUM based)
Assets Under Management (AUM) fee schedules for this investment service is not available to
new clients of rebel Financial. Some older clients are "Grandfathered" into their old AUM fee
schedule as noted in their investment management contract.
Silver rebel Investment Advisory Services (Net Worth based)
The Advisory monthly Net Worth Fee is based off the following schedule at a rate of 1/12th the
annual fee shown in the schedule for each tier of net worth value. The minimum monthly fee is
$208.00.
Net Worth Fee:
Net Worth Value
Preferred Custodian Fee
First $0 - $500,000
Next $500,001 - $1,000,000
Next $1,000,001 - $2,000,000
Next $2,000,001 - $3,000,000
Next $3,000,001 - $4,000,000
Next $4,000,000+
1.00%
0.50%
0.35%
0.275%
0.25%
0.165%
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Silver rebel Investment Advisory Services (AUM based)
Assets Under Management (AUM) fee schedules for this investment service is not available to
new clients of rebel Financial. Some older clients are "Grandfathered" into their old AUM fee
schedule as noted in their investment management contract(s).
Gold rebel Investment Advisory Services (Net Worth based)
The Advisory monthly Net Worth Fee is based off the following schedule at a rate of 1/12th the
annual fee shown in the schedule for each tier of net worth value. The minimum monthly fee is
$292.00.
Net Worth Fee:
Net Worth Value
Preferred Custodian Fee
First $0 - $500,000
Next $500,001 - $1,000,000
Next $1,000,001 - $2,000,000
Next $2,000,001 - $3,000,000
Next $3,000,001 - $4,000,000
Next $4,000,000+
1.10%
0.60%
0.45%
0.35%
0.30%
0.225%
Gold rebel Investment Advisory Services (AUM based)
Assets Under Management (AUM) fee schedules for this investment service is not available to
new clients of rebel Financial. Some older clients are "Grandfathered" into their old AUM fee
schedule as noted in their investment management contract(s).
rFreemium+ Fee Schedule (AUM based)
The Advisory monthly AUM Fee is based off the following schedule at a rate of 1/12th the
annual fee shown in the schedule for each tier of net worth value. The minimum monthly fee is
$0.00.
AUM Value
Preferred Custodian Fee
1.000%
0.500%
0.350%
0.250%
First $0 - $99,999.99
Next $100,000 - $999,999.99
Over $1,000,000
Additional fee for rFjord
noncompliance+
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Retirement Plan Investment Management Services
The monthly Assets Under Management (AUM) Fee is based off the following schedule at a rate
of 1/12th the annual fee shown in the schedule.
Amount Under Management:
rebel Financial 401k & Pension Fee Schedule
$0.00-$999,999.99
$1,000,000.00-$1,999,999.99
$2,000,000.00-$9,999,999.99
$10,000,000.00 +
Bronze
0.25%
0.20%
0.10%
0.05%
Silver
0.40%
0.30%
0.15%
0.10%
Gold
0.50%
0.40%
0.20%
0.15%
Pontera Services
We use Pontera to facilitate management of client assets that are held away from our
custodians. The platform allows us to avoid being considered to have custody of client funds
since we do not have direct access to client log in credentials. We are not affiliated with the
platform in any way and receive no compensation for using the Pontera platform. Pontera is
used for discretionary management, where rebel Financial LLC, when deemed necessary, will
rebalance the account(s) considering the client’s investment goals, risk tolerance, and current
economic and market trends. There is an additional 0.25% fee when clients choose to utilize the
Pontera services.
Other Fees
Our management fees are separate from charges assessed by third parties such as broker
dealers, custodians and mutual fund companies. Brokerage and other transaction costs charged
by broker dealers executing transactions and custodians maintaining your assets are in addition
to the management fees and are not negotiable. Mutual funds, variable annuities and or other
platforms charge may asses other fees and expenses such as 12B-1 fees or commissions in
connection with the placement of your funds.
Fees Paid in Advance
Our Net Worth and Asset Under Management (AUM) fees are charged monthly (1/12 of annual
fee) in advance based upon the month end value of your account. In addition, some advisory
programs also charge a fixed rate monthly fee depending on level of Assets Under Management
(AUM). Fees may be deducted from your investment account(s) or clients may be invoiced for
services. Depending on the type and level of services will dictate the ability for invoices and is
selected in the fee addendum of the client agreement.
This Agreement may be terminated by either party at any time upon written notice. In the event
of such termination, Client shall not be entitled to a prorata refund and shall receive
continuation of service, rFPW access, document storage, and assistance with account transfer
service until the end of the current month.
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Monthly Fixed fees for the Simple rebel, eRebel, Silver rebel and Gold rebel are not refund once
charged as stated in the Investment Management Agreement. Your death will not terminate the
Investment Management Agreement or authority granted to rebel Financial LLC until we have
received actual written notification of termination of our service(s) by your estate
representative and/or all accounts managed by rF are closed and/or transferred whichever
occurs later.
Additional Compensation
Neither rebel Financial LLC nor its supervised persons accept any compensation for the sale of
securities or other investment products, including asset-based sales charges or service fees from
the sale of mutual funds.
Item 6: Performance-Based Fees & Side- by-
Side Management
Sharing of Capital Gains or Capital Appreciation
We do not currently have any performance based fee accounts – performance fees are fees
based on a share of the capital gains or appreciation of the assets of the client.
Item 7: Types of Clients
Description
We specialize in customized portfolio management and providing investment advice for
individual investors, high net worth investors, pension/profit sharing plans and corporations.
Account Minimums
There are no account minimums.
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Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Methods of Analysis
rebel Financial will employ both technical and fundamental analysis to our research and investment
management; focusing primarily on fundamental analysis and utilization of modern portfolio theory
(MPT).
Investment Strategies
Investing in securities involves the risk of loss that clients should be prepared to bear. Understanding
the type of risk(s) exposure involved in securities and investment advisory services, as well as one’s
own tolerance for risk is a key component of the investment decision making process.
Depending on a client’s particular situation, needs and expectations, there are various methods of
analysis and investment strategies that Financial Professionals may use when developing a financial
plan, formulating investment advice, or managing assets. The principal source of information used by
rebel Financial to prepare financial plans is the information provided by clients, including personal data,
assets and liabilities, income expectations, assumed rate of inflation and return on assets, long term
and short term financial goals, risk tolerance and other relevant data. The staff may use services and
subscriptions to review current federal laws on income, estate and gift taxes, regulations and rulings, in
addition to financial planning publications and other research material such as the Wall Street Journal
and federal websites such as the IRS. We may also use training and marketing materials, prospectuses
and annual reports for the securities, investment and insurance products distributed by rebel Financial
or its affiliates in developing product recommendations.
rebel Financial also has access to investment research compiled by Morningstar’s in house research
team. Morningstar provides rebel Financial with access to investment research and advice, market and
economic commentary, performance reporting and recommendations, and portfolio management tools
and services, that cover topics including mutual funds, separate accounts, REITs, ETFs, fixed income,
and certain alternative investments.
Risk of Loss
The primary risk involved in financial planning services stems from the possibility that the financial
information and assumptions (such as assumptions regarding future market behavior) used in
connection with developing the financial plan are or will prove to be inaccurate, which could result in
the implementation of the plan in a manner so that the client’s investment goals and financial needs
will not be met. Furthermore, even if the financial plan is itself appropriate, the plan may not be
implemented appropriately.
As discussed, investing in securities involves the risk of loss that clients should be prepared to bear. The
types of risk vary depending on the type of securities and investment advisory programs in which a
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client may participate. The following is a list of key risks that one may be exposed to depending on their
particular investments, with definitions as provided by the Financial Industry Regulatory Authority, Inc.
(FINRA).
Market Risk – Due to the volatile nature of a market-based system, securities cannot guarantee the
safety of principal invested or a certain rate of return. Past performance is no guarantee of future
results.
Capitalization Risk - Equities, i.e., stocks, and equity-based funds may also involve an issuing company
“capitalization risk” as the common shares of small or mid-capitalized companies are generally more
vulnerable to adverse business or economic conditions than larger companies having more available
resources.
Interest-rate risk describes the risk that the value of a security will go down because of changes in
interest rates. For example, when interest rates overall increase, bond issuers must offer higher coupon
rates on new bonds in order to attract investors. The consequence is that the prices of existing bonds
drop because investors prefer the newer bonds paying the higher rate. On the other hand, there's also
interest-rate risk when rates fall because maturing bonds or bonds that are paid off before maturity
must be reinvested at a lower yield.
Inflation risk describes the risk that increases in the prices of goods and services, and therefore the cost
of living, reduce your purchasing power. Let's say a can of soda increases from $1 to $2. In the past, $2
would have bought two cans of soda, but now $2 can buy only one can, resulting in a decline in the
value of your money.
Inflation risk and interest rate risk are closely tied, as interest rates generally rise with inflation.
Because of this, inflation risk can also reduce the value of your investments. For example, to keep pace
with inflation and compensate for the loss of purchasing power, lenders will demand increased interest
rates. This can lead to existing bonds losing value because, as mentioned above, newly issued bonds
will offer higher interest rates. Inflation can go in cycles, however. When interest rates are low, new
bonds will likely offer lower interest rates.
Currency risk occurs because many world currencies float against each other. If money needs to be
converted to a different currency to make an investment, any change in the exchange rate between
that currency and yours can increase or reduce your investment return. You are usually only impacted
by currency risk if you invest in international securities or funds that invest in international securities.
For example, assume that the current exchange rate of the U.S. dollar to British pound is $1 = 0.53
British pounds. If you invest $1,000 in a mutual fund that invests in the stock of British companies, this
will equal 530 pounds ($1,000 x 0.53 pounds = 530 pounds). Six months later, assume the dollar
strengthens and the exchange rate becomes $1=0.65 pounds. If the value of the fund does not change,
converting the original investment of 530 pounds into dollars will return only $815 (530 pounds/0.65
pounds = $815). Consequently, while the value of the mutual fund has not changed in the local
currency, a change in the exchange rate has devalued the original investment of $1,000 into
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$815. On the other hand, if the dollar were to weaken, the value of the investment would go up. So if
the exchange rate changes to $1 = 0.43 pounds, the original investment of $1,000 would increase to
$1,233 (530 pounds/0.43 pounds = $1,233).
As with most risks, currency risk can be managed to a certain extent by allocating only a limited portion
of your portfolio to international investments and diversifying this portion across various countries and
regions.
Liquidity risk is the risk that you might not be able to buy or sell investments quickly for a price that is
close to the true underlying value of the asset. Sometimes you may not be able to sell the investment
at all if there are no buyers for it. Liquidity risk is usually higher in over-the-counter markets and small-
capitalization stocks. Foreign investments can pose liquidity risks as well. The size of foreign markets,
the number of companies listed, and hours of trading may limit your ability to buy or sell a foreign
investment.
Sociopolitical risk is the possibility that instability or unrest in one or more regions of the world will
affect investment markets. Terrorist attacks, war, and pandemics are just examples of events, whether
actual or anticipated, that impact investor attitudes toward the market in general and result in system-
wide fluctuations in stock prices. Some events, such as the September 11, 2001, attacks on the World
Trade Center and the Pentagon, can lead to wide-scale disruptions of financial markets, further
exposing investments to risks. Similarly, if you are investing overseas, problems there may undermine
those markets, or a new government in a particular country may restrict investment by non-citizens or
nationalize businesses.
Management risk, also known as company risk, refers to the impact that bad management decisions,
other internal missteps, or even external situations can have on a company's performance and, as a
consequence, on the value of investments in that company. Even if you research a company carefully
before investing and it appears to have solid management, there is probably no way to know that a
competitor is about to bring a superior product to market. Nor is it easy to anticipate a financial or
personal scandal that undermines a company's image, its stock price, or the rating of its bonds.
Credit risk, also called default risk, is the possibility that a bond issuer won't pay interest as scheduled
or repay the principal at maturity. Credit risk may also be a problem with insurance companies that sell
annuity contracts, where your ability to collect the interest and income you expect is dependent on the
claims-paying ability of the issuing insurance company.
Item 9: Disciplinary Information
Legal and Disciplinary
Registered Investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of rebel Financial LLC and the integrity of
our management of your assets. We have no information that applies to this item.
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Criminal or Civil Action
Registered Investment advisors are required to disclose all material facts regarding any criminal or civil
actions that would be material to your evaluation of rebel Financial LLC and the integrity of our
management of your assets. We have no information that applies to this item.
Administrative Proceeding
Registered Investment advisors are required to disclose all material facts regarding any administrative
proceeding that would be material to your evaluation of rebel Financial LLC and the integrity of our
management of your assets. We have no information that applies to this item.
Self-Regulatory Proceeding
Registered Investment advisors are required to disclose all material facts regarding any self- regulatory
proceedings that would be material to your evaluation of rebel Financial LCC and the integrity of our
management of your assets. We have no information that applies to this item.
Item 10: Other Financial Industry Activities and
Affiliations
Broker-dealer or Registered Representative
rebel Financial LLC and our staff are not affiliated with a broker dealer or are registered representatives
of a broker dealer.
Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser or
Associated Person
rebel Financial LLC and our staff are not affiliated with a Futures Commission Merchant, Commodity
Pool Operator, or Commodity Trading Adviser.
Material Relationships or Arrangements with Financial Industry
rebel Financial LLC also offers tax preparation and accounting services to clients as a stand-alone
service. rebel Financial LLC always acts in the best interest of the client and clients always have the right
to decide whether or not to utilize the services of any rebel Financial LLC representative in such
individuals outside capacities.
Recommend or Select Other Investment Advisers
rebel Financial LLC may recommend or select other investment advisors for our clients. This may occur
to meet the objectives of specific clients to provide additional investment services of an advisor that
has expertise that is not available at rebel. When this occurs, clients may need to sign paperwork for
the investment advisor that serves as a subadvisor for rebel Financial.
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Item 11: Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading
Code of Ethics
rebel Financial LLC has adopted a Code of Ethics. Our Officers and staff members are required to
provide us with a written acknowledgement regarding the Code of Ethics. The Code of Ethics covers the
following areas:
1. Definition of Terms
2. Standard of Conduct & Statement of General Fiduciary Principles
3. Protecting Inside Information
4. Restrictions on Personal Investing
5. Reporting Personal Securities Transactions and Accounts
6. Monitoring Personal Securities Transactions
7. Administration of the Code of Ethics and Violations
8. Acknowledgement of Code of Ethics
rebel Financial will provide a copy of the Code of Ethics to clients and prospective clients upon request.
To obtain a copy contact Phil Ratcliff at (614) 441- 9605 or by e-mail at support@rebelfinancial.com.
Recommend Securities with Material Financial Interest
rebel Financial LLC and its investment advisor representatives do not have any material financial
interest in any public companies.
Invest in Same Securities Recommended to Clients
All related persons and affiliates of rebel Financial may not purchase or sell securities ahead of our
clients. Unless there is a meaningful and favorable change in the price of a security, or an extenuating
circumstance, our portfolio managers will not make any further purchases or sales that day after a
related person or affiliate. This policy is a minimum for securities with limited marketability. For
securities with limited marketability, related persons and affiliates may not purchase or sell until the
portfolio manager agrees that he or she has substantially completed the purchase/or sale for clients.
The purchase or sale program may extend over a number of days. This requirement does not apply to
mutual fund purchases or sales except for mutual funds. As a general rule, in a situation where an
investment conflict of interest occurs between a client and one of our associates, the conflict of interest
will be resolved in the best interests of the client.
Personal Trading Policies
rebel Financial has a formal a Personal Securities Trading Policy. As part of this policy we require that
our employees and affiliated persons submit all personal trading requests to the firm portfolio
managers for approval prior to placing our personal transactions. Employees submit their personal
securities transaction report quarterly to the compliance officer.
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Item 12: Brokerage Practices
Selecting Brokerage Firms
You are free to select any broker dealer for your brokerage account. While you may select your broker
dealer, rebel Financial suggests that our clients use TD Ameritrade Institutional (A division of TD
Ameritrade Inc. Member FINRA/SIPC/NFA), Charles Schwab & Co., Inc (“Schwab), or Interactive Brokers
for personal (non-qualified and individual retirement) accounts, TIAA CREF or Fidelity for university
retirement accounts as your broker dealer and custodian for execution of transactions. You will be
provided the commission schedules for these broker dealers at the time accounts are established so
you can make a decision based on your needs and review of transaction costs and other fees charged.
rebel Financial has direct on-line server access to accounts maintained at these broker dealers, as well
as straight through order entry. rebel Financial is not affiliated with the above listed broker dealers and
receives no economic benefit for recommending client establish accounts with these firms.
In some cases where clients chose a specific broker dealer other than those mentioned above, this
could cost you the client more money. You the client may pay higher brokerage commissions or
transactions costs charged by that broker dealer.
Research and Soft Dollars
rebel Financial may receive non-cash compensation from investment companies, custodians, and third
party vendors. Such compensation may include such items as gifts of nominal value, an occasional
dinner or ticket to a sporting event, or reimbursement in connection with educational meetings or
marketing or advertising initiatives. Such sponsors may also pay for education or training events that
may be attended by rebel Financials’ employees.
Brokerage for Client Referrals
rebel Financial LLC does not engage in the practice of directing brokerage trades to outside broker
dealers for client referrals.
Directed Brokerage
In almost every case, we direct trades based on each client’s direction. Typically, our trades are placed
directly with the client’s custodian. On occasion a trade may be done with one broker dealer and
settled with the client’s account at another broker dealer as part of a COD transaction. This is always
done per the client’s instruction.
Order Aggregation
Most transactions for each client account are entered on a transaction-by-transaction basis. If we
decide to purchase or sell the same securities for several clients at approximately the same time, we
might combine (otherwise known as aggregating or batching transactions) for these orders. The broker
dealer conducting the trade does this through the use of an average price account. By aggregating
orders of the same securities, the broker dealer may be able to obtain a better overall execution price.
In addition, you may receive lower transaction costs that might or might not have been obtained had
17
multiple orders been placed independently. When aggregating trades in the average price account the
brokerage firm generally averages the price and charges one commission per client per security. We
receive no additional compensation, fees or remuneration from the aggregation of client trades in an
average price account.
Item 13: Review of Accounts
Periodic Reviews
The portfolio manager reviews each portfolio at least quarterly.
Review Triggers
When securities held by clients are to be sold, accounts are reviewed immediately; either prior to or
after the security is sold. When any security is bought for clients, accounts are reviewed immediately;
either prior to or just after the security is purchased. One of the firm's portfolio managers reviews each
portfolio at least quarterly.
Regular Reports
The broker dealer handling your account or custodian sends client account statements at least
quarterly, and in some circumstances monthly. In some cases, account statement may be provided to
you electronically by the custodian. These account statements show money balances, securities held in
the account, investment values and transactions made. rebel Financial may also send out monthly
reports that include other information such as performance of your investments.
Item 14: Client Referrals and Other
Compensation
Economic Benefits
For the benefit we receive from other broker dealers see the “Brokerage Practices” section above.
Third Party Solicitors
rebel Financial LLC has retained Paladin Advisors/Wiseradvisor and Ramsey Solutions as third parties to
act as solicitors/promoters for rebel Financial LLC’s investment management services. Compensation
with respect to the foregoing will be fully disclosed to each client referred by Paladin
Advisors/Wiseradvisor and/or Ramsey Solutions . All such referral activities will be conducted in
accordance with the Advisers Act, where applicable. rebel Financial LLC also has a bonus system for
advisors and employees who help generate new business.
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Item 15: Custody
Account Statements
We do not take custody of your funds and securities. Because of this, rebel Financial LLC does not
accept securities or forward securities to your brokerage firm or custodian. The only checks payable to
rebel Financial LCC that we are permitted to accept are those payable for Advisory fees. You will not
give us authority to withdraw securities or funds (other than for payment of advisory fees) from your
account. rebel Financial LLC is deemed to have custody due to its ability to deduct management fees in
accordance with the advisory agreement but does not otherwise have any access to client assets.
In February 2017, the SEC issued a no-action letter clarifying that standing authority (also known as a
standing letter of authorization or “SLOA”) to move money from a client’s account to a third party
account is “custody” within the meaning of Investment Advisers Act Rule 206(4) -4 (the “Custody
Rule”). The SEC also stated that any accounts that meet the following seven conditions (the SEC refers
to them as “representations”) will not be subject to the “independent verification” requirement under
Rule 206(4)-2(a)(4), also known as the annual surprise accountant’s examination. As such, our firm
has adopted the following seven safeguards in conjunction with our custodians:
1.
2.
3.
4.
5.
6.
7.
The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified
custodian’s form or separately, to direct transfers to the third party either on a specified
schedule or from time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such
as a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of
the third party, the address, or any other information about the third party contained in
the client’s instruction.
The investment adviser maintains records showing that the third party is not a related
party of the investment adviser or located at the same address as the investment
adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming
the instruction and an annual notice reconfirming the instruction
The broker dealer or custodian handling your account sends to you account statements at least
quarterly, but usually monthly. These Account statements show money balances, securities held in the
account, investment values and transactions made. We encourage you to read your statements.
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Item 16: Investment Discretion
Discretionary Authority for Trading
Most clients give rebel Financial LLC discretion over the selection, amount and timing of securities to be
bought and sold. This means that the portfolio manager or advisor representative may purchase or sell
securities consistent with your investment objectives without contacting you prior to entering the
transaction.
Limited Power of Attorney
Investment authority may be subject to specific investment objectives and guidelines and/or conditions
imposed by you. For example, you may specify that the investment in any particular stock or industry
should not exceed specified percentages of the value of your portfolio or you may have restriction or
prohibitions on transactions in the securities of a specific company or industry such as tobacco stocks.
Please detail any such specifications or exceptions in writing prior to engaging our services.
Item 17: Voting Client Securities
Proxy Voting
rebel Financial LLC will accept voting authority for client securities in certain cases. When rebel
Financial does accept voting authority for client securities, it will always seek to vote in the best
interests of its clients. Clients may direct us on how to vote client securities by communicating their
wishes in writing or electronically to rebel Financial. When voting client proxies the firm will always
hold the interests of the clients above its own interests. Clients of rebel Financial may obtain the voting
record of how we voted on client securities by contacting the firm at phone number or e-mail address
listed on the cover page of this brochure. Clients may obtain a copy of the rebel Financial proxy voting
policies and procedures upon request.
Where rebel Financial does not have voting authority, clients will receive proxies and proxy information
or other solicitations about your securities from the account custodian. If you have questions about a
particular solicitation, you can contact your representative for advice. You are not obligated to follow
your representative’s advice on voting your securities.
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Item 18: Financial Information
Prepayment of Fees
Fees for your investment advisor services are charged monthly in advance based upon the net worth or
value of assets managed as determined by the client's custodian or other pricing services at the end of
each calendar month. We do not require more than one month of pre-paid fees.
Financial Condition
Neither rebel Financial LLC nor its management has any financial condition that is likely to reasonably
impair rebel Financial LLC’s ability to meet contractual commitments to clients.
Bankruptcy
rebel Financial LLC has not been subject to a bankruptcy proceeding.
Item 19: Requirements for State- Registered
Advisers
Identify Principal Executive Officers and Management Person
The Principal Executive Officer is William “Phil” Ratcliff. The primary Management Person is William
“Phil” Ratcliff. See Form ADV Part 2B Supplement.
Describe Business Other Than Investment Advice
rebel Financial LLC also offers tax preparation and accounting services to clients as a stand-alone
service. rebel Financial LLC always acts in the best interest of the client and clients always have the right
to decide whether or not to utilize the services of any rebel Financial LLC representative in such
individuals outside capacities.
Describe How Supervised Persons are compensated with performance-based fees
There is no compensation with performance-based fees.
Describe if a Management Person has been subject to a Disciplinary Event
The rebel Financial LLC Management Persons have not been subject to a disciplinary event.
Describe any Relationship with an Issuer of Securities
rebel Financial LLC has no relationships with issuers of securities.
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