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Disclosure Brochure March 14, 2025
a Registered Investment Adviser
411 Hackensack Avenue, Suite 1005
Hackensack, NJ 07601
(201) 373-2163
www.revolvewealth.com
This brochure provides information about the qualifications and business practices of Revolve Wealth Partners,
LLC (hereinafter “Revolve Wealth Partners” or the “Firm”). If you have any questions about the contents of
this brochure, please contact the Firm at the telephone number listed above. The information in this brochure
has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any
state securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of
skill or training.
Disclosure Brochure
Revolve Wealth Partners, LLC
Item 2. Material Changes
The material changes in this brochure from the last annual updating amendment of Revolve Wealth
Partners, LLC on March 18, 2024 are described below. Material changes relate to Revolve Wealth Partners’
policies, practices or conflicts of interests.
• Revolve Wealth Partners, LLC has updated its Assets under Management. (Item 4)
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Item 3. Table of Contents
Item 2. Material Changes........................................................................................................................................................ 2
Item 3. Table of Contents ....................................................................................................................................................... 3
Item 4. Advisory Business ...................................................................................................................................................... 4
Item 5. Fees and Compensation .............................................................................................................................................. 8
Item 6. Performance-Based Fees and Side-by-Side Management ............................................................................................11
Item 7. Types of Clients ........................................................................................................................................................11
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .....................................................................................12
Item 9. Disciplinary Information ............................................................................................................................................14
Item 10. Other Financial Industry Activities and Affiliations ..................................................................................................14
Item 11. Code of Ethics .........................................................................................................................................................15
Item 12. Brokerage Practices .................................................................................................................................................16
Item 13. Review of Accounts .................................................................................................................................................19
Item 14. Client Referrals and Other Compensation .................................................................................................................20
Item 15. Custody ...................................................................................................................................................................20
Item 16. Investment Discretion ..............................................................................................................................................21
Item 17. Voting Client Securities ...........................................................................................................................................21
Item 18. Financial Information ..............................................................................................................................................21
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Item 4. Advisory Business
Revolve Wealth Partners offers a variety of advisory services, which include financial planning, consulting,
and investment management services. Prior to Revolve Wealth Partners rendering any of the foregoing
advisory services, clients are required to enter into one or more written agreements with Revolve Wealth
Partners setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”).
Revolve Wealth Partners has been registered as an investment adviser since April 2017 and is wholly owned
by Daniel L. Katz and Michael S. Israel. As of December 2024, Revolve Wealth Partners had
$ 1,180,023,798 of assets under management, $ 1,180,023,798 of which was managed on a discretionary
basis and $ 0.00 of which was managed on a non-discretionary basis.
As of December 2024, Revolve Wealth Partners had $22,023,024 assets under advisement.
While this brochure generally describes the business of Revolve Wealth Partners, certain sections also
discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), employees or any other person
who provides investment advice on Revolve Wealth Partners’ behalf and is subject to the Firm’s supervision
or control.
Financial Planning and Consulting Services
Revolve Wealth Partners offers clients a broad range of financial planning and consulting services, which
may include any or all of the following functions:
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Business Planning
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Retirement Planning
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Cash Flow Forecasting
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Risk Management
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Trust and Estate Planning
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Charitable Giving
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Financial Reporting
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Distribution Planning
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Investment Consulting
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Tax Planning
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Insurance Planning
• Manager Due Diligence
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While each of these services is available on a stand-alone basis, certain of them may also be rendered in
conjunction with investment portfolio management as part of a comprehensive wealth management
engagement (described in more detail below).
In performing these services, Revolve Wealth Partners is not required to verify any information received
from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly
authorized to rely on such information. Revolve Wealth Partners may recommend clients engage the Firm
for additional related services, its Supervised Persons in their individual capacities as insurance agents
and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest
exists for the Firm to recommend that clients engage Revolve Wealth Partners or its affiliates to provide (or
continue to provide) additional services for compensation, including investment management services.
Clients retain absolute discretion over all decisions regarding implementation and are under no obligation
to act upon any of the recommendations made by Revolve Wealth Partners under a financial planning or
consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm
of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising Revolve Wealth Partners’ recommendations and/or services.
Investment and Wealth Management Services
Revolve Wealth Partners manages client investment portfolios on a discretionary or non-discretionary basis.
In addition, Revolve Wealth Partners can be engaged to provide clients with wealth management services
which includes a broad range of comprehensive financial planning and consulting services as well as
discretionary and/or non-discretionary management of investment portfolios.
Revolve Wealth Partners primarily allocates client assets among various mutual funds, exchange-traded
funds (“ETFs”), individual debt and equity securities, and independent investment managers (“Independent
Managers”) in accordance with their stated investment objectives. In addition, Revolve Wealth Partners
also recommends that certain eligible clients invest in privately placed securities (including investments in
private funds such as real estate funds, hedge funds, and private equity funds). Securities in these private
placements are typically offered pursuant to Regulation D under the Securities Act of 1933, as amended.
Participation as an investor in these private placements is typically restricted to investors that are both
"qualified clients" as defined in Rule 205-3(d) under the Advisers Act and “accredited investors” as defined
in Rule 501(a) of the Securities Act of 1933, as amended.
Investments in these private placements often involves a significant degree of risk. All relevant information,
terms and conditions relative to the Private Funds, including information relating to suitability, risk factors,
and potential conflicts of interest, are typically set forth in a Confidential Private Offering Memorandum,
Limited Partnership Agreement or limited liability company operating agreement, and/or Subscription
Agreement (collectively, the “Offering Documents”), which each investor is typically required to receive
and/or execute prior to being accepted as an investor. Persons involved with these private placement
investments may be clients of the Firm or have other relationships with the Firm and its principals. As such,
the Firm has an incentive to recommend such investments to its clients. Additionally, in certain
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circumstances, sponsors of such private placement investments may pay for costs incurred by the Firm in
conducting due diligence on such investments and their sponsors. As a result, a conflict of interest exists as
the Firm has an incentive to recommend to its clients those investments where the sponsors bear some or
all such due diligence expenses.
Where appropriate, the Firm may also provide advice about any type of legacy position or other investment
held in client portfolios, but clients should not assume that these assets are being continuously monitored
or otherwise advised on by the Firm unless specifically agreed upon. Clients may engage Revolve Wealth
Partners to manage and/or advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored
retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Revolve Wealth Partners
directs or recommends the allocation of client assets among the various investment options available with
the product. These assets are generally maintained at the underwriting insurance company or the custodian
designated by the product’s provider.
Revolve Wealth Partners tailors its advisory services to meet the needs of its individual clients and seeks to
ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. Revolve Wealth Partners consults with clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify Revolve Wealth Partners if there are
changes in their financial situation or if they wish to place any limitations on the management of their
portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if
Revolve Wealth Partners determines, in its sole discretion, the conditions would not materially impact the
performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
Retirement Plan Consulting Services
Revolve Wealth Partners provides various consulting services to qualified employee benefit plans and their
fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing
and optimizing their corporate retirement plans. Each engagement is individually negotiated and
customized, and may include any or all of the following services:
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Plan Design and Strategy
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Plan Fee and Cost Analysis
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Plan Review and Evaluation
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Plan Committee Consultation
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Executive Planning & Benefits
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Fiduciary and Compliance
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Investment Selection
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Participant Education
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Revolve Wealth
Partners as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written
description of Revolve Wealth Partners’ fiduciary status, the specific services to be rendered and all direct
and indirect compensation the Firm reasonably expects under the engagement.
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Use of Independent Managers
As mentioned above, Revolve Wealth Partners offers certain clients the services of certain Independent
Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which
a client engages an Independent Manager will be set forth in a separate written agreement with the
designated Independent Manager. In addition to this brochure, Revolve Wealth Partners provides clients
with the written disclosure documents of the respective Independent Managers engaged to manage their
assets.
Revolve Wealth Partners evaluates a variety of information about Independent Managers, which may
include the Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the
Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in
relation to its clients’ individual portfolio allocations and risk exposure. Revolve Wealth Partners also takes
into consideration each Independent Manager’s management style, returns, reputation, financial strength,
reporting, pricing and research capabilities, among other factors. The Firm recommends third party
managers when the Firm believes that a specific area of expertise (for example, options trading, individual
bonds or index strategies) is not only appropriate for a client’s account, but such client should have a
substantial enough portion of assets in that niche strategy to merit the use of an independent manager.
Revolve Wealth Partners continues to provide services relative to the discretionary or non-discretionary
selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those
accounts being managed by Independent Managers. Revolve Wealth Partners seeks to ensure the
Independent Managers’ strategies and target allocations remain aligned with its clients’ investment
objectives and overall best interests. The Independent Managers' fees will vary based on strategy and will
be separate from and in addition to the fees charged by the Firm. The Firm will not share in any of those
fees.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions,
we must:
• Meet a professional standard of care when making investment recommendations (give prudent
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advice);
Never put our financial interests ahead of yours when making recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
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Item 5. Fees and Compensation
Revolve Wealth Partners offers services on a fee basis, which includes fixed fees, as well as fees based
upon assets under management. Additionally, certain of the Firm’s Supervised Persons and the Firm’s
Managing Partners, in their individual capacities, offer insurance products and receive commissions on
these products under a separate commission-based arrangement.
Financial Planning and Consulting Fees
Revolve Wealth Partners generally charges a fixed fee for providing financial planning and consulting
services under a stand-alone engagement. These fees are negotiable, but generally range from $500 to
$20,000, depending upon the scope and complexity of the services and the professional rendering the
financial planning and/or the consulting services. If the client engages the Firm for additional investment
advisory services, Revolve Wealth Partners may offset all or a portion of its fees for those services based
upon the amount paid for the financial planning and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Advisory Agreement and Revolve Wealth Partners generally requires one-half of the fee (estimated hourly
or fixed) payable upon execution of the Advisory Agreement. The outstanding balance is generally due
upon delivery of the financial plan or completion of the agreed upon services. The Firm does not, however,
take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services rendered.
Investment Management and Wealth Management Fees
Revolve Wealth Partners offers investment management and wealth management services for an annual fee
based on the amount of assets under the Firm’s management. This management fee varies depending upon
the size and composition of the client’s portfolio as well as the type and amount of services provided. The
fees fall within the following schedule:
PORTFOLIO VALUE
BASE FEE
Up to $1,999,999
$2,000,000 - $9,999,999
$10,000,000 and above
1.25%
1.00%
0.90%
The Firm can impose a minimum fee as described in Item 7, below. With respect to all assets other than
private placement investments and employer retirement plans held at certain custodians, the annual fee is
prorated and charged quarterly, in advance, based upon the market value of the assets being managed by
Revolve Wealth Partners on the last day of the previous billing period. With respect to employer retirement
plans held at certain custodians, the management fee will be deducted monthly or quarterly in advance or
arrears, depending on each custodian. For fees charged in arrears, no adjustment policy is necessary. Fees
charged in advance will be subject to the adjustment policy below.
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With respect to private placement investments, the annual fee is prorated and charged quarterly, in advance,
either based on the value of the assets (as determined by the issuer) being managed by the Firm on the last
day of the previous billing period or at cost. With respect to private placement investments, Revolve Wealth
Partners will also charge an annual administrative and due diligence fee of 0.25% of the assets being
managed by the Firm, which is charged quarterly in advance, either based on the value of the assets (as
determined by the issuer) being managed by the Firm on the last day of the previous billing period or at
cost.
The 0.25% due diligence fee is in consideration of initial and ongoing due diligence which may include
partnering with third party professionals including outside counsel, independent real estate consultants or
market specialists to further evaluate the terms and merits of private placement opportunities as well as
relevant partnership agreements and other accompanying documentation. This includes but is not limited
to an examination of specific markets and sub-markets, asset classes, industry data, pro-forma assumptions,
relevant comps and assumptions for costs.
The Firm may charge a lesser fee of up to 50 basis points (0.50%) for assets not being managed by Revolve
Wealth Partners, but where the Firm provides consulting services, including one-off or periodic advice,
reporting and other administrative services.
If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee
payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial
period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is
terminated, the fee for the final billing period is prorated through the effective date of the termination and
the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), Revolve Wealth Partners may
negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest
exists for the Firm to recommend that clients engage Resolve Wealth Partners for additional services for
compensation, including rolling over retirement accounts or moving other assets to the Firm’s management.
Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation
to act upon any of the recommendations.
Retirement Plan Consulting Fees
Revolve Wealth Partners generally charges as fixed project-based fee to provide clients with retirement
plan consulting services. Each engagement is individually negotiated and tailored to accommodate the
needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the
scope of the services to be rendered. The fee will be an annual asset-based fee between 50 and 75 basis
points (0.50% – 0.75%).
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Fee Discretion
Revolve Wealth Partners may, in its sole discretion, negotiate to charge a lesser fee based upon certain
criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, pre-existing/legacy client relationship,
account retention and pro bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to Revolve Wealth Partners, clients may also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other
financial institutions (collectively “Financial Institutions”). These additional charges may include securities
brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, reporting
charges, fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual
fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s
brokerage practices are described at length in Item 12, below.
Direct Fee Debit
Clients generally provide Revolve Wealth Partners and/or certain Independent Managers with the authority
to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that
act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct
fees, have agreed to send statements to clients not less than quarterly detailing all account transactions,
including any amounts paid to Revolve Wealth Partners. Alternatively, upon request, Revolve Wealth
Partners’ may agree to send a separate invoice to clients for direct payment.
Use of Margin
Revolve Wealth Partners may be authorized to use margin in the management of the client’s investment
portfolio. In these cases the fee payable will be assessed net of margin such that the market value of the
client’s account and corresponding fee payable by the client to Revolve Wealth Partners will not be
increased.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Revolve Wealth
Partners’ right to terminate an account. Additions may be in cash or securities provided that the Firm
reserves the right to liquidate any transferred securities or declines to accept particular securities into a
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client’s account. Clients may withdraw account assets on notice to Revolve Wealth Partners, subject to the
usual and customary securities settlement procedures. However, the Firm generally designs its portfolios
as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment
objectives. Revolve Wealth Partners may consult with its clients about the options and implications of
transferring securities. Clients are advised that when transferred securities are liquidated, they may be
subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g.,
contingent deferred sales charges) and/or tax ramifications.
Commissions and Sales Charges for Recommendations of Securities
Revolve Wealth Partners and a number of the Firm’s Supervised Persons outside business activities (see
Item 10 below) is licensed to accept compensation for the sale of investment products to Revolve clients.
This presents a conflict of interest and gives the supervised person an incentive to recommend products
based on the compensation received rather than on the client’s needs. When recommending the sale of
securities or investment products for which the supervised persons receives compensation, Revolve will
document the conflict of interest in the client file and inform the client of the conflict of interest. Clients
always have the right to decide whether to purchase Revolve -recommended products and, if purchasing,
have the right to purchase those products through other brokers or agents that are not affiliated with
Revolve.
Commissions are not Revolve’s primary source of compensation for advisory services. Advisory fees that
are charged to clients are not reduced to offset the commissions or markups on securities or investment
products recommended to clients.
Item 6. Performance-Based Fees and Side-by-Side Management
Revolve Wealth Partners does not provide any services for a performance-based fee (i.e., a fee based on a
share of capital gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
Revolve Wealth Partners offers services to individuals, pension and profit sharing plans, trusts, estates,
charitable organizations, corporations and business entities.
Minimum Account Requirements
As a condition for starting and maintaining an investment management relationship, Revolve Wealth
Partners can impose a minimum quarterly fee. The minimum fee charge is dependent on the specific
relationship with the client, including the scope of work involved as well as the individual(s) providing the
services. The minimum will be agreed upon by the client. Any minimum fee will cause clients with smaller
portfolios to incur an effective fee rate that is higher than the Firm’s stated fee.
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In addition, certain Independent Managers may, however, impose more restrictive account requirements
and billing practices from the Firm. In these instances, Revolve Wealth Partners may alter its corresponding
account requirements and/or billing practices to accommodate those of the Independent Managers.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Revolve Wealth Partners’ portfolio allocations are derived from leveraging financial planning strategies
and understanding individual client risk and goals. From that analysis, the Firm builds what it believes is
the most efficient portfolio to accomplish those goals. Additionally, Revolve Wealth Partners builds
portfolios using these 5 basic tenants:
Investment Tools
Portfolio creation includes all asset classes, including but not limited to, common stocks, fixed income
instruments, exchange trades funds, mutual funds, separately managed accounts, hedge funds and private
placements. The Firm invests in portfolios consisting of companies that it believes have growth potential,
where earnings grow faster than the market, as well as value potential, which can be bought at a discount
to the companies’ actual value. Revolve Wealth Partners believes that it is the integration of both growth
and value that can lead to success.
Globalized Portfolios
International markets are open to U.S. investors. Some of the companies Revolve Wealth Partners considers
the strongest investment possibilities are domiciled outside the United States. The Firm thinks it is in the
best interest of its clients to take advantage of opportunity all over the world.
Automatic Rebalancing
Regular rebalancing allows clients’ portfolios to stay in line with their original asset allocation. Revolve
Wealth Partners believes that this results in the chosen portfolio remaining consistent with the client’s goals,
regardless of what occurs in the financial markets. The Firm strives to maintain a target allocation with the
belief that return will be increased and risk lowered.
Tax Sensitivity
Working with clients’ tax professionals, Revolve Wealth Partners considers tax ramifications in choosing
different investments. However, taxes do not solely determine the Firm’s bigger-picture goal.
Investment Integrity and Review Process
Revolve Wealth Partners believes that clients want to be invested with the best possible managers in their
specific financial disciplines. As a result, rather than deluging clients with hundreds of money managers to
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consider, the Firm attempts to keep it simple with a select list that it deems suitable for each client. The
Firm conducts its own due diligence on the money managers and their investment portfolios which includes
a stringent and on-going process. If a money manager’s discipline has strayed, lost key employee(s),
performance has faltered, or any other events occur which can affect the management of money, Revolve
Wealth Partners will suggest selecting new money managers.
Client Review Process
Revolve Wealth Partners’ portfolio review processes allow it to monitor and review clients’ goals,
investments and overall financial health on a regular basis. If circumstances change in the financial markets,
a client’s life, or both, the Firm discusses the changes to the portfolio it considers prudent, and then
implements the changes promptly.
Risk of Loss
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of Revolve Wealth Partners’ recommendations and/or
investment decisions may depend to a great extent upon correctly assessing the future course of price
movements of stocks, bonds and other asset classes. There can be no assurance that Revolve Wealth
Partners will be able to predict those price movements accurately or capitalize on any such assumptions.
Diversification does not guarantee a profit or protect against a loss.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual
NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a
mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may,
among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However,
certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There
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is also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Use of Independent Managers
As stated above, Revolve Wealth Partners may select certain Independent Managers to manage a portion
of its clients’ assets. In these situations, Revolve Wealth Partners continues to conduct ongoing due
diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’
ability to successfully implement their investment strategies. In addition, Revolve Wealth Partners
generally may not have the ability to supervise the Independent Managers on a day-to-day basis.
Use of Private Funds
Where appropriate, the Firm recommends that certain clients invest in private placement securities offered
by private funds (e.g., hedge funds, private equity funds, and real estate funds, etc.). Because the private
placement securities are not registered and because these funds are not registered as investment companies,
there is a dearth of regulation. There are numerous other risks in investing in these securities. Clients should
consult each private fund’s Offering Documents prior to investing.
Real Estate Related Risks
The Firm may recommend that its clients invest directly or indirectly in real estate projects. Myriad risks
can impact the profitability of a real estate project, including asset management risk, operating risk, property
management risk, interest rate risk, leverage risk, demographic risk, development risk, general economic
risks, environmental risks, and other risk factors. The real estate projects recommended by the Firm may
utilize significant leverage which can significantly increase the riskiness of the projects. Additionally, the
ability to successfully develop real properties may be impaired by vendor risk, regulatory risk (including
the ability to obtain requisite permits), and other unforeseen circumstances. Once developed, there is no
guarantee that any real estate project will attract the type of tenants desired or the type of lease terms desired.
Prospective investors should familiarize themselves with the risk factors associated with each real estate
project.
Item 9. Disciplinary Information
Revolve Wealth Partners has not been involved in any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
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Registered Representatives of a Broker-Dealer
Neither Revolve Wealth Partners nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
Licensed Insurance Agents
Certain professionals of the Firm are separately licensed as independent insurance agents. As such, these
professionals conduct insurance product transactions for firm clients, in their capacity as licensed insurance
agents, and will receive customary commissions for these transactions in addition to any compensation
received in their capacity as employees of the Firm. Commissions from the sale of insurance products will
not be used to offset or as a credit against advisory fees. These professionals therefore have incentive to
recommend insurance products based on the compensation to be received, rather than on a client’s needs.
The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should
be aware of this conflict when considering whether to engage the Firm or utilize these professionals to
implement any insurance recommendations. Revolve Wealth Partners attempts to mitigate the conflict of
interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty
to the clients of the Firm, which requires that employees put the interests of clients ahead of their own.
Item 11. Code of Ethics
Revolve Wealth Partners has adopted a code of ethics in compliance with applicable securities laws (“Code
of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Revolve Wealth
Partners’ Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices
such as the use of material non-public information by the Firm or any of its Supervised Persons and the
trading by the same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of Revolve Wealth Partners’ personnel to report their personal
securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public
offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities
that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s
policies and procedures. This Code of Ethics has been established recognizing that some securities trade
in sufficiently broad markets to permit transactions by certain personnel to be completed without any
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that
security unless:
•
the transaction has been completed;
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•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact Revolve Wealth Partners to request a copy of its Code of Ethics
Item 12. Brokerage Practices
Recommendation of Broker-Dealers for Client Transactions
Revolve Wealth Partners generally recommends that clients utilize the custody, brokerage and clearing
services of Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”), for
investment management accounts.
Factors which Revolve Wealth Partners considers in recommending Schwab or any other broker-dealer to
clients include their respective financial strength, reputation, execution, pricing, research and service.
Schwab may enable the Firm to obtain many mutual funds without transaction charges and other securities
at nominal transaction charges. Schwab has also agreed to waive commissions for clients for a period of
time. The commissions and/or transaction fees charged by Schwab may be higher or lower than those
charged by other Financial Institutions.
The commissions paid by Revolve Wealth Partners’ clients to Schwab comply with the Firm’s duty to
obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial
Institution might charge to affect the same transaction where Revolve Wealth Partners determines that the
commissions are reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s
services, including among others, the value of research provided, execution capability, commission rates
and responsiveness. Revolve Wealth Partners seeks competitive rates but may not necessarily obtain the
lowest possible commission rates for client transactions.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-dealers
in return for investment research products and/or services which assist Revolve Wealth Partners in its
investment decision-making process. Such research generally will be used to service all of the Firm’s
clients, but brokerage commissions paid by one client may be used to pay for research that is not used in
managing that client’s portfolio.
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Revolve Wealth Partners periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Revolve Wealth Partners may receive without cost from Schwab computer software and related systems
support, which allow Revolve Wealth Partners to better monitor client accounts maintained at Schwab. The
software and support is not provided in connection with securities transactions of clients (i.e., not “soft
dollars”). The software and related systems support may benefit Revolve Wealth Partners, but not its clients
directly. In fulfilling its duties to its clients, Revolve Wealth Partners endeavors at all times to put the
interests of its clients first. Clients should be aware, however, that Revolve Wealth Partners’ receipt of
economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence the
Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or
services.
These services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in
accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice, analyses and
reports, and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or asset-
based fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to the Firm other products and services that benefit the Firm but may not
benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational
events organized and/or sponsored by Schwab. Other potential benefits may include occasional business
entertainment of personnel of Revolve Wealth Partners by Schwab personnel, including meals, invitations
to sporting events, including golf tournaments, and other forms of entertainment, some of which may
accompany educational opportunities. Other of these products and services assist Revolve Wealth Partners
in managing and administering clients’ accounts. These include software and other technology (and related
technological training) that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client
accounts), provide research, pricing information and other market data, facilitate payment of the Firm's fees
from its clients’ accounts, and assist with back-office training and support functions, recordkeeping and
client reporting. Many of these services generally may be used to service all or some substantial number of
the Firm’s accounts, including accounts not maintained at Schwab. Schwab also makes available to Revolve
Wealth Partners other services intended to help the Firm manage and further develop its business enterprise.
These services may include professional compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory compliance,
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employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may
make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent
third parties. Schwab may discount or waive fees it would otherwise charge for some of these services or
pay all or a part of the fees of a third-party providing these services to the Firm. While, as a fiduciary,
Revolve Wealth Partners endeavors to act in its clients’ best interests, the Firm's recommendation that
clients maintain their assets in accounts at Schwab may be based in part on the benefits received and not solely
on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a potential
conflict of interest.
Brokerage for Client Referrals
Revolve Wealth Partners does not consider, in selecting or recommending broker-dealers, whether the Firm
receives client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct Revolve Wealth Partners in writing to use a particular Financial Institution to execute
some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the
account with that Financial Institution and the Firm will not seek better execution services or prices from
other Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by Revolve Wealth Partners (as described above). As a
result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less
favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty
of best execution, Revolve Wealth Partners may decline a client’s request to direct brokerage if, in the Firm’s
sole discretion, such directed brokerage arrangements would result in additional operational difficulties.
Commissions or Sales Charges for Recommendations of Securities
Revolve Wealth Partners does not recommend specific securities to clients and therefore representatives of
Revolve Wealth Partners do not buy or sell securities for themselves that they also recommend to clients.
Trade Aggregation
Transactions for each client generally will be effected independently, unless Revolve Wealth Partners
decides to purchase or sell the same securities for several clients at approximately the same time. Revolve
Wealth Partners may (but is not obligated to) combine or “batch” such orders to obtain best execution, to
negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in
prices and commissions or other transaction costs that might not have been obtained had such orders been
placed independently. Under this procedure, transactions will generally be averaged as to price and
allocated among Revolve Wealth Partners’ clients pro rata to the purchase and sale orders placed for each
client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase
or sale of securities, including securities in which Revolve Wealth Partners’ Supervised Persons may invest,
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the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act and no-
action guidance provided by the staff of the U.S. Securities and Exchange Commission. Revolve Wealth
Partners does not receive any additional compensation or remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when
only a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector weightings
relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one
account has limitations in its investment guidelines which prohibit it from purchasing other securities which
are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account
reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to
other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv)
with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro
rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the
Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
Revolve Wealth Partners monitors client portfolios on a continuous and ongoing basis while regular account
reviews are conducted on at least a semi-annual basis. Such reviews are conducted by the Firm’s investment
adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and
objectives with Revolve Wealth Partners and to keep the Firm informed of any changes thereto. The Firm
contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations and semi-annually to discuss the impact resulting from any changes in the client’s
financial situation and/or investment objectives.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from Revolve Wealth Partners and/or an
outside service provider, which contain certain account and/or market-related information, such as an
inventory of account holdings or account performance. Clients should compare the account statements they
receive from their custodian with any documents or reports they receive from Revolve Wealth Partners or
an outside service provider.
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Item 14. Client Referrals and Other Compensation
Client Referrals
The Advisor engages independent solicitors to provide client referrals. If a client is referred to us by a
solicitor, this practice is disclosed to the client in writing by the solicitor and the Advisor pays the solicitor
out of its own funds—specifically, the Advisor generally pays the solicitor a portion of the advisory fees
earned for managing the capital of the client or investor that was referred. The use of solicitors is strictly
regulated under applicable federal and state law. The Advisor’s policy is to fully comply with the
requirements of Rule 206(4)-1, under the Investment Advisers Act of 1940, as amended, and similar state
rules, as applicable.
The Advisor may receive client referrals from Rainbook Advisors, LLC ("Rainbook"). Rainbook is
independent of and unaffiliated with the Advisor and there is no employee relationship between them.
Rainbook does not supervise the Advisor and has no responsibility for the Advisor’s management of client
portfolios or the Advisor’s other advice or services. The Advisor has confirmed that Rainbook is in
compliance with all necessary SEC rules.
Other Compensation
The Firm receives economic benefits from Schwab. The benefits, conflicts of interest and how they are
addressed are discussed above in response to Item 12.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize
Revolve Wealth Partners and/or the Independent Managers to debit client accounts for payment of the
Firm’s fees and to directly remit that those funds to the Firm in accordance with applicable custody rules.
The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains
the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly
detailing all account transactions, including any amounts paid to Revolve Wealth Partners.
In addition, as discussed in Item 13, Revolve Wealth Partners may also send periodic supplemental reports
to clients. Clients should carefully review the statements sent directly by the Financial Institutions and
compare them to those received from Revolve Wealth Partners.
Standing Letters of Authorization
Revolve Wealth Partners also has custody due to clients giving the Firm limited power of attorney in a
standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically
designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action
letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to
the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian
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will perform appropriate verification of the instruction and provide a transfer of funds notice to the client
promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the
Firm will have no authority or ability to designate or change the identity or any information about the third
party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located
at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice
confirming the SLOA instructions.
Item 16. Investment Discretion
Revolve Wealth Partners may be given the authority to exercise discretion on behalf of clients. Revolve
Wealth Partners is considered to exercise investment discretion over a client’s account if it can effect and/or
direct transactions in client accounts without first seeking their consent. Revolve Wealth Partners is given
this authority through a power-of-attorney included in the agreement between Revolve Wealth Partners and
the client. Clients may request a limitation on this authority (such as certain securities not to be bought or
sold). Revolve Wealth Partners takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Revolve Wealth Partners generally does not accept the authority to vote a client’s securities (i.e., proxies)
on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are
custodied and may contact the Firm at the contact information on the cover of this brochure with questions
about any such issuer solicitations.
Item 18. Financial Information
Revolve Wealth Partners is not required to disclose any financial information due to the following:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more
in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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