Overview
Assets Under Management: $183 million
Headquarters: SCOTTSDALE, AZ
High-Net-Worth Clients: 34
Average Client Assets: $5 million
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Fee Structure
Primary Fee Schedule (ADV PART 2A)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 1.00% |
$1,000,001 | $2,000,000 | 0.85% |
$2,000,001 | and above | 0.75% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $10,000 | 1.00% |
$5 million | $41,000 | 0.82% |
$10 million | $78,500 | 0.78% |
$50 million | $378,500 | 0.76% |
$100 million | $753,500 | 0.75% |
Clients
Number of High-Net-Worth Clients: 34
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 91.47
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 94
Discretionary Accounts: 94
Regulatory Filings
CRD Number: 115994
Last Filing Date: 2024-02-09 00:00:00
Form ADV Documents
Primary Brochure: ADV PART 2A (2025-03-25)
View Document Text
R.H. Investment Group, LLC
Form ADV Part 2A
Disclosure Brochure
Dated: February 27, 2025
Contact: Ehren Haymore, Chief Compliance Officer
Gainey Ranch Financial Center
7373 E. Doubletree Ranch Road, Suite 200
Scottsdale, AZ 85258
(480) 703-7872
This brochure provides information about the qualifications and business practices of R.H. Investment Group, LLC
(RHIG), CRD# 115994. If you have any questions about the contents of this brochure, please contact us at (480) 703-
-7872 or ehren@rhinvestment.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 R.H. Investment Group, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov.
References herein to R.H. Investment Group, LLC as a “registered investment adviser” or any reference to being
“registered” does not imply a certain level of skill or training.
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Item 2
Material Changes
The following material changes have been made to R.H. Investment Group, LLC’s disclosure statement
since the most recent Annual Amendment filing on February 9, 2024:
None
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-by-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
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Advisory Business
Item 4
R.H. Investment Group, LLC (RHIG) has been in business as an investment adviser since October 4, 2001.
RHIG is owned by Ehren McCain Haymore, who is also RHIG’s Managing Member and Chief Compliance
Officer.
INVESTMENT ADVISORY SERVICES
RHIG provides the following investment advisory services:
PORTFOLIO MANAGEMENT SERVICES
RHIG provides discretionary portfolio management services (“investment advisory services”) to its clients
on a fee only basis.
Client Obligations. In performing its services, RHIG shall not be required to verify any information
received from the client or from the client’s other professionals, and is expressly authorized to rely thereon.
Moreover, each client is advised that it remains his/her/its responsibility to promptly notify RHIG if there
is ever any change in his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising RHIG’s previous recommendations and/or services.
Disclosure Statement. A copy of this Form ADV Part 2A Disclosure Brochure shall be provided to each
client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Any client
who has not received a copy of RHIG’s written Brochure at least 48 hours prior to executing the Investment
Advisory Agreement shall have five business days subsequent to executing the agreement to terminate
RHIG’s services without penalty.
RHIG shall provide investment advisory services specific to the needs of each client. Prior to providing
investment advisory services, an investment adviser representative will ascertain each client’s investment
objective(s). Thereafter, RHIG shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at anytime, impose reasonable
restrictions, in writing, on RHIG’s services.
RHIG does not participate in a wrap fee program.
• As of February 26, 2025, RHIG had $213.628 million in discretionary assets under management
and $0 in non-discretionary assets under management.
Additional Important Information
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.
Conflicts of Interest
Conflict of Interest - 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. For
example, if you roll over an IRA or 401k account to our firm or otherwise transfer any other account to our
firm, we will charge your account and make money. If you decide to not roll over the IRA or other account
to our program, we will not make money. While we therefore have a financial incentive to recommend that
you to move your account to our program, RHIG has established policies and procedures that are designed
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to address this conflict between our interests and yours and to ensure that all recommendations made to you
are in your best interest.
Fees and Compensation
Item 5
RHIG provides discretionary investment advisory services on a fee only basis.
INVESTMENT ADVISORY SERVICES
RHIG’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets
placed under RHIG’s management (between 0.75% and 1.00%) as follows:
Market Value of Portfolio
$750,000.00- $999,999.99
$1,000,000.00- $1,999,999.99
More than $2,000,000.00
% of Assets
1.00%
0.85%
0.75%
Clients may elect to have RHIG’s advisory fees deducted from their custodial account. Both RHIG's
Investment Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit
the account for the amount of RHIG's investment advisory fee and to directly remit that management fee to
RHIG in compliance with regulatory procedures. In the limited event that RHIG bills the client directly,
payment is due upon receipt of RHIG’s invoice. RHIG shall deduct fees and/or bill clients quarterly in
advance, based upon the market value of the assets on the last business day of the previous quarter.
As discussed below, RHIG requires that Charles Schwab and Co., Inc. (“Schwab”) serve as the broker-
dealer/custodian for client investment management assets. Please see item 12 below for more information
about Schwab. Broker-dealers such as Schwab charge brokerage commissions and/or transaction fees for
effecting certain securities transactions (i.e. transaction fees are charged for certain no-load mutual funds,
commissions are charged for certain individual equity and fixed income securities transactions). Further,
your accounts may be subject to additional fees charged by the custodian of your portfolio, such as wire
transfer, margin interest, or other account fees. In addition to RHIG’s investment management fee,
brokerage commissions and/or transaction fees, clients will also incur relative to all mutual fund and
exchange traded fund purchases charges imposed at the fund level (e.g. management fees and other fund
expenses). All such fees charged by third-parties are separate from, and in addition to RHIG’s investment
management fee.
RHIG's annual investment advisory fee shall be prorated and paid quarterly, in advance, based upon the
market value of the assets on the last business day of the previous quarter. RHIG generally requires a
minimum asset level of $750,000.00 for investment advisory services. RHIG, in its sole discretion, may
reduce its investment management fee and/or reduce or waive its minimum asset requirement based upon
certain criteria (e.g., anticipated future earning capacity, anticipated future additional assets, dollar amount
of assets to be managed, related accounts, account composition, negotiations with client, etc.).
The Investment Advisory Agreement between RHIG and the client will continue in effect until terminated
by either party by written notice in accordance with the terms of the Investment Advisory Agreement. Upon
termination, RHIG shall refund the pro-rated portion of the advanced advisory fee paid based upon the
number of calendar days remaining in the billing quarter.
Neither RHIG, nor its representatives accept compensation from the sale of securities or other investment
products.
Additional Important Information
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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. For example, if you roll over
an IRA or 401k account to our firm or otherwise transfer any other account to our firm, we will charge your
account and make money. If you decide to not roll over the IRA or other account to our program, we will
not make money. While we therefore have a financial incentive to recommend that you to move your
account to our program, RHIG has established policies and procedures that are designed to address this
conflict between our interests and yours and to ensure that all recommendations made to you are in your
best interest.
Billing on Cash Positions
The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed
in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as
part of assets under management for purposes of calculating the firm’s advisory fee. At any specific
point in time, depending upon perceived or anticipated market conditions/events (there being no
guarantee that such anticipated market conditions/events will occur), the firm may maintain cash
and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are
maintained in cash or cash equivalents, such amounts could miss market advances and, depending
upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by
the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity
The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part
of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to
investment performance, fund manager tenure, financial impact to the client of taxable gains,
account additions/withdrawals, the client’s financial circumstances, and changes in the client’s
investment objectives. Based upon these and other factors, there may be extended periods of time
when the firm determines that changes to a client’s portfolio are neither necessary nor prudent.
Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee
will continue to apply during these periods, and there can be no assurance that investment decisions
made by the firm will be profitable or equal any specific performance level(s).
Performance-Based Fees and Side-by-Side Management
Item 6
Neither RHIG nor any supervised person of RHIG accepts performance-based fees.
Types of Clients
Item 7
RHIG’s clients shall generally include individuals and business entities. RHIG generally requires a
minimum asset level of $750,000.00 for investment advisory services. RHIG, in its sole discretion, may
reduce its investment management fee and/or reduce or waive its minimum asset requirement based upon
certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount
of assets to be managed, related accounts, account composition, negotiations with client, etc.).
Methods of Analysis, Investment Strategies and Risk of Loss
Item 8
RHIG may utilize the following methods of security analysis:
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• Fundamental – (analysis performed on historical and present data, with the goal of making financial
forecasts)
• Technical – (analysis performed on historical and present data, focusing on price and trade volume,
to forecast the direction of prices)
• Cyclical – (analysis performed on historical relationships between price and market trends, to
forecast the direction of prices)
RHIG may utilize the following investment strategies when implementing investment advice given to
clients:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
• Options (contract for the purchase or sale of a security at a predetermined price during a specific
period of time)
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should
not be assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by RHIG) will be profitable or equal
any specific performance level(s).
RHIG’s methods of analysis and investment strategies do not present any significant or unusual risks.
However, every method of analysis has its own inherent risks. To perform an accurate market analysis
RHIG must have access to current/new market information. RHIG has no control over the dissemination
rate of market information; therefore, unbeknownst to RHIG, certain analyses may be compiled with
outdated market information, severely limiting the value of RHIG’s analysis. Furthermore, an accurate
market analysis can only produce a forecast of the direction of market values. There can be no assurances
that a forecasted change in market value will materialize into actionable and/or profitable investment
opportunities.
RHIG’s primary investment strategies - Long Term Purchases and Short Term Purchases - are fundamental
investment strategies. However, every investment strategy has its own inherent risks and limitations. For
example, longer term investment strategies require a longer investment time period to allow for the strategy
to potentially develop. Shorter term investment strategies require a shorter investment time period to
potentially develop but, as a result of more frequent trading, may incur higher transactional costs when
compared to a longer term investment strategy.
Risks of Options
In addition to the fundamental investment strategies discussed above, RHIG may also implement and/or
recommend certain options transactions. While certain options strategies may have a high level of inherent
risk (as discussed more fully below), RHIG generally only makes use of covered calls as an options-
related investment strategy. The primary risk associated with a covered call investment strategy is that
the potential upside profit of owning a stock is limited to the call’s strike price, so that any of a stock’s price
movements above the call’s strike price are lost.
Schwab will provide the disclosure document “Characteristics and Risks of Standardized Options” to any
client desiring to authorize options related strategies for their account which affected clients should read
carefully.
Additional Option Risk Information
Many (but not all) options related investment strategies involves a high level of inherent risk. Option
transactions establish a contract between two parties concerning the buying or selling of an asset at a
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predetermined price during a specific period of time. During the term of the option contract, the buyer of
the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling
or purchasing a security depending upon the nature of the option contract. Generally, the purchase or the
recommendation to purchase an option contract by RHIG shall be with the intent of offsetting
(i.e.”hedging”) a potential market risk in a client’s portfolio. Please Note: Although the intent of the
options-related transactions that may be implemented by RHIG is to hedge against principal risk, certain
options-related strategies (i.e. straddles, short positions, etc), may, in and of themselves, produce principal
volatility and/or risk. Thus, a client must be willing to accept these enhanced volatility and principal risks
associated with such strategies. In light of these enhanced risks, client may direct RHIG, in writing, not to
employ any or all such strategies for his/her/their/its accounts. Option transactions are not typically
employed by RHIG. In the event we deem such a strategy to be appropriate for a client, we typically
discuss the strategy and its risks in detail with the client.
Currently, RHIG primarily allocates client investment assets among various individual equity (stocks), debt
(bonds) and fixed income securities, mutual funds and/or exchange traded funds on a discretionary basis in
accordance with the client’s designated investment objective(s).
Disciplinary Information
Item 9
RHIG has not been the subject of any disciplinary actions.
Other Financial Industry Activities and Affiliations
Item 10
Neither RHIG, nor its representatives, are registered or have an application pending to register, as a broker-
dealer or a registered representative of a broker-dealer.
Neither RHIG, nor its representatives, are registered or have an application pending to register, as a futures
commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the
foregoing.
Neither RHIG, nor its representatives, have any relationships or arrangements that are material to clients
with other financial industry participants except as otherwise may be disclosed in this brochure.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
RHIG maintains a personal trading policy relative to personal securities transactions. This personal trading
policy is part of RHIG’s overall Code of Ethics, which serves to establish a standard of business conduct
for all of RHIG’s Representatives that is based upon fundamental principles of openness, integrity, honesty
and trust, a copy of which is available upon request.
RHIG also maintains and enforces written policies reasonably designed to prevent the misuse of material
non-public information by RHIG or any person associated with RHIG.
Neither RHIG nor any related person of RHIG recommends, buys, or sells for client accounts, securities in
which RHIG or any related person of RHIG has a material financial interest.
RHIG and/or representatives of RHIG may buy or sell securities that are also recommended to clients. This
practice may create a situation where RHIG and/or representatives of RHIG are in a position to materially
benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of
interest. RHIG maintains a personal trading policy which establishes standards designed to place clients’
interests ahead of those of RHIG and RHIG’s IARs.
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Brokerage Practices
Item 12
The custodian and brokers we use
RHIG does not maintain custody of your assets that we manage, although we may be deemed to have
custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody,
below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer
or bank. We require that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer,
member SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets
in a brokerage account and buy and sell securities when either we or you instruct them to. While we require
that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with
Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this
arrangement are described below as well as in Item 14 (Client Referrals and Other Compensation). You
should consider these conflicts of interest when selecting your custodian.
We do not open the account for you, although we may assist you in doing so. If you do not wish to place
your assets with Schwab, then we cannot manage your account. Not all advisors require their clients to use
a particular broker-dealer or other custodian selected by the advisor. Even though your account is
maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still
use other brokers to execute trades for your account as described below (see “Your brokerage and custody
costs”).
How we select brokers/custodians
We seek to use Schwab, a custodian/broker that will hold your assets and execute transactions. When
considering whether the terms that Schwab provides are, overall, most advantageous to you when compared
with other available providers and their services, we take into account a wide range of factors, including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody);
• Capability to execute, clear, and settle trades (buy and sell securities for your account);
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests,
bill payment, etc.);
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
[ETFs], etc.);
• Availability of investment research and tools that assist us in making investment decisions;
• Quality of services;
• Competitiveness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate the prices;
• Reputation, financial strength, security and stability;
• Prior service to us and our clients;
• Services delivered or paid for by Schwab; and
• Availability of other products and services that benefit us, as discussed below (see “Products and
services available to us from Schwab”).
Your brokerage and custody costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it executes
or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may
not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the
uninvested cash in your account in Schwab’s Cash Features Program. In addition, Schwab charges you a
flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a
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different broker-dealer but where the securities bought or the funds from the securities sold are deposited
(settled) into your Schwab account. These fees are in addition to the commissions or other compensation
you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have
Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker
provides execution quality comparable to other brokers or dealers. Although we are not required to execute
all trades through Schwab, we have determined that having Schwab execute most trades is consistent with
our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a
transaction based on all relevant factors, including those listed above (see “How we select
brokers/custodians”). By using another broker or dealer you may pay lower transaction costs.
Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us.
They provide us and our clients with access to their institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to Schwab retail customers.
However, certain retail investors may be able to get institutional brokerage services from Schwab without
going through us. Schwab also makes available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s
support services are generally available on an unsolicited basis (we don’t have to request them) and at no
charge to us. Following is a more detailed description of Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services described
in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and services
that benefit us but do not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts and operating our firm. They include investment
research, both Schwab’s own and that of third parties. We use this research to service all of our clients’
accounts. In addition to investment research, Schwab also makes available software and other technology
that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements);
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• Provide pricing and other market data;
• Facilitate payment of our fees from our clients’ accounts; and
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
• Educational conferences and events;
• Consulting on technology and business needs;
• Consulting on legal and related compliance needs;
• Publications and conferences on practice management and business succession;
• Access to employee benefits providers, human capital consultants, and insurance providers; and
• Marketing consulting and support.
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Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all
or a part of a third party’s fees. If you did not maintain your account with Schwab, we would be required
to pay for these services from our own resources.
A conflict of interest exists when RHIG receives soft dollar benefits, especially those that benefit us, as our
receipt of such benefits can incentivize us to use Schwab for brokerage and custodial services rather than
another firm that does not provide such benefits even when using Schwab may not be in your best interest.
This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to act in the best
interest of its clients.
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or purchase
them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing
any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we
receive these benefits from Schwab is an incentive for us to require our clients to use Schwab rather than
making such a decision based exclusively on your interest in receiving the best value in custody services
and the most favorable execution of your transactions. This is a conflict of interest. We believe, however,
that taken in the aggregate, our use of Schwab as custodian and broker is in the best interests of our clients.
Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we
select brokers/ custodians”) and not Schwab’s services that benefit only us.
Trade order aggregation
To the extent that RHIG provides investment management services to its clients, the transactions for each
client account generally will be effected independently, unless RHIG decides to purchase or sell the same
securities for several clients at approximately the same time. RHIG may (but is not obligated to) combine
or “bunch” such orders to allocate equitably among RHIG’s clients differences in prices and commissions
or other transaction costs that might have been obtained had such orders been placed independently. Under
this procedure, transactions will be averaged as to price and will be allocated among clients in proportion
to the purchase and sale orders placed for each client account on any given day. RHIG shall not receive any
additional compensation or remuneration as a result of such aggregation.
Review of Accounts
Item 13
For those clients to whom RHIG provides investment supervisory services, account reviews are conducted
on an ongoing basis by RHIG's Principals and/or representatives. All investment supervisory clients are
advised that it remains their responsibility to advise RHIG of any changes in their investment objectives
and/or financial situation. All clients (in person or via telephone) are encouraged to review financial
planning issues (to the extent applicable), investment objectives and account performance with RHIG on
an annual basis.
RHIG may conduct account reviews on an other than periodic basis upon the occurrence of a triggering
event, such as a change in client investment objectives and/or financial situation, market corrections and
upon client request.
Clients are provided, at least quarterly, with written transaction confirmation notices and regular written
summary account statements directly from the broker-dealer/custodian and/or program sponsor for the
client accounts.
Item 14
Client Referrals and Other Compensation
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We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain their accounts at Schwab.
You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we
benefit from this arrangement because the cost of these services would otherwise be borne directly by us.
You should consider these conflicts of interest when selecting a custodian and/or deciding to use our
services. The products and services provided by Schwab, how they benefit us and the related conflicts of
interest are described above (see Item 12—Brokerage Practices).
Neither RHIG nor any supervised person of RHIG compensates any non-supervised person for client
referrals.
Custody
Item 15
Schwab maintains actual custody of your assets. Clients are provided, at least quarterly, with written
transaction confirmation notices and regular written summary account statements directly from Schwab.
Please note that Schwab does not verify the accuracy of RHIG’s advisory fee calculation.
RHIG may also provide occasionally a written report summarizing account activity and performance. To
the extent that RHIG provides you with such reports, you are urged to compare any report provided by
RHIG with the account statements received from the account custodian.
Investment Discretion
Item 16
The client can determine to engage RHIG to provide investment advisory services on a discretionary basis.
Prior to RHIG assuming discretionary authority over a client’s account, the client shall be required to
execute an Investment Advisory Agreement, naming RHIG as the client’s attorney and agent in fact, granting
RHIG full authority to buy, sell, or otherwise effect investment transactions involving the assets in the
client’s name found in the discretionary account.
Clients who engage RHIG on a discretionary basis may at any time impose restrictions, in writing, on
RHIG’s discretionary authority (e.g., limit the types/amounts of particular securities purchased for their
account, exclude the ability to purchase securities with an inverse relationship to the market, limit or
proscribe RHIG’s use of margin, etc.).
Voting Client Securities
Item 17
RHIG does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the manner
in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2)
making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other
type events pertaining to the client’s investment assets.
Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact
RHIG to discuss any questions they may have with a particular solicitation.
Financial Information
Item 18
RHIG does not solicit fees of more than $500, per client, six months or more in advance of services to be
rendered to clients.
RHIG is unaware of any financial condition that is reasonably likely to impair its ability to meet its
contractual commitments relating to its discretionary authority over certain client accounts.
RHIG has not been the subject of a bankruptcy petition.
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