This Disclosure document is being offered to you by Prairie Rivers Investments LLC (“Prairie
Rivers Investments”) about the investment advisory services we provide. It discloses
information about the services that we provide and the way those services are made
available to you, the client.
We are an investment management firm located in Robinson, IL. We specialize in
investment advisory services for high-net-worth individuals, institutions, charitable
organizations and endowments, employer sponsored retirement plans, families, trusts and
estates. The firm was established by its principal owner Pat Keen in 2016.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer
an initial complimentary meeting at our discretion; however, investment advisory services
are initiated only after you and Prairie Rivers Investments execute an engagement letter
or client agreement.
Investment and Wealth Management and Supervision Services
We offer discretionary and non-discretionary investment management and investment
supervisory services for a fee based on a percentage of your assets under management.
We primarily allocate client assets among cash, individual stocks, bonds, exchange traded
funds (“ETFs”), no-load or load-waived mutual funds, equities and cash in accordance with
their stated investment objectives. We generally invest Client’s cash balances in money
market funds and/or FDIC Insured Certificates of Deposit. In most cases, at least a partial
cash balance will be maintained in a money market account so that our firm may debit
advisory fees for our services related to this service.
We provide these services at four different levels: Bronze, Silver, Gold and Platinum, as
described below.
Bronze Level: Services include an Annual Review, utilization of Nitrogen, Quarterly
FI360, Beneficiary Review, Power of Attorney Check-Up and an Investment Policy
Statement.
Silver Level: Services include those listed above at the Bronze Level, plus Advisor
Access+, Tax Clarity Review and Social Security Timing.
Gold Level: Services include those listed above at both the Bronze and Silver Levels,
plus Major Purchase Assistance, a Coordinated Professional Meeting, Insurance
Analysis, All Year Tax Harvesting and a Document Vault.
Platinum Level: Services include those listed above at the Bronze, Silver and Gold
Levels plus Family Office Services, Charitable Giving Reviews & Planning and Trust
Consulting.
All of our service levels include Investment Analysis, Allocation of Investments, Quarterly
portfolio Reports, and Ongoing Monitoring of Client Portfolios. We primarily allocate client
assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt
(bonds) and equity securities in accordance with their stated investment objectives.
Through our use of Nitrogen, we will work with you to obtain necessary information
regarding your financial condition, investment objectives, liquidity requirements, risk
tolerance, time horizons, and any restrictions on investing. This information enables us to
determine the portfolio best suited for your investment objective and needs.
In performing our services, we shall not be required to verify any information received from
you or from other professionals. If you request, we will recommend you engage the
services of other professionals for implementation purposes. You have the right to decide
whether or not to engage the services of any such recommended professional.
Once we have determined the types of investments to be included in your portfolio and
have allocated them, we will provide ongoing portfolio review and management services.
We will rebalance the portfolio, as we deem appropriate, to meet your financial objectives.
We trade these portfolios and rebalance them on an ongoing basis, using our investment
process and based on your investment objectives and on the combination of our market
views. We tailor our advisory services to meet the needs of our clients and seek to ensure
that your portfolio is managed in a manner consistent with those needs and objectives. You
will have the ability to leave standing instructions with us to refrain from investing in
particular industries or invest in limited amounts of securities.
If a non-discretionary relationship is in place, calls will be placed presenting the
recommendation made and only upon your authorization will any action be taken on your
behalf.
In all cases, you have a direct and beneficial interest in your securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from your accounts, but only with the
appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position or other
investment held in client portfolios. Clients will engage us to 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).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks may exist that adversely
affect an account’s performance. This could result in capital losses in your account.
Third Party Management (“TPM Program” or “TPM”)
Prairie Rivers Investments provides investment advice and recommendations based on the
investment strategies of Third Party Managers (“Managers” or “TPM”). Selected Managers
are evaluated by Prairie Rivers Investments for client use.
Our services include assisting you in identifying your investment objectives and matching
personal and financial data with a select list of Managers. The intent of this service is to
have a selected list of high quality and recognizable third party investment management
firms from which you select one or more Managers to handle the day-to-day management
of your account(s). Managers selected for your investments need to meet several
quantitative and qualitative criteria established by Prairie Rivers Investments. Among the
criteria that may be considered are the Manager’s experience and regulatory record, assets
under management, performance record, client retention, the level of client services
provided, investment style, buy and sell disciplines, capitalization level, and the general
investment process. Information collected by our firm regarding Managers is believed to
be reliable and accurate but Prairie Rivers Investments does not necessarily independently
review or verify it on all occasions.
Following recommendations by our Investment Adviser Representatives (“IAR”), you will
have final authority to select a Manager. The IAR will assist you in completing appropriate
documents. Prairie Rivers Investments’ IARs assist clients with identifying their risk
tolerance and investment objectives. IARs will recommend TPMs in relation to the client’s
stated investment objectives and risk tolerance. A client may select a recommended TPM
based upon the client’s needs. Clients will enter a Third Party Advisory Program Agreement
directly with Prairie Rivers Investments.
Prairie Rivers Investments IARs shall be available to answer questions the client may have
regarding their account and act as the communication conduit between the client and the
Manager. Managers may take discretionary authority to determine the securities to be
purchased and sold for the client. Neither Prairie Rivers Investments nor its associated
persons will have any trading authority with respect to clients’ managed account with the
TPM(s).
All accounts are managed by the selected Manager and Prairie Rivers Investments does not
have any discretionary trading authority with respect to such accounts. All performance
reporting will be the responsibility of the respective Manager. Such performance reports
will be provided directly to you and Prairie Rivers Investments. Prairie Rivers Investments
does not audit or verify that these results are calculated on a uniform or consistent basis
as provided by a Manager directly to Prairie Rivers Investments or through the consulting
service utilized by the Manager.
Prairie Rivers Investments has entered into agreements with various independent
Managers. Under these agreements, Prairie Rivers Investments offers client’s various types
of programs sponsored by these Managers. All third-party Managers to whom Prairie Rivers
Investments will refer clients will be licensed as registered investment advisors by their
resident state and any applicable jurisdictions or registered investment advisors with the
Securities and Exchange Commission.
Third-party managed programs generally have account minimum requirements that will
vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity based accounts. A complete description of
the Manager’s services, fee schedules and account minimums will be disclosed in the
Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the
time an agreement for services is executed and account is established.
Financial Planning
Through the Financial Planning process, the Prairie Rivers Investments LLC team strives to
engage our clients in conversations around the family’s goals, objectives, priorities, vision,
and legacy – both for the near term as well as for future generations. With the unique
goals and circumstances of each family in mind, the Prairie Rivers Investments team will
offer wealth planning ideas and strategies to address the client’s holistic financial picture,
including estate, income tax, charitable, cash flow, wealth transfer and family legacy
objectives. Prairie Rivers Investments does not provide tax or legal advice. We will work
with your independent tax/legal advisor (CPA, Estate Attorney, Insurance broker, etc.) to
help create a plan tailored to your specific needs. Such services include various reports on
specific goals and objectives or general investment and/or planning recommendations,
guidance to outside assets and periodic updates.
Our specific services in preparing your plan include:
• Review and clarification of your financial goals.
• Assessment of your overall financial position including cash flow, balance sheet,
investment strategy, risk management and estate planning.
• Creation of a unique plan for each goal you have, including personal and business
real estate, education, retirement or financial independence, charitable giving,
estate planning, business succession and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors
to our clients around tax suggestions, asset allocation, expenses, risk and liquidity
factors for each goal. This includes IRA and qualified plans, taxable and trust
accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance,
mitigation and transfer, including liquidity as well as various insurance and
possible company benefits.
• Crafting and implementation of, in conjunction with your estate and/or corporate
attorneys as tax advisor, an estate plan to provide for you and/or your heirs in the
event of an incapacity or death.
A written evaluation of each client's initial situation or Financial Plan is provided to the
client. An annual review will be provided by the Adviser, if indicated by the Client and
Advisor per the Financial Planning Agreement. More frequent reviews occur but are not
necessarily communicated to the client unless immediate changes are recommended.
Employer Sponsored Retirement Plans
Prairie Rivers Investments will assist in the creation and annual maintenance of the Plan
and its Investment Policy Statement (IPS). PRI will make ongoing investment alternative
recommendations and
monitor these choices for continued adherence to the IPS, compare
them against their peers, and other fiduciary criteria. PRI will assist the plan fiduciaries in
identifying a Qualified Default Investment Alternative and will assist with creating a plan to
comply with all disclosures required by law and by plan mandate. PRI will provide ongoing
performance reporting using multiple independent data providers and assist the plan
fiduciaries in evaluating these reports for adherence to plan policies.
PRI will also assist plan sponsors in designing and implementing education tailored to the
plan for participants, educating them on the plan provisions and for all investment
alternatives, as well as general investment education. PRI will provide education to the
Plan Committee tailored to the plan on plan features and fiduciary responsibility. PRI will
serve as liaison between the plan and service providers. Periodically, PRI will assist with
Requests for Proposals or Requests for Information to assist the Plan Committee in
identifying and evaluating plan service providers. PRI will evaluate and assist the plan
committee in benchmarking both the plan and all investment alternatives on multiple
levels of fiduciary responsibility.
Employer Sponsored Retirement Plan Consulting
Prairie Rivers Investments will assist the sponsoring employer on the administration and
compliance aspects of their plan, without the expectation for investment
management. Consulting services include, but are not limited to:
• Preparation of Requests for Proposal (RFP) packages
• Review of Investment Policy Statements
• Due Diligence review of investment and insurance offerings
• Review plan committee structure and administrative policies and procedures
• Review fee levels and benchmark against similar plans
• Review education and enrollment process
• Evaluate Qualified Default Investment Alternative (QDIA) options
• Review ERISA Spending Accounts or Plan Expense Recapture Accounts (PERA)
After the consultation is complete, Prairie Rivers Investments’ obligation to the client will
terminate and will not be under obligation to provide ongoing monitoring or updates.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). Our Firm may recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services.
As a result, our Firm and its representatives may earn an asset-based fee. In contrast, a
recommendation that a client or prospective client leave their plan assets with their
previous employer or roll over the assets to a plan sponsored by a new employer will
generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. All rollover recommendations are also reviewed by our Firm’s Chief Compliance
Officer in a best effort to determine that the recommendation to a client was reasonable
or that the client has determined to make the rollover after being provided ample
information about their options. No client is under any obligation to roll over plan assets
to an IRA advised by our Firm or to engage our Firm to monitor and/or advise on the
account while maintained with the client's employer. Our Firm’s Chief Compliance Officer
remains available to address any questions that a client or prospective client has regarding
this disclosure.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also 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. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
Endowment Consulting
Prairie Rivers Investments will assist endowments with the creation and ongoing
maintenance of relevant documents and protocols required by regulators, and adherence
to current fiduciary responsibilities. These services include but are not limited to the
creation of an Investment Policy Statement (IPS), written Conflict of Interest policy, and
creating a system to formalize, implement, monitor and organize necessary best practices
for not-for-profit fiduciaries.
Third Party Managers
Prairie Rivers Investments provides investment advice and recommendations based on the
investment strategies of Third Party Managers (“Managers” or “TPM”). Selected Managers
are evaluated by Prairie Rivers Investments for client use. (See more about Third Party
Managers in Item 8 below).
Our services include assisting you in identifying your investment objectives and matching
personal and financial data with a select list of Managers. The intent of this service is to
have a selected list of high quality and recognizable third party investment management
firms from which you select one or more Managers to handle the day-to-day management
of your account(s). Managers selected for your investments need to meet several
quantitative and qualitative criteria established by Prairie Rivers Investments. Among the
criteria that may be considered are the Manager’s experience and regulatory record, assets
under management, performance record, client retention, the level of client services
provided, investment style, buy and sell disciplines, capitalization level, and the general
investment process. Information collected by our firm regarding Managers is believed to
be reliable and accurate, but Prairie Rivers Investments does not necessarily independently
review or verify it on all occasions.
Following recommendations by our Investment Adviser Representatives (“IAR”), you will
have final authority to select a Manager. The IAR will assist you in completing appropriate
documents. Prairie Rivers Investments’ IARs assist clients with identifying their risk
tolerance and investment objectives. IARs will recommend TPMs in relation to the client’s
stated investment objectives and risk tolerance. A client may select a recommended TPM
based upon the client’s needs. Clients will enter a Third Party Advisory Program Agreement
directly with Prairie Rivers Investments.
Prairie Rivers Investments IARs shall be available to answer questions the client may have
regarding their account and act as the communication conduit between the client and the
Manager. Managers may take discretionary authority to determine the securities to be
purchased and sold for the client. Neither Prairie Rivers Investments nor its associated
persons will have any trading authority with respect to clients’ managed account with the
TPM(s).
All accounts are managed by the selected Manager and Prairie Rivers Investments does not
have any discretionary trading authority with respect to such accounts. All performance
reporting will be the responsibility of the respective Manager. Such performance reports
will be provided directly to you and Prairie Rivers Investments. Prairie Rivers Investments
does not audit or verify that these results are calculated on a uniform or consistent basis
as provided by a Manager directly to Prairie Rivers Investments or through the consulting
service utilized by the Manager.
Prairie Rivers Investments has entered into agreements with various independent
Managers. Under these agreements, Prairie Rivers Investments offers client’s various types
of programs sponsored by these Managers. All third-party Managers to whom Prairie Rivers
Investments will refer clients will be licensed as registered investment advisors by their
resident state and any applicable jurisdictions or registered investment advisors with the
Securities and Exchange Commission.
Third-party managed programs generally have account minimum requirements that will
vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity based accounts. A complete description of
the Manager’s services, fee schedules and account minimums will be disclosed in the
Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at the
time an agreement for services is executed and account is established.
Consulting Services
We also provide clients investment advice on a more-limited basis on one-or-more isolated
areas of concern such as variable sub-account management, estate planning, real estate,
retirement planning, or any other specific topic. Additionally, we provide advice on non-
securities matters about the rendering of estate planning, insurance, real estate, and/or
annuity advice or any other business advisory / consulting services for equity or debt
investments in privately held businesses. In these cases, you will be required to select your
own investment managers, custodian and/or insurance companies for the implementation
of consulting recommendations. If your needs include brokerage and/or other financial
services, we will recommend the use of one of several investment managers, brokers,
banks, custodians, insurance companies or other financial professionals ("Firms"). You must
independently evaluate these Firms before opening an account or transacting business,
and have the right to effect business through any firm you choose. You have the right to
choose whether to follow the consulting advice that we provide.
Wrap Fee Programs
Prairie Rivers Investments is the sponsor and manager of the Prairie Rivers Investments
Wrap Program (the “Program”), a wrap fee program (i.e., an arrangement where
brokerage commissions and transaction costs are absorbed by the Firm). The fee covers
transaction costs or commissions resulting from the management of your accounts. While
many types of investments trade without transaction fees today, PRI has committed to
using the lowest available cost share class of mutual funds, which typically are not free to
trade. Participants in the Program may pay a higher aggregate fee than if brokerage
services are purchased separately. Additional information about the Program is available
in Prairie Rivers Investments’ Wrap Brochure, which appears as Part 2A Appendix 1 of the
Firm’s Form ADV. Because wrap program transaction fees and/or commissions are being
paid by Prairie Rivers Investments to the account custodian, we could have an economic
incentive to minimize the number of trades in the client's account. This creates a conflict
of interest. We recognize the fiduciary responsibility to place your interests first and have
established policies in this regard to avoid any potential conflict of interest a wrap fee
arrangement may create.
Assets
As of December 31, 2023, our discretionary assets under management totaled
$191,646,137 and our non-discretionary assets total $0.