A. Description of the Advisory Firm
RPC Private Wealth, LLC (hereinafter “RPCPW”) is a Limited Liability Partnership
organized in the State of Illinois. The firm was formed in September 2018, and the
principal owner is Thomas Edward Westrick.
B. Types of Advisory Services
Portfolio Management Services
RPCPW offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client.
RPCPW evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. RPCPW will require discretionary authority from
clients in order to select securities and execute transactions without permission from the
client prior to each transaction.
RPCPW seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of RPCPW’s economic,
investment or other financial interests. To meet its fiduciary obligations, RPCPW attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, RPCPW’s policy is
to seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is RPCPW’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent
among its clients on a fair and equitable basis over time.
RPCPW provides account management under three levels of service structures. Our first
structure is a comprehensive service that provides account management on a continuous
basis and is referred to internally and with clients as our FundMAP platform. Clients on
FundMAP have Charles Schwab as the custodian of their accounts. Clients’ accounts on
the FundMAP platform have their account transactions reviewed daily by all advisors in
the firm, receive quarterly performance reports, have more frequent meetings, written,
and oral communications with their RPCPW advisor regarding their accounts and other
financial planning topics, have the activity in their accounts reviewed at least quarterly,
generally utilize a more robust variety of investment managers and styles, and are likely
to have more account maintenance trades (such as rebalancing and capital gain/loss
management) done in their accounts. Due to the more engaged level of advisory service,
clients on the FundMAP platform are likely to be charged the highest advisory fee. Our
second structure provides a less robust level of investment advisory service and is referred
to internally and with clients as our F2 platform. Under this platform, clients’ accounts
use American Funds mutual fund company as their custodian. Investments utilized are
exclusively American Funds and almost exclusively use their “F2” fee only share class.
Under this platform, clients pay the lowest level of advisory fee. RPCPW’s ongoing
account management services are more limited and typically do not include more than
annual account reviews and rebalancing trades. Client meetings are generally limited to
annual in person or phone calls, and modest consulting conversations related to non-
portfolio financial planning topics and issues. Our third structure of service is referred to
as our variable annuity and 529 plan platforms. Clients on this platform typically have
Nationwide Advisory Services Company serve as the custodian of their variable annuity
accounts and Bright Directions or American Funds serve as the custodian of
their 529 plan
accounts. Under this platform, clients typically pay an advisory fee slightly above the F2
platform but less than the FundMAP platform. The level and complexity of advisory and
financial planning services provided to clients on this platform are similar to those
provided on the F2 platform. Under all platforms, subject to a grant of discretionary
authority, RPCPW, through its IARs or any recommended sub-advisers, shall invest and
reinvest the securities, cash or other property held in the client’s account in accordance
with the client’s investment objectives as identified by the client during initial interviews
and information gathering sessions. Such suitability information is reviewed and updated
as needed by the client’s advisor at least annually.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
RPCPW generally limits its investment advice to mutual funds, real estate funds
(including REITs), and Exchange Traded Funds (ETFs). RPCPW primarily recommends
clients invest mostly in mutual funds and ETFs. RPCPW may use other securities as well
to help diversify a portfolio when applicable.
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 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.
C. Client Tailored Services and Client Imposed Restrictions
RPCPW offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon each client’s current
situation (income, tax levels, investment time horizon, and risk tolerance levels). Clients
may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent RPCPW
from properly servicing the client account, or if the restrictions would require RPCPW to
deviate from its standard suite of services, RPCPW reserves the right to end the
relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees.
RPCPW does not participate in wrap fee programs.
E. Assets Under Management
RPCPW has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$218,766,382.00 $1,886,273.00 December 2023