A. Firm Information
Point B Planning, LLC d/b/a AtwoB (“AtwoB” or the “Advisor”) is a registered investment advisor located in the
State of New York. AtwoB is organized as a Limited Liability Company (“LLC”) under the laws of New York.
AtwoB was founded in August 2014, and is owned and operated by its Richard Todd Rebori, CFA (Principal) and
Michael Tom, CFA, CFP® (Principal) and Jeffrey Wund (Principal and Chief Compliance Officer). This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services
provided by AtwoB.
B. Advisory Services Offered
AtwoB offers investment advisory and financial planning services to individuals, high net worth individuals, trusts,
charitable organizations, and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information
regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
AtwoB provides customized investment advisory solutions for its Clients. This is achieved through personal
Client contact and interaction while providing discretionary investment management services. AtwoB works with
each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in
order to create a portfolio strategy. AtwoB will then construct a portfolio, primarily consisting of diversified mutual
funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also
utilize individual stocks, bonds and any other applicable investment vehicles to meet the needs of its Clients.
AtwoB may also recommend certain unaffiliated money managers (Please see below).
AtwoB’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market conditions.
AtwoB will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance
by the Advisor.
AtwoB evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. AtwoB may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. AtwoB may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. AtwoB may
recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
AtwoB will provide investment management and related services. At no time will AtwoB accept or maintain
custody of a Client’s funds or securities, except for the limited authority outlined in Item 15 - Custody. All Client
assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the
agreement, please see Item 12 – Brokerage Practices.
Use of Independent Managers - AtwoB may recommend to Clients that all or a portion of their portfolio be
implemented by utilizing one or more unaffiliated money managers participating in a managed accounts program
at the Client's custodian (the “Program Sponsor”). The Client will then enter into a program and investment
advisory agreement with the Program Sponsor and the participating money manager[s]. The Advisor will assist
and advise the Client in establishing investment objectives for the account[s], the selection of the money
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manager[s], and defining any restrictions on the account. AtwoB will continue to provide oversight of the Client
account and ongoing monitoring of the activities of the unaffiliated money managers.
These money managers will develop an investment strategy to meet those objectives by identifying appropriate
investments and monitoring such investments. In consideration for such services, the Program Sponsor will
charge a program fee that includes the investment advisory fee of the money managers, the administration of the
program and trading, clearance and settlement costs. If applicable, the Program Sponsor will add AtwoB‘s
investment advisory fee (described below in Item 5 – Fees and Compensation) and will deduct the overall fee
from the Client account, generally at the start of each calendar month or quarter. The asset-based program fee is
tiered and varies depending on the size of the account, the asset class of the underlying securities and the sub-
advisor selected. The overall fee (including the Advisor's investment advisory fee) will not exceed 3% annually.
AtwoB does not receive any compensation from these unaffiliated money managers or the
Program Sponsor,
other than AtwoB’s investment advisory fee (described in Item 5 – Fees and Compensation).
The Client, prior to entering into an agreement with a Program Sponsor, will be provided with the Program
Sponsor's Form ADV Part 2A (or a brochure that makes the appropriate disclosures). In addition, AtwoB and its
Client will agree in writing that that selected Program Sponsor will manage the Client's account[s] on a
discretionary basis.
Financial Planning Services
AtwoB will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals, objectives and financial situation. Generally, such financial planning services will involve preparing a
financial plan based on the Client’s financial goals and objectives. This planning may encompass one or more
areas of need, including, but not limited to investment planning, retirement planning, personal savings, education
savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for the Client will usually include general recommendations for a course of activity or
specific actions to be taken by the Client. For example, recommendations may be made that the Client start or
revise their investment programs, commence or alter retirement savings, establish education savings and/or
charitable giving programs. AtwoB may also refer Clients to an accountant, attorney or other specialist, as
appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a
written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six months of contract date, assuming all information and documents requested are provided promptly.
Financial planning recommendations may pose a potential conflict between the interests of the Advisor and the
interests of the Client. For example, a recommendation to engage the Advisor for investment management
services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase
the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the
Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor.
Retirement Plan Advisory Services
AtwoB provides discretionary and non-discretionary advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to
assist the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the
needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education
• Investment Policy Statement (“IPS”) Design & Monitoring
• Investment Due Diligence & Management
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• Ongoing Investment Recommendations and Assistance
AtwoB may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may be in either
a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary investment
management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select the
investments for the Plan and/or make investment decisions on behalf of Plan Participants. In accordance with
ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of AtwoB’s fiduciary status, the
specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under
the engagement.
C. Client Account Management
Prior to engaging AtwoB to provide advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client.
These services may include:
• Establishing an Investment Strategy – AtwoB, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives taking into consideration the Client’s financial
situation, time horizon and tolerance for risk.
• Asset Allocation – AtwoB will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – AtwoB will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – AtwoB will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
AtwoB does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by AtwoB.
E. Assets Under Management
As of December 31, 2023, AtwoB manages the following assets:
Discretionary Assets $61,298,017
Non-Discretionary Assets $12,360,392
Total Assets Under Management $73,658,409
Clients may request more current information at any time by contacting the Advisor.