RM Private Wealth Management Inc. was incorporated in 2018 and is registered as an investment
advisor with the U.S. Securities and Exchange Commission (“SEC”) since June 2020. From
February 2019 to June 2020 the firm was registered with the States of Florida, New Jersey, and
Washington.
The principal owner of RM Private Wealth Management Inc. is Ramesh Madhusudan, President.
Advisory Services
RM Private Wealth Management Inc. (“RM Private Wealth” or “Advisor”) principal service is
providing fee-based investment advisory services and financial planning services. The Advisor
practices custom management of portfolios, on a discretionary basis, according to the client’s
objectives. The Advisor’s primary approach is to use a tactical allocation strategy aimed at
reducing risk and increasing performance. The Advisor may use exchange listed securities, foreign
securities, warrants, corporate debt securities, commercial paper, CDs, municipal securities,
mutual funds, and United States government securities to accomplish this objective, employing
options strategies and derivatives to manage risk. The Advisor measures and selects mutual funds
by using various criteria, such as the fund manager’s tenure, and/or overall career performance.
The Advisor may recommend, on occasion, redistributing investment allocations to diversify the
portfolio in an effort to reduce risk and increase performance. The Advisor may recommend
specific stocks to increase sector weighting and/or dividend potential. The Advisor may
recommend employing cash positions as a possible hedge against market movement which may
adversely affect the portfolio. The Advisor 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, or any risk deemed unacceptable for the client’s risk
tolerance.
Pension Consulting Services
RM Private Wealth will assist defined contribution plans in selecting and monitoring third-party
investment managers and investment options included in the plans.
As part of the process, RM Private Wealth will provide an investment policy statement. RM
Private Wealth will recommend, monitor, and benchmark the selected investment platform
according to the investment policy statement. RM Private Wealth may assist the client in
completing the third-party investment manager’s client questionnaire and opening account
paperwork. RM Private Wealth will also assist in the development of the initial policy
recommendations.
Depending on the needs of each client, Advisor may provide any of the following ERISA Fiduciary
services:
(i) Non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client shall have the final decision-making
RM Private Wealth Management Inc. Page 5
authority regarding the initial selection, retention, removal and addition of
investment options.
(ii) Assist the Client with the selection of a broad range of investment options
consistent with ERISA section 404(c) and the regulations thereunder.
(iii) Assist the Client in the development of an investment policy statement (IPS). The
IPS establishes the investment policies and objectives for the Plan. Client shall
have the ultimate responsibility and authority to establish such policies and
objectives and to adopt and amend the investment policy statement.
(iv) Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain or remove and replace investment options.
(v) Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
(vi) Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative (“QDIA”) for participants
who are automatically enrolled in the Plan or who otherwise fail to make an
investment election. The Client retains the sole responsibility to provide all notices
to participants required under ERISA section 404(c)(5).
In addition, the Adviser can perform the following Non-Fiduciary services if required:
(i) Assist in the education of the participants in the Plan about general investment
principles and the investment alternatives available under the Plan.
Client
understands that Adviser’s assistance in participant investment education shall be
consistent with and within the scope of (d) (i.e., the definition of investment
education) of Department of Labor Interpretive Bulletin 96-1. As such, the Adviser
is not providing fiduciary advice (as defined in ERISA) to the participants. Adviser
will not provide investment advice concerning the prudence of any investment option
or combination of investment options for a particular participant or beneficiary under
the Plan.
(ii) Assist in the group enrollment meetings designed to increase retirement plan
participation among employees and investment and financial understanding by the
employees.
Adviser may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Adviser and Client.
As a registered investment adviser, the Adviser has a fiduciary duty as an investment adviser to
the Client. While the Adviser may have specific responsibilities under ERISA to disclose its
ERISA fiduciary services separately from its non-ERISA fiduciary services, this does not affect
the Adviser’s investment adviser fiduciary duty to the Client.
RM Private Wealth Management Inc. Page 6
In consideration for these services, RM Private Wealth will receive an investment advisory fee,
billed quarterly in advance, and based on the value of the plan/assets on the last day of the quarter.
Adviser has no responsibility to provide any services related to the following types of assets:
employer securities; real estate (except for real estate funds and publicly traded REITs); stock
brokerage accounts or mutual fund windows; participant loans; non-publicly traded partnership
interests; other non-publicly traded securities or property (other than collective trusts and similar
vehicles); or other hard-to-value or illiquid securities or property (“Excluded Assets”), and those
assets will not be included in the fee calculation. The third-party investment managers are hired
by the client. RM Private Wealth is only making recommendations to the client about who should
be hired. The third-party investment manager will have discretion as to the model portfolios/asset
allocations and not the individual participants elections, or asset allocation of any participants
should they elect to customize their own portfolio. The client, prior to entering into an agreement
with a third-party investment manager recommended by RM Private Wealth will be provided with
that manager’s Brochure. In addition, the third-party investment manager and the client will agree
in writing that the client’s account will be managed by that selected third-party investment
manager on a discretionary basis. Additionally, Investment Advisor Representatives of RM Private
Wealth may provide consultation services on general non-securities advice on topics including
operations management, business model integration and management, and retirement plan
consulting and business planning. Fees are negotiable. Pre-payment of fees will not exceed $500
per client, 6 months in advance.
RM Private Wealth will recommend and refer clients to unaffiliated money managers or
investment advisors. Through this arrangement, the client will then enter into an advisory
agreement with the third-party money manager or investment advisor authorizing them to assist
and advise the client in establishing investment objectives and develop an investment strategy to
meet those objectives by identifying appropriate investments and monitoring such investments.
Financial Planning
In addition to investment supervisory services, RM Private Wealth may provide Financial Planning
Services to some of its clients. The Advisor’s Financial Planning services may include
recommendations for portfolio customization based on their client’s investment objectives, goals
and financial situation. Financial Planning Services may also include recommendations relating
to investment strategies as well as tailored investment advice, insurance, tax strategies, retirement
needs, and estate planning.
RM Private Wealth will tailor its advisory services to its client’s individual needs based on
meetings and conversations with the client. If clients wish to impose certain restrictions on
investing in certain securities or types of securities, the Advisor will address those restrictions with
the client to have a clear understanding of the client’s requirements.
RM Private Wealth does not provide portfolio management services to wrap fee programs.
As of February 29, 2024, RM Private Wealth had $219,755,228 in discretionary, and $0 in non-
discretionary, client assets under management.
RM Private Wealth Management Inc. Page 7