A. Firm Information
RD Lewis Holdings, Inc. dba RD Lewis Wealth Management (“RD Lewis” or the “Advisor”) is a registered
investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a
corporation under the laws of Florida. RD Lewis was founded in July 2010 and is owned and operated by
Delcena D. Lewis (President) and Richard A. Lewis (Vice President, Chief Compliance Officer and Secretary).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by RD Lewis.
B. Advisory Services Offered
RD Lewis provides investment management services to individuals, high net worth individuals, families, trusts,
estates 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. RD Lewis’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
RD Lewis provides custom investment management services, according to the Client’s objectives, time horizon
and tolerance for risk. This is achieved through continuous personal Client contact and interaction while providing
discretionary investment management and related advisory services. RD Lewis emphasizes a long-term
investment time horizon, where appropriate. RD Lewis primarily recommends that its Clients allocate investment
management assets among various mutual funds and exchange-traded funds (“ETFs”) as appropriate for the
type of account[s]. RD Lewis selects mutual funds and ETFs by using various criteria, such as the fund
manager’s tenure, and/or overall career performance, tracking to its benchmark and overall expense ratios. The
Advisor may also utilize other types of investments, as appropriate, to meet the needs of its Clients.
RD Lewis may recommend, on occasion, redistributing investment allocations to diversify the portfolio in an effort
to reduce risk and increase performance. RD Lewis may recommend specific positions to increase sector
weighting and/or dividend potential. The Advisor may recommend employing cash positions as a possible hedge
against market movement. RD Lewis 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 the Client,
or any risk deemed unacceptable for the Client’s risk tolerance.
Under certain circumstances, RD Lewis may accept or maintain custody of Client’s funds or securities. Please
see Item 15 – Custody for more information.
Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will recommend that a Client
take a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts
(“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one
IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-
based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under
The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if
the Advisor will earn a new (or increase
its current) advisory fee as a result of the transaction. No client is under
any obligation to roll over a retirement account to an account managed by the Advisor.
Financial Planning Services
RD Lewis offers 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 and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting 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, or financial consultation rendered to 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.
RD Lewis may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the 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 (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of 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.
C. Client Account Management
Prior to engaging RD Lewis to provide investment 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 – RD Lewisin connection with the Client, will develop a strategy that
seeks to achieve the Client’s and objectives.
• Asset Allocation – RD Lewis 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 – RD Lewis will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – RD Lewis will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
RD Lewis does not place Client assets into a wrap fee program. Investment management services are provided
directly by RD Lewis.
E. Assets Under Management
As of December 31, 2023, RD Lewis manages $183,826,112 in assets,all of which are on a discretionary basis.
Clients may request more current information at any time by contacting the Advisor.