Item 5 - Additional Compensation .......................................................................................................................... 19
Item 6 - Supervision ..................................................................................................................................................... 19
Firm Description
Rinaldi Wealth Management, Inc (“RWM”) was founded in 2017 and began offering
investment advisory services in 2021. Dustin Rinaldi is 100% owner.
RWM is a fee-based investment management firm. The firm also sells insurance products
for a commission.
Types of Advisory Services
ASSET MANAGEMENT
RWM offers discretionary asset management services to advisory Clients. RWM will offer
Clients ongoing asset management services through determining individual investment
goals, time horizons, objectives, and risk tolerance. Investment strategies, investment
selection, asset allocation, portfolio monitoring and the overall investment program will be
based on the above factors. The Client will authorize RWM discretionary authority to
execute selected investment program transactions as stated within the Investment
Advisory Agreement.
SUB-ADVISORS
When deemed appropriate for the Client, RWM will hire Sub-Advisors to manage all or a
portion of the assets in the Client account. RWM has full discretion to hire and fire Sub-
Advisors as they deem suitable. Sub-Advisors will maintain the models or investment
strategies agreed upon between Sub-Advisor and RWM. Sub-Advisors execute trades on
behalf of RWM in Client accounts. RWM will be responsible for the overall direct
relationship with the Client. RWM retains the authority to terminate the Sub-Advisor
relationship at RWM’s discretion.
ERISA PLAN SERVICES
RWM provides service to qualified retirement plans including 401(k) plans, 403(b) plans,
pension and profit-sharing plans, cash balance plans, and deferred compensation plans.
RWM will act as a 3(21) advisor:
Limited Scope ERISA 3(21) Fiduciary. RWM will serve as a limited scope ERISA 3(21) fiduciary
that will advise, help and assist plan sponsors with their investment decisions. As an
investment advisor RWM has a fiduciary duty to act in the best interest of the Client. The
plan sponsor is still ultimately responsible for the decisions made in their plan, though
using RWM will help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide 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 will make the final decision regarding the initial selection,
retention, removal and addition of investment options. RWM acknowledges that it is
a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections. The
Client retains the sole responsibility to provide all notices to the Plan participants
required under ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and make
recommendations to maintain, remove or replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands RWM’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such,
RWM is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan
participants. RWM 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.
• Assist in the group enrollment meetings
designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
RWM may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between RWM and Client.
3. RWM has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or 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 will not be included in calculation of Fees paid to RWM on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2
disclosure.
FINANCIAL PLANNING AND CONSULTING
Financial planning services include a comprehensive evaluation of an investor's current
and future financial state will be provided by using currently known variables to predict
future cash flows, asset values and withdrawal plans. RWM will use current net worth, tax
liabilities, asset allocation, and future retirement and estate plans in developing financial
plans.
Typical topics reviewed in a financial plan may include but are not limited to:
• Financial goals: Based on an individual's or a family's clearly defined financial
goals, including funding a college education for the children, buying a larger home,
starting a business, retiring on time or leaving a legacy. Financial goals should be
quantified and set to milestones for tracking.
• Personal net worth statement: A snapshot of assets and liabilities serves as a
benchmark for measuring progress towards financial goals.
• Cash flow analysis: An income and spending plan determines how much can be set
aside for debt repayment, savings and investing each month.
• Retirement strategy: A strategy for achieving retirement independent of other
financial priorities. Including a strategy for accumulating the required retirement
capital and its planned lifetime distribution.
• Comprehensive risk management plan: Identify all risk exposures and provide
the necessary coverage to protect the family and its assets against financial loss. The
risk management plan includes a full review of life and disability insurance,
personal liability coverage, property and casualty coverage, and catastrophic
coverage.
• Long-term investment plan: Include a customized asset allocation strategy based
on specific investment objectives and a risk profile. This investment plan sets
guidelines for selecting, buying and selling investments and establishing
benchmarks for performance review.
• Tax reduction strategy: Identify ways to minimize taxes on personal income to the
extent permissible by the tax code. The strategy should include identification of tax-
favored investment vehicles that can reduce taxation of investment income.
• Estate preservation: Help update accounts, review beneficiaries for retirement
accounts and life insurance, provide a second look at your current estate planning
documents, and prompt you to update your plan when the legal environment
changes or you have major life events such as a marriage, death, or births.
If a conflict of interest exists between the interests of RWM and the interests of the Client,
the Client is under no obligation to act upon RWM’s recommendation. If the Client elects to
act on any of the recommendations, the Client is under no obligation to affect the
transaction through RWM. Financial plans will be completed and delivered inside of 30
days contingent upon timely delivery of all required documentation.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities.
Agreements may not be assigned without written Client consent.
Wrap Fee Programs
RWM does not sponsor any wrap fee programs.
Client Assets Under Management
RWM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$162,600,000 $0 December 31, 2023