Rialto Wealth Management (“Rialto” or “Advisor”) is an investment advisor firm registered with
the United States Securities and Exchange Commission (“SEC”).
The principal owners of Rialto are Michael L. Antonacci, Member, Edward J. Barno, Member,
and Ethan D. Gilbert, Member and Chief Compliance Officer, Rachel Ryan, Member, Jeffrey H.
Watson, Member.
Advisory Services
Rialto’s principal service is providing fee-based, fiduciary investment management and financial
planning services. The Advisor practices custom management of portfolios, on a discretionary
basis, according to the client’s objectives. The Advisor primarily uses low-cost non-actively
managed mutual funds and exchange traded funds to accomplish this objective. In addition,
Advisor may recommend and use exchange listed securities, over-the-counter securities, CDs,
United States government securities, and options on securities to meet a client’s investment needs.
The advisor selects mutual funds and ETFs by using various criteria, such as cost, turnover ratio,
exposure to the desired asset class, management’s tenure, and fund performance. The Advisor
may recommend selling positions for reasons that include, but are not limited to, harvesting capital
gains or losses, reducing exposure to a specific security, sector, 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 total financial picture.
Qualified Retirement Plan Consulting Services
Rialto will offer pension consulting services to Qualified Plans and participant fiduciary advice to
plan participants for assets held at Qualified Plans. The Advisor’s pension consulting services and
participant fiduciary advice will be based on information obtained from the plan participant about
goals and investment objectives, time horizon, risk tolerance and the plan participant's financial
situation. In cases where Rialto provides ERISA Section 3(38) fiduciary investment services,
Rialto is responsible for the implementation of recommendations for the Qualified Plans. Where
Rialto provides ERISA Section 3(21) fiduciary investment recommendations, the trustee and the
investment committee are responsible for implementation of recommendations and Rialto will not
act on the plan participants’ behalf to implement these recommendations.
Rialto may offer other pension consulting services that include but are not limited to educational
seminars, plan surveys, evaluations of vendor's services or special projects on behalf of the plan
sponsor.
Additionally, Rialto Wealth Management LLC may provide services as follows for qualified
retirement plans:
Fiduciary Services
The Advisor may perform the following Fiduciary Services:
(i) Provide discretionary and non-discretionary investment advice to the Client about asset
classes and investment alternatives available for the Plan in accordance with the Plan’s
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investment policies and objectives. Client shall have the final decision-making
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 discretionary and 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).
Non-Fiduciary Services
The Advisor may perform the following Non-Fiduciary services:
(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 Advisor’s assistance in participant investment education shall be consistent with
and within the scope of section (d) of the Department of Labor Interpretive Bulletin
96-1 (i.e., the definition of investment education). As such, the Advisor is not
providing fiduciary advice (as defined in ERISA) to the participants. Advisor 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.
Advisor may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between Advisor and Client.
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The Advisor's roles and actions in fulfilling all responsibilities pertaining to this Agreement shall
not include those of the Plan's Trustee, and will be performed solely at the direction of the Plan
Sponsor, its authorized officers, employees and/or agents. At no time will the Advisor accept,
maintain possession of, or have custodial responsibility for, the Plan's assets. The Advisor will
not conduct or effect the purchase or sale of any assets of the Plan on behalf of the Plan Sponsor
or Plan Participants. The Advisor will not advise, in any manner, any Participant, person or entity
related to the Plan other than the Plan Sponsor, except where the Participant is an advisory client
of Rialto under a separate advisory agreement. Communicational and educational activities in
which the Advisor engages related to Participants in the Plan shall be solely at the direction of the
Plan Sponsor, and shall not be represented by the Advisor or Plan Sponsor as investment, tax or
legal advice. The Advisor is not licensed to provide, shall not provide, nor be construed to provide,
the services of an attorney or accountant.
Financial Planning
In addition to investment management services, Rialto may provide financial planning services to
its clients. The Advisor’s financial planning services may include recommendations for portfolio
customization based on the client’s investment objectives, goals and financial situation,
recommendations relating to investment strategies as well as tailored investment advice. Financial
planning may also include non-investment advice such as developing strategies to achieve
retirement or other financial goals, tax optimization strategies, cash flow and budgeting analysis
and recommendations, financing and financial education, estate planning, and asset protection
strategies.
Rialto 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.
Rialto does not provide portfolio management services to wrap fee programs.
As of December 31, 2023, Rialto had $305,185,000 in discretionary, and $7,159,000 in non-
discretionary client assets under management.