Rubicon Wealth Management, LLC is a registered investment adviser based in Blue Bell, Pennsylvania. Our firm is organized as a limited liability company under the laws of the State of Pennsylvania. We have been providing investment advisory services since 1995. Our firm is 100% owned by Rubicon Holdings, Inc. Scott J. Mason is the principal owner of Rubicon Holdings, Inc.
We provide our clients with an extensive range of investment advisory services through our investment management programs, including wealth management, discretionary and non-discretionary portfolio management, review and selection of other advisors, and general consulting services. Our integrated suite of services may be offered to clients on an all-inclusive or individual basis. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services based on an analysis of your financial situation, personal balance sheet complexities, and individualized needs.
Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Wealth Management Services We engage in ongoing wealth management services, the goal of which is to help you structure a multi- generational wealth management plan designed to grow, preserve and protect family assets for future generations. Prior to proceeding, we will work with you to determine the scope of the services to be provided, and we will enter into an agreement for services. The process typically begins with an exploratory meeting during which we start the process of gathering pertinent information necessary to assist you in determining specific needs, goals, objectives, and tolerances for risk. As required, we will conduct follow-up interviews for the purpose of reviewing and/or collecting additional financial data. Once such information has been reviewed and analyzed, we will provide you with a written investment strategy in the form of an assessment/analysis based on your individual needs, goals and objectives.
Wealth management services may address subjects such as retirement planning, estate planning, cash flow, assets and liabilities, asset allocation, estate planning, insurance needs, tax management, credit management, and educational planning. The assessment/analysis may be provided in sections after one or more working sessions with you. As part of this service, we will also meet periodically with you to discuss your financial strategy, and to implement this strategy by providing one or more of the advisory services described below.
The written investment strategy is based on your financial situation at the time the strategy is presented to you. You are advised that certain assumptions may be made with respect to interest and inflation rates, as well as past trends, historical market performance, and the economy. Past performance is in no way an indication of future results. We cannot offer any guarantees or promises that your financial goals and objectives will be met. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
Portfolio Management Services We typically offer discretionary portfolio management services in accordance with your individual investment objectives. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. This authorization includes deciding which securities to buy and sell, when to buy and sell, and in what amounts, in accordance with your investment program, without obtaining your prior consent or approval for each transaction. Discretionary authority is typically granted by the investment advisory 5 agreement you sign with our firm, a power of attorney, and/or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
We may also manage advisory accounts on a non-discretionary basis, meaning specific client consent must be granted prior to each transaction. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Predicated on suitability, we may also recommend third-party money managers and other wealth advisers (collectively "sub-adviser") for account management services. The sub-adviser may be retained to manage a portion of, or your entire portfolio. In doing so, our primary objective is to align you with the appropriate sub-adviser(s) to allow you to capitalize on opportunities that will strengthen or enhance your personal wealth. Under such arrangements, we will monitor the sub-adviser's performance and we may assume discretionary authority to hire and fire a sub-adviser and reallocate your assets, where such action is deemed to be in your best interest. Discretionary authority to hire and fire the sub-adviser will be granted in the agreement for services, or other account opening documents. If such discretionary authority is not granted, we will provide these services on a non- discretionary basis as directed by you.
You may make additions to and withdrawals from your account at any time, subject our right to terminate an account that in our discretion falls below a size which is too small to effectively manage. You may withdraw account assets on notice to our firm, and subject to the usual and customary securities settlement procedures. However, we design our portfolios as long-term investments and asset withdrawals may impair the achievement of your specific investment objectives.
Wealth management fees may consist of an asset-based management free, a fixed annual retainer fee, or a combination thereof. Our fees are subject to negotiation, depending on the nature, complexity and time involved in providing the requested services. Therefore, arrangements with existing clients may differ.
Fixed Fees: We may charge a fixed annual fee that ranges between $500.00 and $50,000.00. The fee is payable quarterly in arrears (i.e., after services are rendered).
Percentage Based Fees: We may charge an annual percentage based fee, paid quarterly in arrears (i.e., after services are rendered), and based on the value of your Account(s) on the last day of the quarter. If the agreement for services is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Currently, our negotiable asset-based management fee is based on a range from 0.05% to 1.25%: We will either send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account, including and deductions of our advisory fees. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements.
6 Our agreement for services will continue in effect until terminated by either party. You may terminate the management agreement upon 30-days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Refunds are not applicable as fees are payable in arrears (i.e., after services are rendered).
For those clients who receive an invoice from our firm, we encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian please call our main office number located on the cover page of this brochure.
Managed Account Program We participate in the Managed Accounts Program (the "Program"). To participate in the Program, our firm, SEI Investments Management Corporation ("SIMC") and the individual investors execute a tri- party agreement ("Managed Account Agreement") providing for the management of certain investor assets in accordance with the terms thereof. Pursuant to a Managed Account Agreement, you, as the investor, appoint our firm as your investment adviser to assist you in selecting an asset allocation strategy, which would include the percentage of your assets allocated to designated portfolios of separate securities (each, a "Managed Account Portfolio") and may include the percentage of assets allocated to a portfolio of mutual funds advised by SIMC or an affiliate of SIMC. You further appoint SIMC to manage the assets in each Managed Account Portfolio in accordance with a strategy selected by you together with our firm. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers.
The negotiable fees payable to the Firm are based on a range from 0.05% to 1.25%: SIMC's advisory fee schedule for the MAP Program is as follows: The fees payable to SIMC for Large Cap Core/Transition Strategy: 0.85% for the first $1 million 0.80% for the next $2 million 0.75% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Equity Core and Large Cap Core Strategy: 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Large Cap Growth Strategy: 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Large Cap Value Strategy: 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million 7 The fees payable to SIMC for Managed Volatility/Tax-Sensitive Managed Volatility: 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Midcap Strategy: 1.10% for the first $1 million 1.00% for the next $2 million 0.90% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Small Cap Strategy: 1.20% for the first $1 million 1.10% for the next $2 million 1.00% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for International Equity Strategy: 1.20% for the first $1 million 1.10% for the next $2 million 1.00% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Active Municipal Bond Strategy: 0.70% for the first $1 million 0.65% for the next $2 million 0.60% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Laddered Bond Strategy: 0.30% for the first $500,000 0.27% for the next $500,000 0.25% for the next $1 million 0.20% for the next $3 million The fees payable to SIMC for Core Fixed Income Strategy: 0.70% for the first $1 million 0.65% for the next $2 million 0.60% for the next $2 million Negotiable for above $5 million SIMC may impose minimum account balances ranging from $50,000 to $1,000,000 depending upon the Managed Account Portfolio chosen and whether you select the tax management feature. Under the Program, you receive investment advisory services, the execution of securities brokerage transactions, custody services and reporting services for a single specified fee. Participation in the Program may 8 cost you more or less than purchasing such services separately. In addition, the Program fee may be higher or lower than that charged by other sponsors of comparable wrap fee programs. The aforementioned fees may be subject to a discount.
In addition, the Program offers a feature called Integrated Managed Accounts ("IMAP"), which is an enhancement to the standard Program. In IMAP, SIMC selects one sub-adviser to serve as a tax manager for the entire Managed Account Portfolio. Other sub-advisers recommend securities using buy/sell lists for their specific asset class to which the investor has selected. An integration fee will be charged to your account when you select the IMAP feature. The fee will cover the integration of the equity managers, which helps result in increased coordination across the equity account, increased tax efficiency and additional features such as wash sale prevention. These additional fees only apply to the equity portion of your account that is allocated to the integrated equities

portfolio; the fees do not apply to the fixed income or funds portion of your account (if any). A selection of your assets may receive a fee discount.
The fees payable to SIMC for the IMAP feature are up to 0.15% for the first $500,000 and 0.05 % for amounts in excess of $500,000 in assets under management.
GoalLink - Integrated Managed Account Program We participate in the GoalLink Program ("GoalLink Program"). We offer the GoalLink Program to high net worth individuals, trusts, endowments, foundations and institutions. Through the GoalLink Program, our firm serves as the primary investor contact, responsible for analyzing your current financial situation, return expectations, risk tolerance, time horizon, and asset class preference. Using the GoalLink Presentation Tool, together with our client we select an investment strategy ("Strategy") which is then submitted and reviewed by a representative of SIMC. The Strategy may include a combination of individual securities and mutual funds advised by SIMC (the "SEI Funds"), based upon your selected Strategy and account size.
To participate in the Program, our firm, SIMC and you, as the individual investor, execute a tri-party agreement ("Agreement") providing for the management of certain of your assets in accordance with the terms thereof. Pursuant to the Agreement, you appoint our firm as your investment adviser to assist you in selecting the Strategy. Based upon the selected Strategy, SIMC will have investment authority of the assets and will make prescribed adjustments to the Strategy weights based on the market environment at a point in time. However, you may, at any time, impose reasonable restrictions on the management of your account or choose a new Strategy. SIMC's investment authority is effective until changed or revoked in writing. SIMC may delegate its day-to-day responsibility for selecting particular securities to one or more sub-advisers.
The SEI Funds expenses are found in the Funds' prospectus, which you should read carefully before investing. For SIMC's fees on assets held in the separate accounts, the fees are determined based on the asset classes incorporated in your account. The following sets forth the fees charged by SIMC for each specific Strategy managed in the GoalLink Program.
The fees payable to SIMC for U.S. Large Cap Core/Tax Transition Strategy: 0.85% for the first $1 million 0.80% for the next $2 million 0.75% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Large Cap Growth, Value and Core Strategy: 9 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Managed Volatility/Tax-Sensitive Managed Volatility: 0.90% for the first $3 million 0.85% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Mid Cap Strategy: 1.10% for the first $1 million 1.00% for the next $2 million 0.90% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for U.S. Small Cap Strategy: 1.20% for the first $1 million 1.10% for the next $2 million 1.00% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for International Equity Strategy : 1.20% for the first $1 million 1.10% for the next $2 million 1.00% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Active Municipal Bond and Core Fixed Income Strategy: 0.70% for the first $1 million 0.65% for the next $2 million 0.60% for the next $2 million Negotiable for above $5 million The fees payable to SIMC for Laddered Bond Strategy: 0.30% for the first $500,000 0.27% for the next $500,000 0.25% for the next $1 million 0.20% for the next $3 million The fees payable to SIMC for Time Focused Fixed Income Strategy: 0.30% for the first $5 million Negotiable for above $5 million The fees payable to our firm are based on a range from 0.05% to 1.25%: 10 Additionally, the GoalLink Program offers IMAP, which is an enhancement to the standard GoalLink Program, as described above. The fee for IMAP covers the integration of the equity managers, which helps result in increased coordination across the equity account, increased tax efficiency and additional features such as wash sale prevention.
The fees payable to SIMC for the IMAP Feature are up to 0.10% of the total account value (excluding zero coupon assets managed by SIMC).
Under the GoalLink Program, you receive investment advisory services, the execution of securities brokerage transactions, custody services, and reporting services for a single specified fee. Participation in the GoalLink Program may cost you more or less than purchasing such services separately. In addition, the GoalLink Program fee may be higher or lower than that charged by other sponsors of comparable wrap fee programs.
SIMC's fees shall be a percentage of the market value of your account assets held in the Strategy. The annual fee for portfolio management services is billed quarterly in arrears (i.e., after services are rendered) based on the market value of client assets on the last day of the quarter.
Third-Party Investment Management Program In providing our discretionary management services, we may engage the services of Advyzon Investment Management LLC ("AIM") to manage all or a portion of your assets through its turnkey asset management program (the "Program"). When we do so, we will provide you with a copy of AIM's current Disclosure Brochure, Privacy Policy, and Form CRS ("AIM's Disclosure Documents"). You should read these documents carefully to be sure you understand the Program.
Using information we gather from you, we evaluate your financial situation, investment objectives, financial goals, tolerance for risk, and investment time horizon. This information helps us determine whether your participation in the Program is appropriate for you, and if so, allows us to choose an appropriate Investment Strategy for the management of your assets. Once we choose the Investment Strategy and allocate all or a portion of your assets to the Investment Strategy, AIM will provide ongoing discretionary management of your assets according to the mandate of the Investment Strategy.
Please note that if we engage AIM to manage your assets, AIM will obtain access to your confidential information from us and/or from the custodian of your brokerage account. As stated in our Privacy Policy, we are authorized to share your personal information with third parties as necessary to service your account. Our agreement with AIM includes provisions requiring AIM to hold your information in strict confidence, and to maintain reasonable technological protections, precautions, and safeguards your information.
Held-Away Assets We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System through Pontera to implement tax- efficient asset location and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. We use a third party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the platform in any way and receive no 11 compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary.
General Consulting Services We do not hold ourselves out as a financial planner, but we may provide general consulting services on securities and non-securities related investments. The scope of the services to be provided will be determined in advance of any services rendered, and will be clearly set forth in the executed agreement for services. Such services may include a review of your existing portfolio, the drafting/review of the investment policy statement, cash flow analysis, budget analysis, tax analysis, retirement analysis, education funding analysis, estate analysis, family legacy analysis and risk management analysis.
Advice is based on financial information you disclose to our firm at the time the consulting services are provided. Past performance is in no way an indication of future results. We cannot offer any guarantees or promises that your financial goals and objectives will be met. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our consulting recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the recommendation through any of our other investment advisory services.
We charge a fixed fee, which ranges between $500 and $15,000, for consulting services. The fee is based upon the scope and complexity of the services requested. In limited circumstances , the total cost could potentially exceed $15,000. In such cases, we will notify you in advance of rendering additional services and we may request that you pay an additional fee. Generally, fees are payable upon completion of the contracted services, or as invoiced.
You may terminate the consulting services at any time by providing written notice to our firm. Refunds are not applicable as fees are payable in arrears (i.e., after services are rendered).
Types of Investments We offer advice on equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities, U.S. Government securities, options contracts on securities, and interest in partnerships investing in real estate, private equity and private debt, among others. Additionally, we may recommend other types of investments since each client has different needs and different tolerances for risk. We may also advise you on any type of investment held in your portfolio at the inception of our advisory relationship, or on specific types of investments at your request.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the 12 following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of January 9, 2024, we provide continuous management services for $77,147,702 in client assets on a discretionary basis, and $153,922,121 in client assets on a non-discretionary basis.