(A) Introduction to Riverview Capital Advisers, LLC
Riverview Capital Advisers, LLC, a Massachusetts limited liability company formed in 2006
(hereinafter "RCA" or “Riverview”), is a federally registered investment adviser, providing
various investment supervisory services to a variety of clients.
1 Riverview is owned by Alan
Arcadipane and Paula Pienkowska and principally managed by Paula Pienkowska.
(B) Service Options
RCA provides three service options:
1. Investment Management Services
2. Family Office Services
3. Business Advisory Services
After reviewing the particular services available under each option (summarized below), clients
select the service option(s) that they determine will best meet their needs. Each advisory client
must sign an Investment Advisory Agreement ("Advisory Agreement") to reflect the choice(s)
made and the manner in which RCA will be compensated for the service(s) selected.
I. INVESTMENT MANAGEMENT SERVICES
RCA provides Investment Management Services, which grant discretionary authority to
RCA, for clients who choose this option to provide direct and indirect management as
summarized below. Assets are managed in each individual client's account according to such
client's stated goals and objectives, as set forth in the client's Investment Policy Statement, or as
amended by the client from time to time. For client accounts utilizing this service, RCA has
discretion to use the services of third-party portfolio manager(s) to meet each client's specific
needs. Such third-party portfolio manager(s) may have discretion to handle the day-to-day
investment management of the respective portion of client’s account(s).
In providing Investment Management Services, RCA and RCA Investment Adviser
Representative (“RCA Adviser”) will furnish supervisory and management services over client
account(s) through analysis of client investment goals, needs, objectives, and restrictions, as
identified by the client from time to time.
RCA provides direct management and security selection for each account for clients
selecting this service and/or oversight of third-party portfolio manager(s), provider(s) and/or sub-
advisor(s) selected to provide service(s) for client's account(s).
In the exercise of its discretion, RCA may place client account(s) in whole or in part with
1 Registration with any state or federal regulator does not imply a certain level of skill or training and does not imply
any endorsement by a state or federal regulatory authority.
third party portfolio manager provider(s) and/or sub- advisor(s) who will manage assets on behalf
of RCA. RCA will monitor the performance of such third-party portfolio manager(s) and charge
fees for its Investment Management Services.
With respect to the execution of any transactions involving assets in a client's account, a
client authorizes RCA and RCA Adviser to issue brokerage instructions to purchase, sell and to
otherwise trade in or deal with any security in that account. Brokerage confirmations are
forwarded by the broker promptly after execution of transactions.
II. FAMILY OFFICE SERVICES
In addition to Investment Management Services, RCA offers Family Office Services that
generally include, but are not limited to, financial planning, retirement planning, tax planning
and coordination with tax and accounting professionals, bookkeeping, estate and wealth transfer
planning, charitable planning and administration, consultation on insurance needs, and family
business continuity and succession planning.
RCA offers these services
to individuals, families, trusts, and business entities. This is generally
a combination of discretionary and non-discretionary services. As part of these services, RCA
may provide cash flow, retirement, education and estate analysis, stock option planning,
compensation and bonus analysis, real estate analysis, family consulting, and legacy planning to
clients based upon their specific objectives.
These services may be provided independently or as part of comprehensive Family Office
services. RCA does not provide legal and tax drafting and filing and tax form preparation. RCA
encourages each client selecting this service option to seek the advice of an accountant, tax
planner, attorney or other professional for any tax drafting, filing, or legal advice.
In general, RCA’s Family Office Services seek to identify client's short, intermediate, and multi-
generational objectives, with consideration for each client's investment objectives for the short
and long term, client's risk tolerance, client's assets and liabilities, and other information the
client believes might be helpful or pertinent to RCA. The RCA Adviser takes the information
supplied by the client and performs lengthy financial analysis to determine the components of the
plan and the basis for the RCA Adviser's recommendations. Finally, the RCA Adviser provides
the client with recommendations designed to meet the client's objectives, risk tolerance, and
investment criteria.
III. BUSINESS ADVISORY SERVICES
RCA Business Analysts, in conjunction with third party consultants, can assist in
strategic forecasting, financial modeling, marketing and sales evaluation, executive incentives,
and succession planning. RCA takes a holistic approach in providing a blueprint for evaluating,
executing, and amending a strategy that fits the organization’s needs, whether it is a startup or
established firm.
RCA may refer and work directly with other third-party specialists including record
keeping services, payroll administration, employee benefits, bill pay services, accounting and tax
preparation, private banking and lending, and residential and commercial mortgage and
refinancing. Where services require outside professionals the client may receive a separate
invoice in addition to the fees described in Item 5 below.
IV. OTHER SERVICES
From time to time, a client may approach RCA to perform services not specifically enumerated
herein. RCA may undertake to accommodate clients by providing such services.
(C) Clients must provide accurate and complete information identifying client's investment
objectives, risk tolerance and investment restrictions, if any, and other like information, as the
intent is to tailor recommendations and strategies to address client-identified objectives and
incorporated client-specified restrictions. It is client's responsibility directly or through their
RCA Adviser to notify RCA if client wishes to change their previously identified investment
objective(s) and/or strategy.
(D) RCA does not participate in wrap fee programs.
(E) As of December 31, 2023, RCA has the following assets under management:
Discretionary Non-Discretionary TOTAL
$495,776,172 $31,697,576 $527,473,748
In addition to the assets reported immediately above, as of December 31, 2023, RCA also had
assets under advisement totaling approximately $1,771,453,462. These are client assets that RCA
oversees as part of the overall core investment management strategy but does not manage on a
discretionary basis. The combined total of Regulatory Assets Under Management and Assets
Under Advisement is approximately $2,298,927,210.