Description of Advisory Firm
Signature Resources Capital Management, LLC (“SRCM,” “we,” “our,” or “us”) is a privately owned Limited Liability
Company headquartered in Newport Beach, California. SRCM was founded in April 2007, and in June 2007, we started
operating as an investment adviser registered with the U.S. Securities and Exchange Commission. Beverly Kaltenbach,
Geoffrey Kaltenbach, Gregory Kaltenbach and Mark Mowrey are the principal owners of the firm.
SRCM is an independent fee-only investment and financial advisory firm. We do not offer any proprietary products
and do not maintain any inventory, which means we are able to offer independent, objective wealth and investment
management solutions.
Mission Statement
Our mission is to bring efficient and decisive financial advice to affluent families and provide the most satisfying client
experience in America.
Vision Statement
Our vision is to create experiences that combine our expertise with our client’s collaborative input to deliver quality,
professional and independent advice.
Advisory Services Offered
SRCM provides investment advisory and investment management solutions to retail investors, including financial,
retirement and estate planning services. Advisory solutions comprise a range of services and deliverables, including
fact-finding and informational conversations with the client’s advisor, reports on progress toward financial goals and
interactive tools to examine potential future scenarios. The firm also provides Retirement Plan Services.
SRCM also conducts business practices offered through other business names, which are disclosed through separate
Form ADV, Part 2A filings.
Investment Management
We provide Investment Management services (“investment solutions,” “portfolio management,” “Portfolios” and
“models”) to our clients on a discretionary basis. The Investment Management service includes, among other things,
providing advice regarding asset allocation and/or the selection of investments.
Our investment advisory and management solutions seek to incorporate client investments into broader strategies that
target near- and long-term financial goals. When working with clients to resolve suitable investment portfolios, the
solutions we develop seek to address what we believe to be the most important factor determining client investment
outcomes—client comfort with exposure to investment risk.
The Investment Team (“Team”) manages client engagements on an individual basis, with decisions guided by unique
client objectives and restrictions. To facilitate the investment management process, the Team maintains a range of
investment models built to provide specific exposures to investment risk. Each model is customizable to specific client
situations. This approach should allow our advisors to address current client investment scenarios, while enabling
flexible adaptation to any changes to those scenarios as they may occur over time.
Clients are responsible for informing us of any changes to their investment objectives, risk profile, financial status
and/or restrictions. We do not assume any responsibility for the timeliness or accuracy of the information provided by
the client.
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Portfolio decisions we direct generally include investments in mutual funds and exchange traded funds (ETFs) that
represent both equity (stocks), fixed income (bonds) and other asset classes. SRCM remains flexible in accommodating
individual client needs and restrictions at the initiation of the relationship and as they might evolve over time.
Additionally, depending on the individual investment objectives and needs of the client, SRCM occasionally will offer
advice regarding additional types of investments if they are appropriate to address the individual needs, goals, and
objectives of the client or in response to client inquiry. As needed, SRCM will offer investment advice on investments
held by the client at the start of and during the advisory relationship.
We describe the material investment risks for many of the securities that we recommend under the heading Specific
Security Risks in Item 8 below.
Sub-Advisory Relationships
SRCM, doing business as Statera Asset Management, provides sub-advisory services through a turnkey asset
management program (“TAMP”) offered by Envestnet Asset Management. SRCM provides to Envestnet “model” target
asset allocations across a series of portfolios. SRCM receives compensation for providing these model portfolio
allocations that is comprised of an asset-based fee accrued quarterly based on the market values of the client portfolios
managed by Envestnet as of the last day of each quarter.
SRCM does not directly manage accounts as part of a wrap or bundled fee program.
Discretionary Accounts
We discuss discretionary authority below under Item 16 – Investment Discretion. For more information about the
restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in this item below.
We describe the Fees charged for investment management services below under Item 5 – Fees and Compensation.
Limited-Discretionary & Non-Discretionary Accounts
SRCM also offers investment management services to clients on a limited-discretionary basis and non-discretionary
basis. See also Item 16 – Investment Discretion below.
Employer-Sponsored Retirement Plans and Their Participants
SRCM offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory Services
and (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their participants. Depending
on the type of the Plan and the specific arrangement with the Sponsor, we may provide one or more of these services.
Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2 along with a copy of our Privacy
Policy and Advisory Agreement (“Agreement”) that contains the information required under Sec. 408(b)(2) of the
Employee Retirement Income Security Act (“ERISA”) as applicable.
The Agreement authorizes our Investment Adviser Representatives (“IARs”) to deliver one or more of the following
services:
Discretionary Investment Management Services
These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring and disposing
of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 (“ERISA”). We
will perform these investment management services through our IARs and charge fees as described in this Form ADV
and the Agreement. If the Plan is subject to ERISA, we will perform these services as an “investment manager” as
defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically,
the Sponsor may determine that we perform the following services:
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Selection, Monitoring and Replacement of Designated Investment Alternatives (“DIAs”)
Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor
an IPS that contains criteria from which Advisor will select, monitor and replace the Plan’s DIAs. Once the IPS is
approved by Sponsor, Advisor will review the investment options available to the Plan and will select the Plan’s DIAs
in accordance with the criteria set forth in the IPS. On a periodic basis, Advisor will monitor and evaluate the DIAs and
replace any DIA(s) that no longer meet the IPS criteria.
Selection, Monitoring & Replacement of Qualified Default Investment Alternatives (“QDIA(s)”)
Based upon the options available to the Plan, Advisor will select, monitor and replace the Plan’s QDIA(s) in accordance
with the IPS.
Management of Trust Fund
Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to Sponsor
an IPS that contains criteria from which Advisor will select, monitor and replace the Plan’s investments. Once approved
by Sponsor, Advisor will review the investment options available to the Plan and will select the Plan’s investments in
accordance with the criteria set forth in the IPS. On a periodic basis, Advisor will monitor and evaluate the investments
and replace any investment(s) that no longer meet the IPS criteria.
Non-Discretionary Fiduciary Services
These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan.
We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary investment
advisory services through our IARs and charge fees as described in this Form ADV and the Agreement. If the Plan is
covered by ERISA, we will perform these investment advisory services to the Plan as a “fiduciary” defined under ERISA
Section 3(21). The Sponsor may engage us to perform one or more of the following Non-Discretionary investment
advisory services:
Investment Policy Statement (“IPS”)
Advisor will review with Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not
have an IPS, Advisor will provide recommendations to Sponsor to assist with establishing an IPS. If the Plan has an
existing IPS, Advisor will review it for consistency with the Plan’s objectives. If the IPS does not represent the objectives
of the Plan, Advisor will recommend to Sponsor revisions to align the IPS with the Plan’s objectives.
Advice Regarding Designated Investment Alternatives (“DIAs”)
Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the investment options available
to the Plan and will make recommendations to assist Sponsor with selecting DIAs to be offered to Plan participants.
Once Sponsor selects the DIAs, Advisor will, on a periodic basis and/or upon reasonable request, provide reports and
information to assist Sponsor with monitoring the DIAs. If a DIA is required to be removed, Advisor will provide
recommendations to assist Sponsor with replacing the DIA.
Advice Regarding Qualified Default Investment Alternative (“QDIA(s)”)
Based on the Plan’s IPS or other guidelines established by the Plan, Advisor will review the investment options available
to the Plan and will make recommendations to assist Sponsor with selecting or replacing
the Plan’s QDIA(s).
Participant Investment Advice
Advisor will meet with Plan participants, upon reasonable request, to collect information necessary to identify the Plan
participant’s investment objectives, risk tolerance, time horizon, etc. Advisor will provide written recommendations
to assist the Plan participant with creating a portfolio using the Plan’s DIAs or Models, if available. The Plan participant
retains sole discretion over the investment of his/her account.
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Advice Regarding Investment of Trust Fund
Based on the Plan’s IPS, Advisor will review the investment options available to the Plan and will make
recommendations to assist Sponsor with selecting investments that meet the IPS criteria. Once Sponsor selects the
investment(s), Advisor will, on a periodic basis and/or upon reasonable request, provide reports and information to
assist Sponsor with monitoring the investment(s). If the IPS criteria require any investment(s) to be replaced, Advisor
will provide recommendations to assist Sponsor with replacing the investment(s).
Retirement Account Advice
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 Securities Act (“ERISA”) and/or
the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of our
advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. For
example, if we recommend that you roll over assets from one retirement account to another and we will receive
increased compensation as a result of that recommendation, we have a conflict that requires us to operate under this
special rule.
Retirement Plan Consulting Services
Retirement Plan Consulting Services are designed to allow our IARs to assist the Sponsor in meeting his/her fiduciary
duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement Plan Consulting
Services are performed so that they would not be considered “investment advice” under ERISA. The Sponsor may elect
for our IARs to assist with any of the following services:
Administrative Support
Assist Sponsor in reviewing objectives and options available through the Plan
Review Plan committee structure and administrative policies/procedures
Recommend Plan participant education and communication policies under ERISA 404(c)
Assist with development/maintenance of fiduciary audit file and document retention policies
Deliver fiduciary training and/or education periodically or upon reasonable request
Recommend procedures for responding to Plan participant requests
Service Provider Support
Assist fiduciaries with a process to select, monitor and replace service providers
Assist fiduciaries with review of Covered Service Providers (“CSP”) and fee benchmarking
Assist with preparation and review of Requests for Proposals and/or Information
Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
Periodic review of investment policy in the context of Plan objectives
Assist the Plan committee with monitoring investment performance
Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s)
Participant Services
Facilitate group enrollment meetings and coordinate investment education
401(k) Consulting
SRCM provides services to 401(k) plans. Services include monitoring plan options and providing education to plan
participants.
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We describe fees charged for 401(k) services below under Item 5 – Fees and Compensation.
Potential Additional Retirement Services Provided Outside of the Agreement
In providing Retirement Plan Services, SRCM and its IARs may establish a client relationship with one or more Plan
participants or beneficiaries. Such client relationships develop in various ways, including, without limitation:
1. as a result of a decision by the Plan participant or beneficiary to purchase services from SRCM not involving
the use of Plan assets;
2. as part of an individual or family financial plan for which any specific recommendations concerning the
allocation of assets or investment recommendations relating to assets held outside of the Plan; or
3. through a rollover of an Individual Retirement Account (“IRA Rollover”).
If SRCM is providing Retirement Plan Services to a plan, IARs may, when requested by a Plan participant or beneficiary,
arrange to provide services to that participant or beneficiary through a separate agreement. If a Plan participant or
beneficiary desires to affect an IRA Rollover from the Plan to an account advised or managed by SRCM, IAR will have
a conflict of interest if his/her fees are reasonably expected to be higher than those paid to SRCM in connection with
the Retirement Plan Services. IAR will disclose relevant information about the applicable fees charged by SRCM prior
to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain that
of the Plan participant or beneficiary alone.
In providing these optional services, we may offer employers and employees information on other financial and
retirement products or services offered by SRCM and our IARs.
Financial Planning and Consulting Services
SRCM’s primary service offering is Investment Management Services, which may include estate and/or financial
planning as components. However, we also offer stand-alone Financial Planning and Consulting Services. SRCM offers
a range of Financial Planning Services, from broad planning to custom planning focused on specific areas requested by
the client. SRCM provides general non-securities advice on topics that may include tax and budgetary planning, estate
planning and business planning. Our Financial Planning Services do not include preparation of any kind of income, gift
or estate tax returns nor preparation of any legal documents, including wills or trusts. We do not offer tax or legal
advice of any kind.
We offer both Financial Planning Services and Investment Management Services. When preparing a financial plan, we
may have an incentive to recommend our Investment Management Services. Additionally, a number of our personnel
hold insurance and brokerage licenses. When preparing a financial plan, we may have an incentive to recommend
insurance or brokerage products for which we or any of our personnel earn a separate fee or commission. However,
Financial Planning Services clients are under no obligation to act upon any recommendations of SRCM or to effect any
transactions through SRCM or any of our personnel if they decide to follow the recommendations. For additional
information on insurance and brokerage licenses, please see Item 10 – Other Financial Industry Activities and Affiliations.
We describe fees charged for financial planning services below under Item 5 – Fees and Compensation.
Limitations on Investments
In some circumstances, SRCM’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event SRCM is managing assets within a retirement plan such as 401(k), 403(b) or other employer plan, SRCM
is limited to those investment providers and investment options chosen by the plan administrator. When we provide
services to participants in an employer-sponsored plan, the participant may be limited to investing in securities included
in the plan’s investment options.
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Limitation by Client
SRCM may also limit advice based on certain client-imposed restrictions. For more information about the restrictions
clients can put on their accounts, see Tailored Services and Client Imposed Restrictions directly below.
Tailored Services and Client Imposed Restrictions
SRCM manages client accounts according to a defined investment strategy, as discussed below under Item 8 – Methods
of Analysis, Investment Strategies, and Risk of Loss. SRCM applies the strategy for each client in a manner appropriate to
the client’s individual circumstances and financial situation. SRCM makes investment decisions for clients based on
information the client supplies about their financial situation, goals and risk tolerance, among other details. Investment
recommendations will be limited if the client does not provide accurate and complete information. It is the client’s
responsibility to keep SRCM informed of any changes to their investment objectives or restrictions.
Clients have the option to request other restrictions on the account. Such restrictions may include a minimum level of
cash in the account and/or the exclusion of certain specific securities or security types in the account. SRCM reserves
the right to not accept and/or terminate management of a client’s account if the client-imposed restrictions would limit
or prevent proper implementation of the client’s investment strategy.
When providing investment fiduciary services, SRCM may tailor advice or (if applicable) discretion to meet the
investment policies or other written guidelines adopted by the Sponsor. When providing Participant Investment
Advice, such advice will be based on the investment objectives, risk tolerance and investment time horizon of each
individual Plan participant.
Client Assets
Regulatory Assets Under Management are calculated the same for Form ADV Part 1 and Part 2A. These figures include
all fee paying and non-fee paying (generally employees, family members and friends, among others) accounts to whom
we provide our portfolio management services as of the date indicated.
SRCM manages client assets in discretionary accounts on a continuous and regular basis. As of 12.30.2022, the total
amount of discretionary assets under our management was $207,518,843.
Assets Under Advisement (“AUA”)
SRCM also provides investment recommendations to various third-party platforms, which in turn implement our
advice to retail clients on their platforms. As of 12.30.2022, our total AUA was $171,146,255.