RDA Financial Network, Inc. (RDAFN) is registered as an investment advisor with the
Securities and Exchange Commission since October 2008. RDAFN is notice filed in Iowa and
all other states where it conducts business and is required to be notice filed.
Investment Management Services - RDAFN provides Investment Management Services,
defined as giving continuous advice to clients based on their individual needs through RDAFN’s
Investment Management Services. RDAFN will obtain financial information from prospective
clients to determine the suitability of RDAFN’s Investment Management Services for prospective
clients and to determine the appropriate investment objectives that are specific for each client
account that is established with RDAFN.
Sub-Advisor Services - In some instances, Investment Management Services Accounts may
be managed by independent Sub-Advisors that have Sub-Advisory agreements with RDAFN. In
such circumstances, the Sub-Advisor will have discretionary power and trading authority for the
investment of the Account. RDAFN and IAR shall be responsible for making the suitability
determination in what investment strategy will be implemented in the management of Client’s
Account by Sub-Advisor. Sub-Advisor will also provide administrative services which may
include the calculating and processing for payment of advisory fees on behalf of RDAFN. Sub-
Advisor may perform other administrative duties on behalf of RDAFN.
Discretionary Trading - RDAFN, IAR or Sub-Advisor will buy, sell, exchange, convert, tender
and otherwise trade on a discretionary basis mutual funds, variable annuities and life contracts,
and the sub-accounts thereof, general securities including stocks, bonds, CMOs, REITs, ETFs,
unit investment trusts and other securities, and if authorized independently, to purchase or write
options to purchase or sell securities, consistent with investment analysis, interpretations and
judgments designed to seek an investment return suitable to the investment objectives and
goals of the Client, subject, however, to any limitations established by the Client and
acknowledged by RDAFN.
WRAP Fee Custodian/Broker-Dealer Arrangements - RDAFN shall consider a
number of factors including, without limitation, best execution, the overall direct net economic
impact on account assets (including commissions which may not be the lowest available, but
which will not be higher than the generally prevailing competitive range) the financial stability of
the Custodian/Broker-Dealer, the efficiency with which the transaction is effected, the ability to
effect the transactions where complicating factors are involved, the availability of the Custodian/
Broker-Dealer to stand ready to execute possible difficult transactions in the future, and other
matters involved in the receipt of brokerage and research services.
RDAFN has Wrap Fee Custodian/Broker-Dealer arrangements with Charles Schwab & C0.,
Inc. (Schwab) (Referred to as Custodian/Broker-Dealer)
RDAFN will recommend this Custodian/Broker-Dealer to clients for custody and brokerage
services. This Custodian/Broker-Dealer’s advisory accounts custody and brokerage services
are typically not available to retail investors. These benefits include the following products and
services (provided without cost or at a discount)
• Duplicate client statements and confirmations
• Research related products and tools.
• Consulting services.
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• Access to a trading desk serving advisor participants.
• Access to block trading (which provides the ability to aggregate securities
transactions for execution and then allocate the appropriate shares to client
accounts).
• The ability to have advisory fees deducted directly from client accounts.
• Access to an electronic communications network for client order entry and account
information; access to mutual funds with no transaction fees and to certain institutional
money managers.
• Discounts on compliance, marketing, research, technology, and practice
management products or services provided to RDAFN by third party vendors.
Some of the products and services made available by this Custodian/Broker-Dealer may
benefit RDAFN but may not directly benefit client accounts. These products or services may
assist RDAFN in managing and administering client accounts, including accounts not
maintained at this Custodian/Broker-Dealer. Other services made available by this
Custodian/Broker-Dealer are intended to help RDAFN manage and further develop its business
enterprise. The benefits received by RDAFN do not depend on the amount of brokerage
transactions directed to this Custodian/Broker- Dealer. Clients should be aware, however, that
the receipt of economic benefits by RDAFN or its related persons in and of itself creates a
potential conflict of interest and may indirectly influence RDADFN’s choice or recommendation
of this Custodian/Broker-Dealer for custody and brokerage services.
Trading – RDAFN allocates trades to clients in a fair and equitable manner that will be applied
consistently to all clients. Personal accounts of RDAFN, its investment advisor representatives,
associates and family members will not be treated more favorably than any other client
account. RDAFN will make every attempt to completely fill all block order trades. In the event
where there is a partial fill of the trade the trade will be allocated as follows: Small (100 share)
and odd lot positions filled in entirety then prorated across the remaining shareholders. All
variable annuities managed within the Investment Management Program by RDAFN will have
their variable annuity sub- account transactions processed through the Custodian of record for
the variable annuity.
Trading Error Corrections - It is RDAFN’s policy to ensure clients are made whole following a
trade error. Specifically, when a trade error occurs in a client account that results in a loss, the
responsible party will reimburse the client. The responsible party may include RDAFN, RDAFN
IARs, United Planners or a Custodian/Broker-Dealer. If the trade error was made in a client
account resulting in a gain of over $100.00, the client will keep the gain. If the gain is under
$100.00 Schwab will keep the gain If the trade error was made in a block trading account and
client funds were not at risk and the trade results in a gain, RDAFN will keep the gain unless
the Custodian/Broker-Dealer keeps the gain.
Additional Information on RDAFN’s Relationship with United Planners Financial Services
– United Planners and its clearing broker/dealers (Pershing LLC.) also make available to
RDAFN other products and services that benefit RDAFN but may not directly benefit its clients'
accounts. Some of these other products and services assist RDAFN in managing and
administering client accounts. These include software and other technology that provide access
to client account data (such as trade confirmation and account statements); facilitate trade
execution; provide research, pricing information and other market data; facilitate payment of
RDAFN's fees from its clients' accounts; and assist with back-office functions; record keeping
and client reporting.
Many of these services generally may be used to service all or a substantial number of
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RDAFN's accounts, including accounts not held through United Planners. Broker-Dealer and
Custodian fees, expenses, and commission charges are separate and distinct from the fee
charged by RDAFN.
Custody - All client accounts and assets are held by independent custodians. Under no
circumstances will RDAFN maintain custody of Client accounts or assets.
RDAFN’ only has custody to the extent it needs to have Advisory Fees deducted from client
accounts.
Investment Management Agreements Termination. Agreements
may be terminated by any
party to the Agreements by giving notice to the other party of termination. Agreements shall
also be terminated by closing the Client Account(s). In addition, Agreements shall be
terminated upon written notice from the Custodian that the authorization to deduct the Advisory
Fees from the Client Account(s) has been terminated. Any prepaid, unearned fees will be
refunded to Client on a pro-rata basis. There is no termination fee; however, the account(s)
may be subject to fees or charges related to transferring an account, or account closing costs
charged by the Custodian.
Doing Business As - Our business model is based on a network of Investment Advisor
Representatives (“IARs) with offices located in numerous states and cities. Although all IARs of
RDAFN are registered with, and subject to oversight and supervision by RDAFN, they operate
their businesses independently and some offices work under a separate business name or
“DBA”. IARs associated with RDAFN may provide IAR services to clients under a DBA name
that is owned and registered by the IAR or the group of IARs for which the DBA name
represents. As such, marketing materials provided to clients and potentials clients may include
the DBA name and may include a logo associated with the DBA name. RDAFN continues to
review and approve marketing materials related to the IAR or IA firm services offered and
provided to clients. RDAFN supervises IARs in the performance of their IAR duties whether the
services are performed under the IAR’s name, the DBA name, or the RDAFN name. If properly
disclosed as an outside business activity of the IAR, RDAFN allows IARs to provide other
products and services through their DBA so long as they are unrelated to RDAFN’s investment
advisor business. These outside business activities are not associated with or supervised by
RDAFN. Because all our IARs operate their businesses independently from one another, they
have significant flexibility in providing tailored individualized investment advice to clients.
RDAFN’s home office in Akron, Iowa, assists the IARs with marketing, back-office functions
and compliance responsibilities. A list of all the RDAFN approved DBA names can be found on
our Schedule D, Section 1.B. Other Business Names of our Form ADV Part 1 available on the
SEC’s Investment Advisor Public Disclosure websi
te at www.adviserinfo.sec.gov.
GENERAL ADVISORY SERVICES DISCLOSURES Investment Management -Assets Under
Management
RDAFN has $493,702,617.90 of assets under discretionary management in its
Investment Management Services as of December 31, 2023.
RDAFN has $0.0 of assets under non-discretionary management in its
Investment Management Services as of December 31, 2023.
RDAFN has $47,378,137.59 of assets under its Wrap Fee Management program as of
December 31, 2023.
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RDAFN’s Investment Management Fees - RDAFN manages client accounts for a
percentage of the assets under management. RDAFN charges an annualized Advisory Fee
that ranges up to 2.05%, depending on the size and complexity of the client account.
The initial Advisory Fee shall be calculated from the date on which assets or cash were first
deposited to the Account to the last day of the calendar quarter in which such deposits were
made (or, at RDAFN’s option, through the last business day of the next calendar quarter if the
date the account is accepted by RDAFN falls within 30 days prior to the beginning of a calendar
quarter). The Account Value for the purposes of calculating the initial Advisory Fee is the value
on the last day of the calendar quarter. If additional assets are deposited to the Account(s)
during a fee period, the client will be charged additional Advisory Fees based on the value of
the additional assets, prorated for the number of days remaining in such fee period.
The Advisory Fee will normally be charged on a quarterly basis, payable in advance, and will be
billed based on the value of the assets under management on the last day of the prior reporting
period. Debit balances due to the use of margin will be ignored for the purposes of calculating
fees. If an Account is opened by transferring assets from an existing RDAFN Account, then the
Advisory Fee will not be assessed until the beginning of the quarter following execution of this
Agreement. If an Account is closed by transferring assets to a new Account managed by
RDAFN or Sub-Advisor, then the Advisory Fee for the quarter shall not be prorated to the date
of transfer.
Sub-Advisors - RDAFN will compensate Sub-Advisors up to 1.05% for their investment
management services and administrative services for sub-advised accounts. Sub- Advisor
compensation may increase client’s Advisory Fees.
RDAFN’s Fiduciary Oath - RDAFN and RDAFN’s IARs must adhere to a fiduciary
standard of care that requires RDAFN and RDAFN’s IARs to act and serve in the client's
best interests with the intent to eliminate, or at least to expose, all potential conflicts of
interest which might incline them—consciously or unconsciously—to render advice which
was not in the best interest of their clients.
RDAFN’s Proprietary Strategies Fees – RDAFN proprietary strategies have a
maximum fee allowable of 2.05%.
General Investment Management Fee Disclosures - Client may have Advisory Fees paid from other
accounts or custodians, or be billed directly by invoice, in such cases Advisory Fee deductions will be
noted as zero on the client’s monthly Custodian statements.
Clients may incur certain charges imposed by third parties other than RDAFN, in connection
with investments placed in a managed account, including but not limited to:
• IRA and Qualified Retirement Plan Fees
• Other custodial fees
• Mutual fund and variable annuity internal expenses, commissions, sales loads,12(b)-
1 fees, trail fees and surrender charges.
Some advice offered by the IARs may involve investments in mutual funds and variable annuity
products which pay 12b-1 trail fees. RDAFN prohibits IARs from collecting both a fee for
investment advisory management, and any 12b-1 trail fees associated with their clients
investing in such products. Clients should be aware that the payment and receipt of 12b-1 trail
fees do exist, and that other entities may collect such fees.
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RDAFN and IARs may in some instances receive other advantages from these entities in the
form of soft dollars to help cover technology costs, thus creating a potential conflict of interest.
Advisory Fees paid by clients in RDAFN’s Wrap Fee Program may be more than the cost of
purchasing the same services separately or similar services elsewhere. RDAFN’s Wrap Fee
Program Advisory Fees are negotiable.
MARKETING SOFT DOLLARS - RDAFN Advisors may receive a portion of fees paid to sub-
advisors to be used for marketing purposes. This may create a conflict of interest in where an
IAR may encourage the use of one of these participating strategists over other approved sub-
advisors. Currently, RDAFN does not have any existing relationships to disclose.
RDAFN Miscellaneous Technology Fee – RDAFN advisors may choose to charge each client
account at their discretion a miscellaneous technology fee. This fee helps defray the growing
costs of technology and cyber security expenses associated with the maintenance of your
account(s). Each advisory account may be charged a yearly miscellaneous technology fee not
to exceed $150.00 USD. This fee will be debited directly from each account agreed to by both
IAR and client in writing on RDAFN’s Agreement for Investment Managements Services Exhibit
A form in advance on a quarterly basis. Any technology fee will not be refunded.