RFG Advisory provides Clients with a wide array of investment advisory services. We specialize
in Portfolio Management, Financial Planning, Consulting, Referrals to Third-Party Money
Managers, Retirement Plan Consulting, Financial Wellness and Education Services. Our firm is a
limited liability company formed in the State of Alabama in business as an investment advisor
since 2011 and is owned as follows:
As of September 15, 2023, is 100% owned by RFG Holdings. RFG Holdings is owned, directly
or indirectly, by Bobby White, Shannon Spotswood, Rick Wedell, and investment vehicles
controlled by Long Ridge Equity Partners.
Description of the Types of Advisory Services We Offer
Clients may select from a variety of investment advisory services including Portfolio Management,
Financial Planning, Consulting, unaffiliated Third-Party Money Management, Retirement Plan
Consulting and Education Services. Our firm provides services to Clients through individuals
registered as investment adviser representatives (“IARs”), which the Firm refers to as “Financial
Advisors” and are subject to the Firm’s supervisory oversight.
RFG Advisory maintains agreements with Schwab Advisor Services (“Schwab”) and Fidelity
Investments (“Fidelity”) that we recommend through which Clients may choose where to custody
their advisory assets. The Custodian chosen by the Client does not have discretionary authority
over assets. The Client grants discretion to RFG Advisory through execution of one of the RFG
Advisory Discretionary Agreements.
RFG Advisory provides advisory services to certain retirement plan participants. When we render
investment advice, including rollover advice, to Clients regarding their retirement plan account,
HSA, ESA, individual retirement account, and employee benefit plans, we are fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and the Internal
Revenue Code, which are laws governing retirement accounts. As such we must act “with the care,
skill, prudence and diligence under the circumstance then prevailing that a prudent person acting
in a like capacity and familiar with such manners would use in the conduct of an enterprise of a
like character with like aims”.
We regularly provide advisory services to retirement plans (including, 401(k) plans, 403(b) plans
and other profit-sharing plans) and the fiduciaries of those plans. In providing these services and
as part of our normal course of business, we act as a non-discretionary co-fiduciary under ERISA
§3(21). RFG nor its Financial Advisors provide ERISA §3(16) or §3(38) services. We require each client
to select services in writing as part of the Retirement Plan Consulting Services Agreement with such
plan which sets forth the rights and obligations of each party. This agreement also states the
negotiated fee or fee structure for each client.
The way we make money creates some conflicts with the Client’s interests because it is in RFG’s
interest to recommend a rollover since we will earn an advisory fee. Therefore, we operate under
the prescriptions of DOL PTE 2020-02 that requires us to act in the Client’s best interest and not
put our interest ahead of a Client’s. Under this 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 the Client’s when making recommendations
(give loyal advice);
• Avoid making any misleading statements about conflicts of interest, fees, and
investments;
• Give advice that is in the Client’s best interest;
• Charge no more than is reasonable for our services; and
• Disclose conflicts of interest and manner of mitigation or elimination.
In performing our services, we sometimes rely on information received from clients or from other
professionals hired by clients. In such cases, we are not, nor can we, verify or audit the accuracy
of such information. However, we will make reasonable inquiries about the information for the
avoidance of any doubts, in accordance with our fiduciary duty. If requested, we will recommend
the services of other professionals for non-advisory services but not before disclosing any
associated conflicts that may exist or arise. Our clients are never under any obligation to accept
such recommendation.
Clients are advised that the same or similar programs or services as those described herein may
be available from other investment advisors for an annual fee lesser or greater than set forth
herein, and that the programs described in this brochure may cost the Client more or less than
purchasing the different services within each program separately depending upon such factors as
trading activity, account size, portfolio management fees, mutual fund expenses, complexity of
financial situation, etc.
Clients will need to complete the necessary advisory account documents required by their
custodian, by RFG Advisory and by their Third-Party Manager (where applicable).
Clients at Schwab and Fidelity have the option to hold a position(s) otherwise referred to as a
non-managed or excluded asset(s) inside a managed discretionary account. This is a Client
accommodation only with no asset management or advisory fees charged on the non-managed
asset(s).
We also provide 10b5-1 trading plans, which are advised upon and managed as a non-
managed asset.
Financial Advisors will reasonably be available for consultation with Clients regarding the
management of their account(s). Financial Advisors are responsible for the management and
review of Client’s advisory accounts on an ongoing basis. Additionally, periodic reviews and
surveillance are performed by the RFG Advisory compliance team.
Available Programs
A. Portfolio Management
Our Portfolio Management service encompasses discretionary asset management. This service is
designed to assist Clients in meeting their financial goals using financial investments. Financial
Advisors will conduct at least one, but sometimes more than one meeting (in person, by telephone,
video conference, or via email) with Clients to understand their current financial situation, existing
resources, financial goals, tolerance for risk and overall investment objective. Based on those
findings, the Financial Advisor will propose an investment approach to the Client and the Client
will have an opportunity to place reasonable restrictions on the types of investments to be held in
the discretionary investment portfolio.
RFG Advisory provides advisory services to Clients who are participants in unaffiliated employer
sponsored 401(k), HSA, 403(b), 401(a), and 457 Plans. These accounts are managed through
RFG’s employee plan participant platform referred to as “Connect” through the technology
platform offeror Pontera. Clients link their existing employee retirement account to the employee
plan participant platform and receive discretionary advisory services from their selected Financial
Advisor through the selection of captive investment options made available exclusively by the Plan
and transmitted to the Plan administrator for execution.
Clients who participate in Connect are exclusively subject to the investment options made available
by their respective employer Plan. The investment options available may be limited to higher cost
mutual funds than could be obtained through a self-directed brokerage option or window, if
available within the employer Plan. RFG Advisory will not be responsible for determining whether
the Client should open a self-directed brokerage option or window if a feature of their employer
sponsored retirement plan. That decision remains with Client, although RFG will discuss that option
at the Client’s request.
• The investment approach, guidelines and restrictions will form the investment plan of
the account. Upon the Client’s agreement with the Financial Advisor to the proposed
investment plan, the Financial Advisor will work with the Client to establish the Pontera
inlay for investment management account(s).
• Once the relevant accounts are under our management, the Financial Advisor reviews
such accounts at least annually with the Client. Financial Advisors may periodically
rebalance or adjust Client accounts based upon a variety of circumstances. If the Client
experiences any significant changes to his/her financial or personal circumstances, the
Client must notify us so that we can consider such information in managing the Client’s
investments.
B. RFG Advisory Bluemonte - model investment strategies:
Client accounts at Fidelity and Schwab in RFG Advisory model investment strategies are managed
on a discretionary basis. The Financial Advisor will have discretion selecting the appropriate
strategy consistent with the Client’s stated investment objective(s) and risk tolerance. These
strategies consist of Mutual Funds, Fixed Income, Equities, Exchange Traded Funds, Options,
Structured Notes, Alternative Investments and advisory variable annuities.
Select
The Select portfolios are selected, managed, and traded by the RFG Investment Team, led by
our Chief Investment Officer Rick Wedell. These portfolios are strategic asset allocations with
mild active tilts. We manage our exposure to different asset classes via sleeves which enables
us to offer over 60 different model combinations that are appropriately arranged to meet the
specific needs of clients. All our investments begin with a focus on risk. We constantly seek to
define the risks that we are exposed to and work to ensure that they are appropriate for the
client’s investment objective. We begin our portfolio construction process by identifying the key
investment themes that we wish to express, and then we carefully select a mix of securities that
reflect those ideas. We simultaneously seek to diversify and minimize our exposure to risk
factors where we do not have abundant information or conviction in taking. We utilize a wide
range of securities through active and passive management styles. We do not attempt to time
the markets but look to actively re-balance our client accounts as they drift beyond acceptable
or predetermined thresholds.
ETF Models
The Select portfolios are low cost, ETF drive portfolios that express the top-down views of the
investment team. These portfolios feature the following:
• No trading fees assuming the client elects certain options at our custodians (e.g.
electronic delivery of statements)
• Trading for contributions, distributions, account setup, model changes, etc.
• Periodic rebalancing as markets move
• Tax efficiency for non-qualified accounts – periodic tax loss harvesting and ETF structure
with no pass throughs
• Low internal expense ratios averaging between .1%-.25%
Mutual Fund Models
The portfolios are comprised of ETF’s and actively managed mutual funds in a strategic, top-
down approach that reflect the views of the investment team. These portfolios feature the
following:
• Our team’s highest conviction picks in terms of active managers in the industry
• Minimal trading costs using asset-based pricing at our custodians
• Trading for contributions, distributions, account setup, model changes, etc.
• Periodic rebalancing as markets move
• Periodic tax loss harvesting
• Internal expense ratios ranging from .4%-.7% depending on model selected
Direct Indexing
Direct indexing is a tax efficient method of portfolio construction. Our investment team
facilitates account set up, implementation, go forward monitoring and reporting as it relates to
direct index investing.
• A non-qualified account is selected for management
• Our team selects a series of indices to align to the performance of the account being
replicated on a pre-tax basis
o Indices can be selected with different weightings, including domestic,
international, fixed income, etc.
o The allocation of the various indices will align with the client’s risk tolerance and
suitability
• Once the target portfolio allocation has been identified, our team can select how
frequently the account is traded for various tax budgets, tracking errors, and other
characteristics
• The strategy drives trades in individual equities and fixed income ETF’s to
o Replicate as close as reasonably possible the gross performance of the target
portfolio
o Tax loss harvest routinely to deliver net of tax results targeted to exceed the
original portfolio’s non-managed performance
• Results are reported in a manor that identifies not only the gross and net returns of
the account, but also how much the client has been able to realize in tax savings as a
result of the strategy
CAIS
Our partnership with CAIS allows us to offer a curated selection of private investment options
and structured notes in an advisory structure. All of these investments have been vetted and
screened by CAIS, Mercer Research and the RFG Investment team. The CAIS platform provides
initial client suitability pre-qualifications, diligence materials, selection and implementation of
the actual investments. We offer a wide range of products across a number of different asset
classes to sophisticated investors with the requisite investing experience to understand these
types of higher risk investment products.
SmartX
SmartX provides our Advisors with access to over 1,000 different prescreened managers,
models, and strategies via a multi-strategy Unified Managed Account or single strategy
Separately Managed Account format, across a broad range of styles. Single name equities,
ETF’s, Mutual Funds, and other investment types can be managed tactically (active asset
allocation), passively or under special circumstances. Plus, clients have the option to combine
multiple managers into a single account. Once on the platform, SmartX handles the trading and
operations of the account under the management of the RFG Financial Advisor and Investment
Management team.
Blueprint
RFG Financial Advisors who select investment models on behalf of clients can leverage the skill
sets of the RFG Investment Management team to provide investment and compliance oversight,
and trading services while serving as discretionary
portfolio managers. With Blueprint, Financial
Advisors are able to build models using a broad list of RFG Advisory curated mutual funds and
ETF’s supported through our risk scoring system. Once these models are built, clients are
assigned and the Investment Management team takes over trading, oversight, operations and
cash management.
C. Use of Third-Party Management Platforms (sub-advisor):
Financial Advisors have discretion to place Client accounts under other registered investment
adviser’s Third-Party management platforms with RFG’s custodians outside of RFG Advisory
Bluemonte’s model investment strategies through SMArtX.
Certain Financial Advisors place Client accounts with other unaffiliated (third-party) registered
investment adviser’s management platforms that their clients had relationships with prior to
affiliating with RFG that are outside of SMArtX platform. These accounts may not be custodied at
RFG Advisory’s selected custodians Charles Schwab or Fidelity but still provide data for RFG
Advisory’s compliance, surveillance, and reporting purposes. While some of these accounts are
held at qualified custodians other than those selected by RFG Advisory, they receive the same
oversight and surveillance as all other client accounts. They subject to ongoing due diligence to
reasonably ensure these managers are acting in the clients’ best interest.
In these instances, the Financial Advisor is responsible for assisting the Client in setting an
appropriate investment objective based on the client’s goals and risk tolerance, selecting an
appropriate asset allocation model portfolio from those available under the applicable platform,
and providing ongoing monitoring and review of the Client account. The Third-Party Manager is
responsible for individual security selection, trading, and portfolio rebalancing. Details related to
Third-Party Management platforms are disclosed in advance of any such engagements. Financial
Advisors will review Third-Party Money Manager reports provided to the Client at least annually.
The Financial Advisor will also contact Clients from time to time to review their financial situation,
stated investment objectives and risk tolerance; communicate information to the money manager
as warranted and assist the Client in understanding and evaluating the services provided by the
Manager. Clients are expected to notify RFG Advisory of any changes in their financial situation,
investment objectives, or account restrictions that could affect their financial standing.
RFG Advisory does perform routine due diligence of the Third-Party Management platforms
relating to investment methodology, compliance procedures, cyber security programs, privacy
policy, and related matters.
D. Referrals to Third-Party Money Managers (promoter):
Financial Advisors who prior to affiliating with RFG Advisory had client accounts managed by
unaffiliated (third-party) Money Managers and can continue to recommend existing and new
clients to them. In these instances, RFG Advisory is acting as a Promoter (Solicitor), with investment
advice and the trading of securities being provided by or through, the chosen Third-Party Money
Manager. Our firm will not offer advice on any specific securities or other investments in connection
with this service. Prior to referring Clients to Third-Party Money Managers, our firm will conduct
due diligence on the Money Managers being used. To assist in the selection of a Third-Party Money
Manager, the Financial Advisor will gather Client information pertaining to their financial situation,
investment objectives, risk tolerance and reasonable restrictions, if any, to be imposed upon the
management of the account.
Financial Advisors will review Third-Party Money Manager reports provided to the Client at least
annually. The Financial Advisor will also contact Clients from time to time to review their financial
situation, stated investment objectives and risk tolerance; communicate information to the money
manager as warranted; and assist the Client in understanding and evaluating the services
provided by the Manager. Clients are expected to notify RFG Advisory of any changes in their
financial situation, investment objectives, or account restrictions that could affect their financial
standing.
E. Financial Planning and Consulting:
We provide financial planning and consulting services. Generally, such financial planning and/or
consulting services will involve preparing a financial plan or providing a financial consultation for
Clients, based on the Client’s financial goals, objectives, and risk tolerance. This planning or
consulting typically encompasses one or more of the following areas: Investment Planning,
Retirement Planning, Estate Planning, Executive Compensation Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit
Evaluation, Business and Personal Financial Planning.
The written financial plan(s) or financial consultation(s) to Clients usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations can include that the Client establish or revise their investment program(s)s, create
or revise wills and/or trusts, obtain or revise insurance coverage, commence or alter retirement
savings, or establish education or charitable giving programs. It should also be noted that for non-
advisory related services, some Financial Advisors periodically refer Clients to an accountant,
attorney, or other specialist, as necessary.
While some of RFG Advisory’s Financial Advisors are licensed attorneys or accountants, RFG
Advisory does not provide any legal or accounting advice under RFG’s Financial Planning and
Consulting agreements. Financial Advisors that are attorneys or accountants offer these services
under a separate business outside of their RFG affiliation. Clients are under no obligation to engage
in the Financial Advisor’s outside businesses and should seek the counsel of an attorney or
accountant, when necessary, that best suits their individual needs.
For written financial planning engagements, we provide our Clients with a written summary of their
financial situation, observations, and recommendations. For financial consulting engagements, we
usually do not provide our Clients with a written summary of our observations and
recommendations as the process is less formal than our financial planning service. Plans or
consultations are typically completed within six (6) months of the Client signing a contract with RFG
Advisory, contingent upon all information and documentation requested from the Client has been
promptly provided. Implementation of the recommendations will be at the discretion of the Client.
Some Financial Advisors specialize in retirement protocols for specific industries, such as educators,
municipal employees, and medical professionals, and provide general consulting and education
to such individuals at no cost. In addition, Financial Advisors provide financial education through
the RFG sponsored service specifically to women at no cost, referred to as “StrongHer Money®”.
F. Retirement Plan Consulting:
When working with an ERISA Plan, a Financial Advisor is referred to as a Retirement Plan
Consultant (“Consultant”). The Consultant may act as a limited scope fiduciary, pursuant to ERISA
section 3(21), that can advise, help, and assist Plan Sponsors with their investment decisions. The
Plan Sponsor is ultimately responsible for the decisions made in their Plan. Services the Client may
elect are: Non-discretionary investment advice about asset classes and investment
alternatives available for the Plan in accordance with the Plan’s investment policies and objectives;
assistance to the Client in the development of, or amendments to, the Plan’s Investment Policy
Statement (IPS); Non-discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are automatically
enrolled in the Plan or who have otherwise failed to make investment elections; Assist in monitoring
investment options by preparing periodic investment performance reports. The Consultant may
also offer non-fiduciary services to employer plan sponsors in the form of Participant Education
and/or Participant Enrollment.
In providing services for retirement plan consulting, RFG Advisory does not provide any advisory
services with respect to the following types of assets: employer securities, real estate (excluding
real estate funds and publicly traded REITS), participant loans, non- publicly traded securities or
assets, illiquid investments, or brokerage window programs (collectively, “Excluded Assets”).
All retirement plan consulting services shall follow the applicable state laws regulating retirement
consulting services. This applies to Client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the Client accounts are part of a Plan, and our firm accept appointments to provide
services to such accounts, RFG Advisory acknowledges its fiduciary standard within the meaning
of Section 3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect
to the provision of services described therein.
G. Annuities:
RFG Advisory is a member of the DPL Financial Partners, LLC (“DPL”) platform. DPL is a third-
party provider who delivers a turnkey annuity management platform to the firm. DPL services
include, among others, providing their members with analyses of their current methodology for
evaluating client’s current and future annuity needs.
DPL licensed insurance agents are unaffiliated with RFG Advisory and act as the selling agent in
executing the purchase or exchange of the client’s annuity products. DPL Licensed Insurance Agents
are also registered representatives of The Leaders Group, Inc. an unaffiliated SEC registered
broker-dealer and FINRA member. DPL is licensed as an insurance producer in Kentucky and other
jurisdictions where required to perform the platform services. Client’s RFG Financial Advisors
maintain discretionary management authority over the investments in the variable annuity sub-
accounts and select the indexes to be used when a fixed index annuity in purchased through the
RFG Advisory Discretionary Portfolio Management Agreement and with Limited Power of
Authority of the client’s annuity at the carrier.
DPL also has a relationship with Johnstone Brokerage Services, Inc (JBS) an unaffiliated SEC
registered broker-dealer and FINRA member that provides agent of record services to in-force
commission-based brokerage contracts that RFG clients own. Client’s RFG Financial Advisors
maintain discretionary management authority over the investments in the variable annuity sub-
accounts through the RFG Advisory Discretionary Portfolio Management Agreement and with
Limited Power of Authority of the client’s annuity at the carrier.
DPL receives an annual fixed membership fee from RFG Advisory in addition to service fees from
the annuity carriers with whom DPL partners. The service fees paid to DPL by the carriers are
based on the insurance premiums received from DPL member’s clients. The service fee limits the
number of annuity carrier’s available to RFG Clients through the DPL platform. RFG and its
Financial Advisors do not receive commissions.
H. Aspire [PCS Retirement] Strategies Platform:
Aspire provides RFG Advisory through their InvestLinkSM platform the ability to link participant
403b and 457 accounts so that Financial Advisors can provide discretionary investment
management services to Clients. Advisor Trust, Inc., a qualified custodian as defined under the
Advisers Act serves as the custodian for these accounts. The Financial Advisor, as discretionary
portfolio manager can choose to manage a client’s account through the plan’s selection of
investments or allocate portions of the account(s) to a strategy offered by one or more third
parties. All subject to the Financial Advisor’s and RFG’s supervisory oversight of the portfolio or
the sub-manager due diligence oversight program.
I. Schwab 529 Plan Platform
The Schwab 529 Education Savings Plan offers multiple investment options built on Schwab's asset
allocation models and comprised of well-known mutual funds from multiple fund families intended
to help provide diversification across stocks, bonds, industry segments, and investment styles.
RFG Advisory Financial Advisors can choose an age-based investment option, which automatically
adjusts the asset allocation mix as the child nears college age, or a static portfolio that sticks with
a particular investment strategy based on the client’s goals and risk tolerance.
The Platform has $0 account open or maintenance fees. Other account fees, fund expenses, and
brokerage commissions may apply. The Schwab 529 Education Savings Plan has no account
service fee or enrollment fee. The portfolio fee includes a program management fee plus
underlying fund expenses. The annual total portfolio fees for the Schwab 529 Education Savings
Plan range from 0.20% - 0.86%, depending on the investment selected.
Tailoring of Advisory Services
Regardless of the services provided, each is tailored to the individual needs of the respective
Client (whether an individual, a family, or a business) through an assessment conducted prior to an
engagement. Clients may impose restrictions on discretionary portfolios related to the level of
discretion granted, the types of investments used, etc. Terms of an actual engagement, including
description of service, limitations and restrictions, fees, etc., are all detailed before any
engagement begins in a written Client agreement.
Regulatory Assets Under Management
As of December 31, 2023, RFG Advisory manages $ 3,859,253,984 on a discretionary basis.