Redwood Financial Network Corp. was organized as a corporation under the laws of the
State of Ohio on June 10, 2011, and is owned by the following individuals:
William J. Gordon, III 50%
Sunwook Jin 50%
We became a registered as an investment adviser with the Ohio Division of Securities
(“Division”) and the Illinois Securities Department (“Department”) in February 2012 in
order to provide the investment advisory products and services described within this
document. We have been registered as an investment adviser at both the state and
federal level since February 14, 2012. Currently, we are registered with the SEC since
April 28, 2014, and notice filed with the appropriate states in which notice filings are
required. As of December 31, 2023, we managed $185,700,176 on a discretionary
basis and $1,697,895 on a non-discretionary basis.
Redwood provides asset allocation and ongoing investment management services,
including a wrap fee program, Redwood Asset Management (RAM). RAM provides a
professional asset management service for a convenient, single fee that covers account
management, brokerage, clearing, custody, and administrative services. We will receive
a portion of the RAM fee for our services. RAM is administered through our clearing
borker/dealer, LPL Financial (“LPL”). RAM may be discretionary or non-discretionary,
dependent upon client preferences and needs. Please note that our IARs provide
advice individually to each of their clients based on each client’s specific financial
objectives and situation, and therefore, advice provided by one IAR could conflict with or
be in direct opposition to advice provided by another IAR.
Redwood typically manages wrap accounts similarly to non-wrap accounts. However,
several factors may influence the selection of the account structure, including but not
limited to:
1. The client’s preference for a “wrap” vs. transaction charges per trade on certain
or all securities.
2. Account size.
3. Anticipated trading frequency.
4. Anticipated securities to be traded.
5. Management style.
6. Long term investment goals.
The overall cost you will incur if you participate in a wrap fee program may be higher or
lower than you might incur by paying transaction costs separately. To compare the cost
of the wrap fee program with non-wrap fee portfolio management services, you should
consider the frequency of trading activity associated with our investment strategies, the
transaction charges involved, and the advisory fees charged.
Wrap Fee:
The annual fee for this service ranges from 0.50% to 2.5%. Fees are negotiable.
Therefore, clients with similar assets under management and investment objectives
may pay significantly higher or lower fees than other clients. LPL will deduct Redwood’s
fee quarterly in advance; however, for the initial fee deduction, LPL will deduct
Redwood’s fee at the beginning of the quarter following the establishment of the
Account and will include a prorated fee for the initial quarter in addition to the quarterly
Redwood fee for the upcoming quarter. Subsequent fee deductions will be made at the
beginning of each quarter based on the value of the Account assets as of the close of
business on the last business day of the preceding quarter. Additional deposits and
withdrawals will be added or subtracted from the assets, which may lead to an
adjustment of Redwood’s fee. Certain accounts may establish procedures to pay
Redwood’s fee directly rather than through a debit to the Account. The fee schedule
may vary based upon portfolio size and other business considerations. You may
terminate this service at any time and a refund will be made on a pro-rata (by day) basis
of any fees paid in advance.
Potential Conflicts of Interest:
Even though we believe LPL’s fees are competitive, lower fees for similar services may
be available from other sources. Upon your written authorization, we may debit
investment advisory fees directly from your account and pay such amounts to Redwood.
This fee arrangement wherein asset management fees are debited from your account
will not trigger any constructive custody. You authorize LPL to accept instructions from
Redwood regarding adjustments to Redwood’s fees in circumstances such as a fee
waiver or credit or a reduction in fee. Adjustments to increase the fee set out in the
Account Application may be made only at your instruction. You understand that LPL will
not verify that the fees are consistent with those set out in the agreement between you
and Redwood. You will see the amounts deducted from the Account on statements and
will verify them based on the fee rates you negotiated with Redwood. It is agreed by you
that the fee will be payable, first, from free credit balances, if any, in the Account, and
second from the liquidation or withdrawal by LPL of your shares of any money market
fund balances in any money market account, or balances in any insured deposit
account, if applicable. You acknowledge that LPL does not set the fee of Redwood
applicable to the Account.
Because mutual funds pay advisory fees to their investment advisors, such fees are
therefore indirectly charged to all holders of mutual fund shares. Clients with mutual
funds in their portfolios are effectively paying us and the mutual fund advisor for the
management of their assets. Clients who place mutual fund shares under our
management are therefore subject to our direct management fee and the indirect
management fee of the mutual fund advisor.
Mutual Fund Internal Expenses:
Internal advisory fees and expenses are paid by the mutual fund companies to their
fund advisers, and/or sub account sponsors. These internal expenses are further
outlined in the Fund Companies’ Prospectuses. The program sponsor may act as
broker in connection with mutual funds which are designated for management in the
program and thus may receive additional compensation, separate from its Investment
Advisory Program. Redwood only receives a portion of the
advisory fee and does not
share in the revenue produced by mutual fund investments.
Mutual Fund Fees in Wrap Accounts
As described throughout this Brochure, Redwood has a significant relationship with
LPL. This relationship includes access to wrap fee programs offered through the LPL
Platform by third-party money managers. In a wrap fee program, the money manager
does not pass along transaction fees incurred when the program rebalances positions
or otherwise makes purchases or sales of mutual funds. Because the money manager
absorbs these transaction costs, they have an incentive to recommend or select “no-
transaction fee mutual funds” (“NTF funds”). Mutual funds, including NTF funds, have
their own internal charges, including management fees, distribution and/or 12b-1 fees,
and other expenses. These fees are detailed in the mutual fund prospectuses.
Most NTF funds have transaction-fee alternatives that result in higher expense ratios.
IARs that are also registered representatives of LPL are limited to selecting wrap
accounts that have been previously approved by LPL and contain NTF funds, thus
resulting in a higher cost to owning the fund compared to lower share class funds.
Similar to seeking best execution, the determining factor we used in choosing to partner
with LPL is not always the lowest possible cost, but whether the relationship represents
the best platform through which to provide most of our advisory services. To make this
determination, we take into consideration the full range of LPL’s services, including
among others, the ability of our IARs to offer brokerage services as registered
representatives, their fees (both to us and to our clients), their financial wherewithal,
their custodial services, and their responsiveness. Accordingly, although Redwood
seeks to offer the most cost-effective solutions for our clients, LPL may not necessarily
offer the lowest cost mutual fund share classes in all instances. LPL selects certain
mutual fund product offerings because the share class pays LPL compensation for the
administrative and recordkeeping services LPL provides to the mutual fund, and which
we believe is passed along to us in the execution of their services to us. You should
understand that another custodian may offer the same, or similar, mutual fund products
at a lower overall cost.
Notwithstanding these potential conflicts, Redwood believes this arrangement does not
interfere with its provision of advice to clients because of its practices and controls.
Redwood’s IARs and supervisors review client accounts to ensure they are consistent
with the clients’ stated needs, objectives, and financial situation. While we believe that
removing the cost to implement trades is important and helpful to the management of
client assets and to clients' overall performance, you need to understand the added cost
to your portfolio. You should review both the fees charged by the funds and our fees to
fully understand the total amount of fees you are paying and, thereby, to evaluate the
advisory services being provided. We are happy to explain these products and any
associated conflicts in detail.
General Information on Advisory Programs and Fees:
All fees paid to us are separate and distinct from the fees and expenses charged by
mutual funds to their shareholders. These fees and expenses are described in each
fund's prospectus. These fees will generally include a management fee, other fund
expenses, and a possible distribution fee.
You could invest in a mutual fund directly, without our services. In that case, you would
not receive the services we provide which are designed, among other things, to assist
you in determining which mutual fund or funds are most appropriate to your financial
condition, goals, and objectives. Accordingly, you should review both the fees charged
by the funds and the fees we charge to fully understand the total amount of fees to pay
and to thereby evaluate the advisory services being provided.
Advisory recommendations are based on your financial situation at the time the services
are provided and are based on financial information you disclose to us. You are advised
that certain assumptions may be made with respect to interest and inflation rates and
the use of past trends and performance of the market and economy. Past performance
is in no way an indication of future performance. As your financial situation, goals,
objectives, or needs change, you must notify us promptly.
We shall never have custody of any of your funds or securities, as the services of LPL,
a qualified and independent custodian will be used for these asset management
services.
The wrap fee service may cost clients more or less than purchasing such services
separately depending on the frequency of trading in the client's accounts, commissions
charged at other broker/dealers for similar products and fees charged for like services by
other broker/dealers and other factors.
Under the RAM Program, you will pay a single fee for investment advice and all
transaction related costs associated with executing transactions (except for incidental
costs such as wire fees or bank charges). The RAM Fee also does not cover certain fees
and expenses associated with investments in mutual funds, as discussed above. Other
costs that may be assessed to you and that are not part of the wrap fee include fees for
portfolio transactions executed away from Broker, dealer mark-ups, electronic fund and
wire transfers, spreads paid to market-makers, dealer mark-ups, market maker spreads
and exchange fees, among others.
We may receive compensation or other benefits in addition to the RAM fee we receive
from you and, therefore, we may have an incentive to engage in such transactions. This
compensation may be more than what you would receive if you participated in other
programs or paid separately for investment advice, brokerage, and other services.
Therefore, we may have a financial incentive to recommend the wrap fee program over
other programs or services.