Rocky Mountain Private Wealth Management, L.L.C. is a registered investment adviser primarily
based in Sugar Land, Texas. Our firm is organized as a limited liability company under the laws
of the State of Texas. We have been providing investment advisory services since 2003. Gabriel
Steven Gallegos and Taylor Leigh Gallegos are our principal owners.
The following paragraphs describe our services and fees. Refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services
to your individual needs. As used in this brochure, the words "we", "our", "us", “RMPWM” and
"Rocky Mountain" refers to Rocky Mountain Private Wealth Management, L.L.C. and the words
"you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you
may see the term Associated Person throughout this brochure. As used in this brochure, our
Associated Persons are our firm's officers, employees, and all individuals providing investment
advice on behalf of our firm.
Portfolio Management Services
We provide discretionary portfolio management services in accordance with your individual
investment objectives. If you participate in our discretionary portfolio management services, we
require you to grant our firm discretionary authority to manage your account. Subject to a grant
of discretionary authorization, we have the authority and responsibility to formulate investment
strategies on your behalf. This authorization includes deciding which securities and the number
of securities to be purchased or sold for your account(s), the broker or dealer to be used for
each transaction, and the commission rates to be paid without obtaining your consent or
approval prior to each transaction. Discretionary authority is typically granted by investment
advisory agreement you sign with our firm, a power of attorney, and/or trading authorization
forms. In providing discretionary management services, we do not accept client restrictions on
the specific securities or the types of securities that may be held in their account.
The agreement for services will continue in effect unless terminated by either party by written
notice in accordance with the terms of the investment advisory agreement. You will incur a pro
rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days
for which you are a client.
Investors in private funds managed by our firm should refer to the offering documents specific
to those investments for details on discretionary authority or terminating the services provided
through the private fund.
If you receive an invoice from our firm, we encourage you to reconcile our invoice with the
statement(s) you receive from the qualified custodian. If you find any inconsistent information
between our invoice and the statement(s) you receive from the qualified custodian, please call
our office at 281-778-4900.
Adviser to Registered Investment Company
Rocky Mountain Private Wealth Management, LLC is an investment adviser to the proprietary
mutual fund named the RM Greyhawk Fund. ("Greyhawk"). The Adviser invests opportunistically
in assets that include, but are not limited to: (i) fixed-income securities of domestic, foreign, and
emerging markets, corporate and government issuers, without restriction as to maturity or credit
quality, including “high yield” securities (commonly known as “junk bonds”); (ii) equity securities
(common and preferred stock) of both domestic and foreign companies of various sizes; (iii)
futures on contracts of physical commodities, such as crude oil, copper and wheat; (iv) swap
contracts on individual stocks, stock mutual funds and ETFs
(v) stock index-based and sector-based futures contracts; and (vi) money market instruments,
including cash and cash equivalents (each an “Asset Class”).
The securities that the fund invests in, may have domestic, regional, international and global
risk exposure. Please refer to the Greyhawk Mutual Fund Prospectus for more information and
details of
the RM Greyhawk Fund. See the Fees and Compensation section (Item 5) below for
additional information.
Accuracy of Client Information
In providing the contracted services, we are not required to verify any information we receive
from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly
authorized to rely on the information you provide. You must promptly notify our firm if your
financial situation, goals, objectives, or needs change for the purpose of reviewing, evaluating,
and/or revising our previous recommendations and/or services.
Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction cost, fund expenses and other administrative fees.
Currently, we do not participate in any wrap fee program.
Types of Investments
We primarily offer advice on mutual funds, exchange traded funds, capital securities, equity
securities and alternative investment including interests in partnerships/hedge funds that invest
in a variety of other investment vehicles. The Adviser invests opportunistically in assets that
include, but are not limited to: (i) fixed-income securities of domestic, foreign, and emerging
markets, corporate and government issuers, without restriction as to maturity or credit quality,
including “high yield” securities (commonly known as “junk bonds”); (ii) equity securities
(common and preferred stock) of both domestic and foreign companies of various sizes; (iii)
futures on contracts of physical commodities, such as crude oil, copper and wheat;
(iv) swap contracts on individual stocks, stock mutual funds and ETFs (v) stock index-based
and sector-based futures contracts; and (vi) money market instruments, including cash and cash
equivalents (each an “Asset Class”). Refer to the Methods of Analysis, Investment Strategies
and Risk of Loss below for additional disclosures on this topic.
Additionally, we may recommend other types of investments since each client has different
needs and different tolerances for risk. We may also advise you on any type of investment held
in your portfolio at the inception of our advisory relationship, or on specific types of investments
at your request.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing
the following acknowledgment to you. When we provide investment advice to you regarding
your retirement plan account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way we make money creates some conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special 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 yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account
that we manage or provide investment advice, because the assets increase our assets under
management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when
we believe it is in your best interest.
Assets Under Management
As of December 31, 2023, we provided continuous management services for $91,740,044 in
Assets Under Management.