Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed in the State of Delaware.
Our firm has been in business as an investment adviser since 2015 and is primarily owned by
Jonathan Bernstein.
Description of the Types of Advisory Services We Offer
Asset Management
As part of our Asset Management service, a portfolio is created, consisting of individual stocks,
bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private
securities or investments. The client’s individual investment strategy is tailored to their specific
needs and may include some or all of the previously mentioned securities. Portfolios will be
designed to meet a particular investment goal, determined to be suitable to the client’s
circumstances. Once the appropriate portfolio has been determined, portfolios are continuously
and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs,
stated goals and objectives.
401(k) Advisory Services:
Our firm provides retirement plan consulting services to employer plan sponsors. Such
consulting services consist of assisting employer plan sponsors in establishing, monitoring and
reviewing their company's participant-directed retirement plan. As the needs of the plan
sponsor dictate, areas of advising could include:
• Assisting with selection and monitoring of investment options at the Plan level.
• Assisting with the creation of the Investment Policy Statement and evaluating the
suitability of the options in the Plan.
• Assisting with initial and ongoing Plan design. A detailed examination of each mutual fund
investment option within the plan, including performance versus the category and index,
fund expense analysis, manager style drift and tenure, risk/return, standard deviation,
Alpha, Sharpe ratio and fund allocation. This Agreement does not guarantee the future
performance or results of any investment option recommended or reviewed.
• Providing an annual investment and administrative review of the Plan utilizing strategic
planning sessions to review current performance and establish future objectives and
strategies for the Plan.
• Assisting with the selection of Qualified Default Investment Alternatives (QDIA) for use
by Plan participants who fail to or choose not to designate the investment options for
their accounts. If implemented, RAA recommends that the QDIA complies with ERISA
Section 404(c) and will assist in understanding these regulations but is not responsible
for ensuring this compliance.
• Providing investment education to and for the benefit of Plan participants. RAA is not a
fiduciary with regard to participants and it is understood that the participant education
service is intended to be impersonal as defined in Rule 204-3.
• Providing Client with verbal reports regarding the status and performance of the
investments and written reports from time to time or upon request. Please note the
custodian of the Plan is required to provide Client with a statement for the Plan and its
accounts on a quarterly basis.
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• Upon request, promptly providing any information to Client or Client’s other service
providers to enable the preparation and distribution of Plan participant notices and
disclosures.
Our firm will conduct strategic planning sessions to review the plan’s investments and establish
future objectives and strategies for the Plan. All services shall be in compliance with the
applicable state law(s) regulating pension consulting services. This applies to client accounts
that are pension 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
we accept appointments to provide our services to such accounts, we acknowledge that we are
a fiduciary within the meaning of Section 3(21) of ERISA (but only with respect to the provision
of services described in Section 1 of the advisory agreement to be signed by the client).
Asset Monitoring:
For accounts held directly with outside custodians where we do not have trading authority, we
offer an asset monitoring service to provide our clients with guidance to aid them in the
allocation of these accounts. We will evaluate the client’s needs and objectives, current accounts
and positions, and risk tolerance to provide
customized advice as to their investment selections.
These holdings shall be reviewed at least annually and clients will be contacted to discuss
recommended actions.
Financial Planning & Consulting:
Our firm provides a variety of financial planning and consulting services to individuals, families
and other clients regarding the management of their financial resources based upon an analysis
of the client’s current situation, goals, and objectives. These services may be conducted on a one-
time or ongoing basis. Regardless of the service, our firm agrees to provide the consulting /
financial planning services consistent with the client’s financial situation, investment objectives
and tax status.
Our financial plans or consultations rendered to clients typically include general
recommendations for a course of activity or specific actions to be taken by the client. For
example, recommendations may be made that the client begin or revise investment programs,
create or revise wills 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 we may refer clients to an accountant, attorney, or other specialist as necessary for non-
advisory related services.
For financial planning engagements, we provide our clients with a written summary of their
financial situation. For financial consulting engagements, we typically do not provide our clients
with a formalized written summary of our observations and recommendations as the process is
less formal than our planning service. However, we will provide some communication of our
observations and/or recommendations during the course of the consulting engagement through
the form of emails, phone calls, in person meetings, etc. depending upon the client’s needs.
Written financial plans are typically completed within 6 months of the client signing a contract
with us, assuming that all the information and documents we request from the client are
provided to us promptly. For one-time financial planning, we will offer a complementary follow-
up meeting within ninety days following delivery of the plan. If Client does not engage our firm
for the follow-up meeting that was offered during those ninety days, the client’s relationship
with our firm will end. If the client wishes to reengage our firm, they may do so for an additional
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fee. However, our ongoing financial planning or financial consulting clients will be provided with
an initial financial plan or consultation as noted above as well as the ability to meet with our firm
on an ad hoc basis throughout the year for any consultative work they require and ongoing
maintenance for their financial plan as needed. These services are incorporated into the ongoing
consulting fees.
Third party planners may be used to aid in the development of our financial planning and
consulting services, the fees for which shall be borne by our firm and will in no way increase the
amount agreed upon in the signed contract. Implementation of the recommendations will be at
the discretion of the client.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our Wrap Asset Management, Asset
Management and Asset Monitoring services. Additionally, we offer general investment advice to
clients utilizing our Financial Planning & Consulting services. Each client has the opportunity to
place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions
on investments in certain securities or types of securities may not be possible due to the level of
difficulty this would entail in managing the account. Restrictions would be limited to our Wrap
Asset Management and Asset Management services.
Participation in Wrap Fee Programs
We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee Program
Brochure”) of our Brochure. Our firm is in the process of transitioning clients without significant
trading costs into a non-wrap Asset Management offering described in this Brochure. Only clients
that we determine could incur substantial trading costs will be managed on a wrap fee basis. This
will typically involve clients using an options strategy. All accounts are managed on an
individualized basis according to the client’s investment objectives, financial goals, risk tolerance,
etc.
Regulatory Assets Under Management
As of December 31, 2023, our firm manages $145,888,181 on a discretionary basis and
$8,715,580 on a non-discretionary basis.