A. Firm Information
Colonial River Investments, LLC (“Colonial River” or the “Advisor”) d/b/a Colonial River Wealth Management,
LLC, is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor
is organized as a limited liability company (“LLC”) under the laws of Virginia. Colonial River was founded in
August 2015 and became registered in Virginia in March 2017. Colonial River is owned and operated by Devin J.
Garofalo (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Colonial River.
B. Advisory Services Offered
Colonial River offers investment advisory services to individuals, high net worth individuals, families, trusts,
estates, and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Colonial River’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Wealth Management Services
Colonial River provides Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary and non-discretionary
management of investment portfolios. These services are described below.
Investment Management Services
Colonial River provides customized investment management solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services. Colonial River works with each Client to identify their investment
goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy.
Colonial River customizes its investment management services for its Clients. Portfolios are primarily constructed
using individual stocks, individual bonds, mutual funds, exchange-traded funds (“ETFs”), and certain alternative
investments (limited partnerships). The Advisor may also utilize other types of investments, as appropriate, to
meet the needs of each particular Client. The Advisor may retain certain legacy investments based on portfolio fit
and/or tax considerations.
Colonial River generally employs a long-term investment approach for Clients, but may buy, sell, or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Colonial River will construct, implement, and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Colonial River evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Colonial River may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Colonial River may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. Colonial River may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating
cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Colonial River utilizes two investment strategies when constructing client portfolios, tactical allocation, and
quantitative rebalancing.
Tactical Portfolios - Tactical allocation portfolios reallocate based on the underlying quantitative algorithm's
assessment of ascending investment opportunities. Reallocations are made intermittently instead of on a
predetermined schedule. In this way the strategy's responsiveness seeks participation in upside growth while
being adaptable and reallocating to defensive securities or cash when necessary for downside protection.
Strategic Portfolios - Strategic allocation portfolios (also called "Target Volatility" portfolios) rebalance quarterly
based on the software’s underlying volatility algorithm. The Advisor will tune the Target Volatility portfolios to
experience a lower level of volatility than a benchmark index and reallocations are made among a group of
securities once per quarter so as to maintain this "targeted" volatility. Target Volatility portfolios seek to minimize
market turbulence, maintain market participation, and soften the effects of sharp drawdowns.
At no time will Colonial River accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account
managed by the Advisor.
Use of Independent Managers
Colonial River will recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each
Independent Manager to ensure the strategy remains aligned with the Client’s investment objectives and overall
best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and
managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV
Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Participant Account Management
As part of the Advisor’s Investment Management Services, when appropriate, the Advisor will use a third-party
platform, Pontera Solutions, Inc., to facilitate management of held away assets such as defined contribution plan
participant accounts, with investment discretion. The platform enables the Advisor to gain access to Client
account without having access through the Client’s credentials. This independent advisor access ensures that the
Advisor will not have custody of Client funds or securities when implementing trades for the Client. The Advisor is
not affiliated with the platform in any way and receives no compensation from the platform. A link will be provided
to the Client allowing them to connect their account[s] to the platform for the Advisor’s secure access.
Colonial River Premiere Solutions
Colonial River Premiere Solutions is an additional investment management service providing an additional layer
of asset management from selected strategists and or asset allocation models. The Colonial River Premier
Solutions offering includes no ticket charges, utilization of ETF, Mutual Funds, Bonds, and Stocks. Clients may
also select Tax Aware Efficiency Options.
Financial Planning Services
Colonial River will typically provide a variety of financial planning services to individuals and families, either
included in its investment management services or pursuant to a written financial planning agreement. Services
are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one
or more areas of need, including, but not limited to investment planning, retirement planning, personal savings,
education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually 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 start or revise their investment programs, commence or alter
retirement savings, establish education savings, and/or charitable giving programs.
Colonial River may also refer Clients to an accountant, attorney, trustee, or another specialist, as appropriate for
their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. Plans or consultations are typically completed within six months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor. Financial planning services may be included in an overall wealth management engagement or provided
as a separate service, pursuant to the terms of the agreement with the Client.
C. Client Account Management
Prior to engaging Colonial River to provide advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Colonial River will work with each Client to develop a custom
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Colonial River will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – Colonial River will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Colonial River will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Colonial River includes transaction fees (herein “Covered Costs”) together with its investment advisory fees.
Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes
its investment management services for its Clients. The Advisor sponsors the Colonial River Wrap Fee Program
solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required
for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid
its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a
supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, Colonial River manages $274,599,256 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.