A. Description of the Advisory Firm
RH Advisors, LLC d/b/a Rock House Financial (hereinafter “RHF”) is a Limited Liability
Company organized in the State of Utah and registered with the Securities and Exchange
Commission (SEC). The firm was formed in January 2018, and the principal owner is
Robert Aamodt. RHF acts in accordance with its fiduciary duty imposed upon by the SEC
rules.
B. Types of Advisory Services
Portfolio Management Services
RHF offers ongoing portfolio management services based on the client profile which
includes, not limited to, individual goals, objectives, time horizon, tax levels, income, and
risk tolerance. RHF creates an investment plan with the client and documents the plan
and the client profile in the client’s books and records. Portfolio management services
include, but are not limited to, the following:
Investment strategy
Client Meetings
Asset allocation
Asset selection
Risk tolerance
Regular portfolio monitoring
RHF evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. Risk tolerance levels are documented in the client’s books and
records and updated no less than annually if risk tolerances need reassessed. RHF will
request discretionary authority from clients in order to select securities and execute
transactions without permission from the client prior to each transaction.
RHF primarily recommends mutual funds and Separately Managed Accounts (SMA)
offered by Dimensional Fund Advisors (DFA). DFA sponsored mutual funds follow an
academic investment philosophy based on economic theory. DFA funds are highly
diversified with low holdings turnover and low cost. They use consistent long-term
objectives based on empirical research not dependent on one portfolio manager. They
employ efficient trading strategies to keep trading costs low inside the funds. All clients
that engage in SMAs with DFA through RHF will be given the DFA ADV 2A or Firm
Brochure.
RHF seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of RHF’s economic, investment or
other financial interests. To meet its fiduciary obligations, RHF attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, RHF’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is RHF’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
We may from time to time determine that an investment in a product or service offered
by us or by a company affiliated with us is consistent with a client's financial situation or
the recommendations contained in the client financial plan. In addition, a client may
decide, at the client's own independent discretion, to purchase financial products offered
by or through us or an affiliated company. In such circumstances, one of our advisors may
receive investment advisory fees as the adviser to such products, like the Utah Focus Fund
in addition to compensation for investment management or financial planning.
Pension Consulting Services
RHF offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
o identifying investment objectives and restrictions
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan assets in ways designed to
achieve objectives
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include but are not limited to: investment
planning; life insurance; annuity planning and consulting; tax concerns; retirement
planning; college planning; and debt and credit planning.
RHF follows the CFP® Board Practice Standards and seven-step financial planning
process.
1. Understanding the client’s personal and financial circumstances
2. Identifying and selecting goals
3. Analyzing the Client’s current course of action and potential alternative courses of
action
4. Developing he financial planning recommendations
5. Presenting the financial planning recommendations
6. Implementing the financial planning recommendations (Unless specifically
excluded from the scope of engagement)
7. Monitoring progress and updating (Unless specifically excluded from the scope of
engagement)
1031 Exchange Services
RHF will assist potential investors in identifying properties, and Real Estate Investment
vehicles by reviewing sponsor related due diligence material, and request/review
independent third-party due diligence reports. Additionally, the Firm will facilitate the
completion of required paperwork and transfer of funds from the qualified intermediary
and the sponsor. Finally, RHF provides potential investors with disclosures of risks and
fees, and other information to help evaluate an exchange offering before any investment
is made.
Robo-Advisory Portfolio Management Services
MTG, LLC dba Betterment Securities (“Betterment”), a registered broker-dealer, member
SIPC, will be the qualified custodian for client accounts using Betterment LLC and/or
Betterment Institutional. RHF is independently owned and operated; it is not affiliated
with Betterment Securities. Clients will open the account with Betterment Securities by
entering into an account agreement directly with them as a sub-advisor to the client. While
we do not open the account for you, we may assist you in doing so.
RHF provides “robo-advisory” portfolio management services via an online interface,
Betterment for Advisory, that is a digital wealth management platform for clients. This
entails the use of algorithm-based portfolio management advice, rather than in-person
investment advice. These automated investment solutions are customized to each client
and based on individual characteristics, such as the client’s age, risk tolerance, income,
and current assets, among others.
The services provided by Betterment
include Goal Based Investment Management,
Portfolio Construction Tools, Automated Investment Management Services, Website and
Mobile Applications and Advisor Dashboard for monitoring client accounts.
Annuity and Insurance Consulting
For annuity or other insurance products or mutual funds that are commission products
RHF advises on these as a consultant only. RHF does not get paid by commission. RHF
can advise on commissionable products already owned by clients or that clients are
considering purchasing as part of financial planning. For clients who would like advice
and servicing help on these commissionable products, they can assign Mutual Securities,
LLC as the agent. Mutual Securities provides servicing and then contracts with RHF to
provide investment advisory services for those clients who have provided written
consent. Mutual Securities pays RHF for consulting on these accounts and policies. See
Item 10.C for details on this arrangement.
RHF refers clients to other agents or vendors for annuities and insurance if it is determined
a product should be implemented as part of financial plan. One of these vendors used is
DPL Financial Partners, LLC. RHF is not compensated by commission from any other
company. Clients pay fees to RHF for advice and consulting on insurance products. The
services and compensation are detailed in the client’s contract with RHF either as a
financial planning service or portfolio management service for products with underlying
investments.
RHF is a member of DPL Financial Partners, LLC’s (“DPL”) platform. They are a third-
party provider of a platform of insurance consultation services to investment advisers
with clients who have current or future needs for insurance products. DPL’s platform is
available to SEC- and state-registered investment advisers (“RIAs”), as well as to
investment advisers who are exempt for SEC and state registration (“ERAs”).
DPL offers RIAs and ERAs memberships to its platform for a fixed annual fee. Through
its licensed insurance agents, who are also registered representative of The Leaders
Group, Inc. an unaffiliated SEC-Registered Broker-dealer and FINRA member, offers
members a variety of services relating to commission free insurance products. These
services include, among others, providing members with analyses of their current
methodology for evaluating client insurance needs, educating and acting as a resource to
members regarding insurance products generally and specific insurance products owned
by their clients or that their clients are considering purchasing, and providing members
access to, and marketing support for, commission free products that insurers have agreed
to offer to members’ clients through DPL’s platform.
For providing platform services to RIAs and ERAs, DPL receives service fees from the
insurers that offer their commission free products through the platform. These service fees
are based on the insurance premiums received by the insurers from DPL members’ clients.
RHF is not compensated by DPL. RHF clients pay for consulting services on insurance as
part of financial planning services.
DPL is licensed as an insurance producer in Kentucky and other jurisdictions where
require to perform the platform services. Its representatives are also licensed as insurance
producers, appointed as insurance agents of the insurers offering their products through
the platform, and registered representatives of the Leaders Group.
Services Limited to Specific Types of Investments
RHF generally limits its investment advice to mutual funds, fixed income securities,
equities, and ETFs. RHF may use other securities as well to help diversify a portfolio when
applicable.
Additional Services
RHF offers our clients the services of Pontera to monitor and provide management of
client’ held away assets. We use a third-party platform, Pontera, to facilitate
management of held away assets such as defined contribution plan participant accounts,
with discretion. The platform allows us to avoid being considered to have custody of
Client funds since we do not have direct access to Client log-in credentials to affect trades.
We are not affiliated with Pontera in any way and receive no compensation from them for
use of the platform. A link will be provided to the Client allowing them to connect an
account(s) to the platform. Once Client account(s) is connected to the platform, Adviser
will review the current account allocations. When deemed necessary, Adviser will
rebalance the account considering client investment goals and risk tolerance, and any
change in allocations will consider current economic and market trends. The goal is to
improve account performance over time, minimize loss during difficult markets, and
manage internal fees that harm account performance. Client account(s) will be reviewed
at least quarterly, and allocation changes will be made as deemed necessary.
C. Client Tailored Services and Client Imposed Restrictions
RHF offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Risk
Assessment which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
RHF from properly servicing the client account, or if the restrictions would require RHF
to deviate from its standard suite of services, RHF reserves the right to end the
relationship.
RHF may provide online “robo-advisory” portfolio management to specific clients. Client
accounts are generally invested into a target allocation depending on the client’s
individual profile. This automated approach factors in client financial situation and risk
tolerance, although the algorithms used to provide advisory services are designed to be
utilized by RHF across multiple clients. Clients may not impose restrictions in investing
in certain securities or types of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
RHF does not participate in wrap fee programs Clients that engage Betterment Securities
for Robo-advisory services will contract independently with Betterment and receive the
Betterment Securities ADV Part 2A wrap fee brochure.
E. Assets Under Management
RHF has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$214,932,245 $0 December 2023