Description of Firm
Resolute Advisors LLC d/b/a Resolute Partners Group (RPG) is a registered investment adviser
located in San Francisco, California. We are organized as a limited liability company ("LLC") under
the laws of the State of Delaware. We have been providing investment advisory services
since 2019. We are owned by RPG HoldCo LLC. RPG believes its clients are the foundation of
its business and RPG has a fiduciary responsibility to put the clients’ best interests ahead of its
own. We are resolute in our steadfast commitment to partnering with clients to provide honest,
excellent, conflict-free client service.
The following paragraphs describe our services and fees. Refer to the description of each
investment advisory service listed below for information on how we specifically tailor our advisory
services to each client's needs. As used in this brochure, the words "we", "Advisor", "our", "it" and
"us" refer to Resolute Partners Group and the words "you," "your," and "client" refer to you as
either a client or prospective client of our firm.
Portfolio Management Services
RPG provides discretionary portfolio management services, comprehensive and conflict-free
wealth management advice to high-net-worth individuals, families and their affiliated entities on a
fee basis as discussed at Item 5 below. RPG's investment advice specifically is tailored to meet
its clients' needs and investment objectives. Before engaging RPG to provide investment advisory
services, clients are required to enter into an Investment Advisory Agreement with RPG setting
forth the terms and conditions of the engagement (including termination), describing the scope of
the services to be provided, and the fee that is due from the client. To commence the investment
advisory process, RPG will ascertain each client’s investment objective(s) and then allocate the
client’s assets consistent with the client’s designated investment objective(s). Once allocated,
RPG provides ongoing supervision of the account(s).
RPG, in intimate partnership with its clients, creates a comprehensive plan for each engagement.
We seek to understand each Client’s goals, risk-tolerance, resources, and investment time
horizon. Our services include developing an appropriate and customized strategic asset allocation
based on the Client’s investment objectives, implementing, and monitoring this allocation, and
financial planning. Our holistic approach incorporates non-investment issues including insurance,
taxes, trusts and estates, philanthropy, family education, concentrated wealth, etcetera. In these
areas, we help manage and coordinate interactions with trusted specialists who supplement our
advice. RPG helps ensure its Clients’ financial decisions are well integrated with their lifestyle
choices, investment portfolios, and financial plan.
RPG’s investment portfolios are primarily comprised of no load, institutional-class mutual funds,
exchange-traded funds (“ETFs”), investment-grade fixed income, individual equities, and private
investment funds. RPG does not engage in subjective forecasting of financial markets. Client
portfolios are designed for the long-term investor who believes capital markets will deliver fair and
competitive returns over time.
If a client participates in RPG's discretionary portfolio management services, we require you to
grant us discretionary authority to manage your account. Subject to a grant of discretionary
authorization, RPG has the authority and responsibility to formulate investment strategies on
client's behalf. Discretionary authorization allows RPG to determine the specific securities, and
the number of securities, to be purchased or sold for a client account without obtaining client
approval prior to each transaction. RPG will also recommend the broker or dealer to be used for
securities transactions in client accounts. Discretionary authority is granted by the investment
advisory agreement clients sign with RPG.
Clients may limit RPG's discretionary authority (for example, limiting the types of securities that
can be purchased or sold in an account) by providing RPG with restrictions and guidelines in
writing.
RPG may also offer non-discretionary portfolio management services. Please Note: Non-
Discretionary Service Limitations. Clients that determine to engage RPG on a non-
discretionary investment advisory basis must be willing to accept that RPG cannot complete any
account transactions without obtaining prior consent to any such transaction(s) from the client.
Thus, in the event that RPG would like to make a transaction for a client’s account, and client is
unavailable, RPG will be unable to complete the account transaction (as it would for its
discretionary clients) without first obtaining the client’s consent. Clients have an unrestricted right
to decline to implement any advice provided by RPG on a non-discretionary basis.
As part of RPG's investment strategy, we may use one or more sub-advisers to manage a portion
of client accounts on a discretionary basis. In such situations, the sub-adviser(s) shall have day-
to-day responsibility for the active discretionary management of the allocated assets and may use
one or more of their model portfolios to manage your account. RPG shall continue to render
investment supervisory services to the client relative to the ongoing monitoring and review of
account performance, asset allocation and client investment objectives. Factors that RPG shall
consider in recommending sub-adviser(s) include the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research.
RPG may hire and fire any sub-adviser without prior client approval. We may pay a portion of our
advisory fee to the sub-adviser(s) we use; however, you will not pay our firm a higher advisory
fee as a result of any sub-advisory relationships.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by RPG. These models are designed for investors with varying
degrees of risk tolerance ranging from a more aggressive investment strategy to a more
conservative investment approach. Clients whose assets are invested in model portfolios may not
set restrictions on the specific holdings or allocations within the model, nor the types of securities
that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in
certain securities or types of securities in their account. In such cases, this may prevent a client
from investing in certain models that are managed by RPG.
Financial Consulting Services
To the extent requested and engaged by the client to do so, RPG offers financial consulting
services that primarily involve advising clients on specific financial-related topics per the terms
and conditions of a separate agreement and a separate fee as discussed at Item 5 below, the fee
for which shall generally be based upon the individual providing the service and the scope of the
services to be provided. RPG’s consulting services may include, but are not limited to, risk
assessment/management, investment planning, financial organization and reporting, or financial
decision making/negotiation. Prior to engaging RPG to provide consulting services, clients are
generally required to enter into a Financial Consulting Agreement with RPG setting forth the terms
and conditions of the engagement (including termination), describing the scope of the services to
be provided, and the portion of the fee that is due from the client.
Please Note. RPG believes that it is important for the client to address financial planning issues
on an ongoing basis. Please Also Note: RPG does not serve as an attorney, accountant, or
insurance agent, and no portion of our services should be construed as same. Accordingly, RPG
does not prepare legal documents, prepare tax returns, or sell insurance products. To the extent
requested by a client, we may recommend the services of other professionals for non-investment
implementation purpose (i.e. attorneys, accountants, insurance, etc.). The client is not under any
obligation to engage any such professional(s). The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from RPG and/or
its representatives. If the client engages any professional (i.e. attorney, accountant, insurance
agent, etc.), recommended or otherwise, and a dispute arises thereafter relative to such
engagement, the client agrees to seek recourse exclusively from the engaged professional. At all
times, the engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and
not RPG, shall be responsible for the quality and competency of the services provided.
Selection of Other Advisers
The Advisor may recommend that a client utilize one or more unaffiliated, third-party money
managers ("TPMMs") or investment platforms for all or a portion of a client's investment portfolio.
After gathering information about a Client's financial situation and objectives, RPG may
recommend a specific TPMM or investment program. Factors that the Advisor takes into
consideration when making its recommendation(s) include, but are not limited to, the following:
the TPMM's performance, methods of analysis, fees, client financial needs, investment goals, risk
tolerance, and investment objectives. RPG will monitor the TPMM(s)' performance to ensure its
management and investment style remains aligned with Client investment goals and objectives.
The TPMM(s) will actively manage client portfolios and will assume discretionary investment
authority over the specific investment accounts. RPG will assume discretionary authority to hire
and fire TPMM(s) and/or reallocate client assets to other TPMM(s) where it deems such action
appropriate.
Please Note. The investment management fee charged by the TPMM is separate from, and in
addition to, RPG’s investment advisory fee disclosed at Item 5 below. ANY QUESTIONS: RPG’Ss
Chief Compliance Officer, Kevin Lutz, remains available to address any questions that a client or
prospective client may have regarding the allocation of account assets to an TPMM including the
specific additional fee to be charged by such TPMM.
Use of Mutual and Exchange Traded Funds: RPG utilizes mutual funds and exchange traded
funds for its client portfolios. In addition to RPG’s investment advisory fee described below, and
transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund
and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees
and other fund expenses).
Custodian Charges-Additional Fees. As discussed below at Items 5 and 12 below, when
requested to recommend a broker-dealer/custodian for client accounts, RPG generally
recommends certain custodians/broker-dealers for client investment management assets. Certain
broker-dealers charge brokerage commissions, transaction, and/or other type fees for effecting
certain types of securities transactions (i.e., including transaction fees for certain mutual funds,
and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of
securities for which transaction fees, commissions, and/or other type fees (as well as the amount
of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians
do not currently charge fees on individual equity transactions [including ETFs], others do).
Although RPG is not a frequent trader, its primary investment vehicles for client accounts are
ETFs. Please Note: there can be no assurance that its recommended custodians/broker-dealers
will not change their transaction fee pricing in the future). Please Also Note: the broker-
dealer/custodian may also assess fees to clients who elect to receive trade confirmations and
account statements by regular mail rather than electronically. Tradeaways: When beneficial to
the client, equity transactions may be effected through broker‐dealers with whom RPG and/or the
client have entered into arrangements for prime brokerage clearing services, including effecting
certain client transactions through other SEC registered and FINRA member broker‐dealers (in
which event, the client generally will incur both the transaction fee charged by the executing
broker‐dealer and a “trade-away” fee charged by the broker-dealer/).These fees/charges are in
addition to RPG’s investment advisory fee at Item 5 below. RPG does not receive any portion of
these fees/charges. ANY QUESTIONS: RPG’s Chief Compliance Officer, Kevin Lutz, remains
available to address any questions that a client or prospective client may have regarding
the above, including the transaction fee differential among its recommended
custodians/broker-dealers.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental,
Social and Governance considerations into the investment due
diligence process (“ESG). ESG investing incorporates a set of criteria/factors used in evaluating
potential investments: Environmental (i.e., considers how a company safeguards the
environment); Social (i.e., the manner in which a company manages relationships with its
employees, customers, and the communities in which it operates); and Governance (i.e.,
company management considerations). The number of companies that maintain an acceptable
ESG mandate can be limited when compared to those that do not, and could underperform broad
market indices. Investors must accept these limitations, including potential for underperformance.
Correspondingly, the number of ESG mutual funds and exchange traded funds are limited when
compared to those that do not maintain such a mandate. As with any type of investment (including
any investment and/or investment strategies recommended and/or undertaken by RPG), there
can be no assurance that investment in ESG securities or funds will be profitable or prove
successful. RPG does not maintain or advocate an ESG investment strategy, but will seek to
employ ESG if directed by a client to do so.
Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, RPG will
advise the client to consider a potential investment in corresponding exchange traded securities,
or an allocation to separate account managers and/or private funds that provide cryptocurrency
exposure. Crypto is a digital currency that can be used to buy goods and services but uses an
online ledger with strong cryptography (i.e., a method of protecting information and
communications with codes) to secure online transactions. Unlike conventional currencies issued
by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price
is determined by the supply and demand of their market. Because cryptocurrency is currently
considered to be a speculative investment, RPG will not exercise discretionary authority to
purchase a cryptocurrency investment for client accounts. Rather, a client must expressly
authorize the purchase of the cryptocurrency investment. Please Note: RPG does not
recommend or advocate the purchase of, or investment in, cryptocurrencies. RPG considers such
an investment to be speculative. Please Also Note: Clients who authorize the purchase of a
cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme
price volatility and complete loss of principal.
Affiliated Private Funds. RPG and/or its owners are affiliated with RPG Animoca Ventures, LP
Fund, a private investment fund (the “Fund”), the complete description of which (the terms,
conditions, risks, conflicts and fees, including incentive compensation) is set forth in the Fund’s
offering documents. RPG, on a non-discretionary basis, may recommend that qualified clients
consider allocating a portion of their investment assets to the Fund. If a client determines to
become a Fund investor, unless indicated to the contrary, in writing, by RPG, the amount of assets
invested in the fund(s) shall be included as part of “assets under management” for purposes of
RPG calculating its investment advisory fee per Item 5 below. RPG’s fee shall be in addition to
the Fund’s fees. RPG’s clients are under absolutely no obligation to consider or make an
investment in a private investment fund(s).
RPG and/or its owners are affiliated with RAISE.ai Ventures, LP, a private investment fund (the
“Fund”), the complete description of which (the terms, conditions, risks, conflicts and fees,
including incentive compensation) is set forth in the Fund’s offering documents. RPG, on a non-
discretionary basis, may recommend that qualified clients consider allocating a portion of their
investment assets to the Fund. If a client determines to become a Fund investor, unless indicated
to the contrary, in writing, by RPG, the amount of assets invested in the fund(s) shall not be
included as part of “assets under management” for purposes of RPG calculating its investment
advisory fee per Item 5 below. RPG’s fee shall be in addition to the Fund’s fees. RPG’s clients
are under absolutely no obligation to consider or make an investment in a private investment
fund(s).
Please Note: Private investment funds generally involve various risk factors,
including, but not limited to, potential for complete loss of principal, liquidity
constraints and lack of transparency, a complete discussion of which is set forth in
each fund’s offering documents, which will be provided to each client for review
and consideration. Unlike liquid investments that a client may own, private
investment funds do not provide daily liquidity or pricing. Each prospective client
investor will be required to complete a Subscription Agreement, pursuant to which
the client shall establish that he/she is qualified for investment in the fund and
acknowledges and accepts the various risk factors that are associated with such
an investment.
Please Also Note: Conflict Of Interest. Because RPG and/or its affiliates can
earn compensation from the Fund (i.e., management fees, incentive
compensation, etc.) that could generally exceed the fee that RPG would earn
under its standard asset-based fee schedule referenced in Item 5 below, the
recommendation that a client become a Fund investor presents a conflict of
interest. No client is under any obligation to become a Fund investor. Given the
conflict of interest, RPG advises that clients consider seeking advice from
independent professionals (i.e., attorney, accountant, adviser, etc.) of their
choosing prior to becoming a Fund investor. No client is under absolutely any
obligation to become a Fund investor. ANY QUESTIONS: RPG’s Chief
Compliance Officer remains available to address any questions regarding
this conflict of interest.
Reporting Services. RPG can also provide account reporting services, which can incorporate
client investment assets that are not part of the assets that RPG manages (the “Excluded
Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other advisors
that maintain trading authority, and not RPG, shall be exclusively responsible for the
investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing,
RPG does not provide investment management, monitoring or implementation services for the
Excluded Assets. If RPG is asked to make a recommendation as to any Excluded Assets, the
client is under absolutely no obligation to accept the recommendation, and RPG shall not be
responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets.
The client can engage RPG to provide investment management services for the Excluded Assets
pursuant to the terms and conditions of the
Investment Advisory Agreement between RPG and
the client.
Types of Investments
RPG believes in diversified, generally liquid client portfolios. As such, we primarily offer advice
on liquid, market-based securities like exchange traded funds ("ETFs"), mutual fund shares and
individual equities, options, or municipal securities managed via third-party managers.
Additionally, we may advise you on various types of investments based on your stated goals
and objectives. RPG may also provide advice on any type of investment held in client portfolios
at the inception of the advisory relationship. This may include illiquid, partnership-type
investments.
Please Note: Cash Positions. RPG continues to treat cash as an asset class. As such, unless
determined to the contrary by RPG, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating RPG’s advisory fee. At
any specific point in time, depending upon perceived or anticipated market conditions/events
(there being no guarantee that such anticipated market conditions/events will occur), RPG may
maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time,
RPG;s advisory fee could exceed the interest paid by the client’s money market fund. ANY
QUESTIONS: RPG’s Chief Compliance Officer, Kevin Lutz, remains available to address
any questions that a client or prospective may have regarding the above fee billing
practice.
Cash Sweep Accounts. Account custodians generally
require that cash proceeds from account
transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep
account. The yield on the sweep account is generally lower than those available in money market
accounts. To help mitigate this issue, RPG shall generally purchase a higher yielding money
market fund available on the custodian’s platform with cash proceeds or deposits, unless RPG
reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period
to purchase additional investments for the client’s account. Exceptions and/or modifications can
and will occur with respect to all or a portion of the cash balances for various reasons, including,
but not limited to, the amount of dispersion between the sweep account and a money market fund,
an indication from the client of an imminent need for such cash, or the client has a demonstrated
history of writing checks from the account. ANY QUESTIONS: RPG’s Chief Compliance Officer,
Kevin Lutz, remains available to address any questions that a client or prospective client may
have regarding the above.
Portfolio Activity. RPG has a fiduciary duty to provide services consistent with the client’s best
interest. RPG will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment performance,
market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a
change in the client’s investment objective. Based upon these factors, there may be extended
periods of time when RPG determines that changes to a client’s portfolio are unnecessary. Clients
remain subject to the fees described in Item 5 below during periods of portfolio inactivity. Of
course, as indicated below, there can be no assurance that investment decisions made by RPG
will be profitable or equal any specific performance level(s).
Client Obligations. In performing our services, RPG shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify RPG
if there is ever any change in his/her/its financial situation or investment objectives for the purpose
of reviewing/evaluating/revising our previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying degrees of risk,
and it should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or undertaken by
RPG) will be profitable or equal any specific performance level(s).
Cybersecurity Risk. The information technology systems and networks that RPG and its third-
party service providers use to provide services to RPG’s clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions
that could cause significant interruptions in RPG’s operations and result in the unauthorized
acquisition or use of clients’ confidential or non-public personal information. Clients and RPG are
nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur
losses, including for example: financial losses, cost and reputational damage to respond to
regulatory obligations, other costs associated with corrective measures, and loss from damage
or interruption to systems. Although RPG has established its systems to reduce the risk of
cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always
be successful, especially considering that RPG does not directly control the cybersecurity
measures and policies employed by third-party service providers. Clients could incur similar
adverse consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental and
other regulatory authorities, exchange and other financial market operators, or other financial
institutions.
Assets Under Management
As of December 31, 2022, we provide continuous management services for $1,396,768,091 in
client assets on a discretionary basis and $335,661,956 on a non-discretionary basis. Additionally,
we have $346,204,642 in assets under advisement.