RoseCap Investment Advisors, LLC (“RoseCap”) was formed in 2010 to provide investment advisory services to individuals, families, and institutions. RoseCap is a subsidiary of RoseCap Financial Advisors, LLC, which was incorporated in 2010 as the parent company to certain entities that are majority owned by Matthew H. Rosenberg. While both entities, from time to time, may be referred to as “RoseCap” or “RoseCap Financial Advisors”, it should be clear that the entity that provides fee-based investment advisory services to clients is RoseCap Investment Advisors, LLC. As of this writing, RoseCap has approximately $341,500,000 in discretionary assets under management, and approximately $23,116,000 in retirement plan assets (non-discretionary). Ownership RoseCap is owned 100% by RoseCap Financial Advisors, LLC. The ownership of RoseCap Financial Advisors, LLC is held 100% by Matthew H. Rosenberg. Advisory Services Offered Asset Management Asset Management services are where RoseCap assists clients with investing money for various purposes, including retirement, future education spending, personal financial goals, to meet annual spending requirements (endowments), or just seeking to earn a selected return while minimizing risk. Asset management is the primary service offered to clients and RoseCap is paid a fee based on the amount of client assets held under management (see ITEM 5 – FEES AND COMPENSATION). Asset management services are discretionary and limited to constraints specified in the client’s investment policy statement (see ITEM 16 – INVESTMENT DISCRETION). Financial Planning Upon request, RoseCap will provide a detailed financial plan to assist with specific financial goals such as cash flow management, education planning, retirement, insurance planning, and tax/estate planning. As part of our financial planning services, RoseCap may advise clients on the ownership of direct investment assets, such as real estate or business ownership. Sub-Advisory RoseCap will perform sub-advisory services, whereby asset management and/or financial planning services are provided by RoseCap, for a fee, to the other investment advisory firms. Employer Sponsored Retirement Plans Employer sponsored retirement plans (i.e., 401(k) and 403(b) plans) are self-directed by the employee (“Participant”). This means RoseCap does not make specific investment decisions on behalf of the Participant. Rather, the Participant will decide on how to invest their own assets by selecting from a mix of investment options that were recommended to the retirement plan by RoseCap. RoseCap will generally recommend exchange traded funds (ETFs) and/or mutual funds as investment options. RoseCap assumes fiduciary responsibility when making recommendations about investment vehicles to the plan sponsor. RoseCap will also assist in group enrollment meetings and in the education of the Participants about general investment principles and the investment alternatives available under the plan. Levels of Advisory Services RoseCap Private Client Management Clients who are part of RoseCap’s Private Client Management group (“RPCM”) typically require a higher or more in-depth level of the advisory services described above. These clients will also typically pay higher fees for services. RPCM asset management services may include one or more of the following: - In depth consultation of client’s financial situation and financial goals.
- Diversified asset allocation

within client investment portfolio, using combination of funds and individual securities.
- Rebalancing and repositioning of asset allocations.
- Portfolio monitoring for tax loss harvesting.
- Regularly scheduled portfolio reviews with client, or ad hoc reviews as client circumstances change.
- Detailed periodic reporting of portfolio performance.
- Custom investment policy statement and portfolio.
RPCM client portfolios are typically customized to include adjustments for the client’s specific goals, net worth, composition of wealth, risk tolerance, and other factors. (Note: Customization does not imply exclusivity. RoseCap may use similar approaches and give similar advice to multiple clients.) In-depth financial planning services may be provided to RPCM clients for an additional fee. RoseCap Investment Services Clients who are part of RoseCap’s Investment Services group (“RIS”) is designed to provide a low-cost solution for clients who require a minimal level of financial service but are still not comfortable handling their investments themselves. RIS clients are typically charged a lower fee rate. Asset management services provided to RIS clients include: - Account set-up and guidance with appropriate account type selection.
- Risk questionnaire designed to find client’s risk tolerance.
- Placement of client in low-cost ETF portfolio to match their risk tolerance.
- Ad hoc reviews as client circumstances change or upon request (limited to one meeting per year).
- Periodic reporting of portfolio holdings and performance.
In-depth financial planning services may be provided to RIS clients for an additional fee. Investment Methods RoseCap specializes in goal-based investment strategies. This means that RoseCap will assess the client’s investment goals and then create an investment strategy that we believe provides the client with the best chance of achieving those goals. RoseCap realizes that investment returns are never certain. Therefore, we aim to assist clients with earning the maximum amount of return, given a specified level of risk, and thus provide the client with the highest probability of reaching their financial goal. Our investment strategies focus on broader asset classes for target investment allocations rather than individual securities. Therefore, a high percentage of the securities recommended by RoseCap are exchange traded funds (ETFs). However, RoseCap also has the capabilities to analyze individual stocks, bonds, mutual funds, derivatives, or alternative investments, and may recommend these to clients from time to time. We generally believe capital markets are efficient – semi-strong form efficient market hypothesis. Although RoseCap generally maintains discretion over client accounts, clients may impose restrictions on investing in certain asset classes, securities, or types of securities. RoseCap tailors investment advisory services to the individual needs of the client by creating an Investment Policy Statement (“IPS”) for each client. The IPS addresses the specific risk preferences, return objectives, and investment constraints of the client. Also, the IPS will state any restrictions the client desires on the securities or types of securities that may be invested in. RoseCap then places the client in a portfolio that matches, as closely as possible, the client’s risk and return objectives as stated in the IPS. Approximately 95% of assets under management are managed on a discretionary basis.