A. Firm Description
RGA Investment Advisors, LLC (“RGA” or the “Firm”) is an SEC-registered investment advisor.
RGA was founded in 2009. The Firm is principally owned by Jason Gilbert and Elliot Turner.
We consider ourselves “holistic” advisors, and as such we do market individual specialties. We
tailor advisory services to our clients’ needs and rely on our multidisciplinary experience in order
to serve specific needs. We do not impose restrictions on investments unless we deem them
inappropriate given our clients’ goals. We do not participate in wrap fee programs and consider
all our clients’ assets managed on a discretionary basis. Because assets are managed under full
discretion, clients may not impose restrictions on investing in certain securities or types of
securities.
B. Types of Advisory Services
The Firm offers investment advisory services to individuals, and high net-worth individuals, and
companies. The Firm offers these services to clients or potential clients (“clients”).
RGA specializes in quantitative, fundamental, technical, and economic analysis to determine what
investments are favorable. RGA Investment Advisors has been offering investment advisory
services since 2009. At this time, the firm provides both (i) supervisory services, investment
management services, and financial planning to individuals and corporations under a separately
managed account platform (“SMAs”), and (ii) investment management services to Soundview
Equity Partners LP, the Soundview Private Opportunities Fund, LP, Soundview Asia Partners
Holdings, LP, each of which is a private investment fund.
Investment Advisory Services
Separately Managed Account (“SMA”) Services: After a detailed discussion and review of your
information package, we will provide you with a formal write-up of our investment proposal. Once
approved, we will ask that you complete the Charles Schwab & Co., Inc. paperwork appended to
our proposal for expedited account set-up. You will retain full ownership of this account; we will
jointly have discretion over investment allocation, trade execution, and fee billing. Customized
portfolios of carefully selected investments are designed to provide consistent, superior
performance over time. It includes ongoing manager selection, rebalancing, and performance
reporting, and all services provided within our Investment Proposal. The annual fee starts at
2.00% of Assets Under Management (AUM) per year with a downward sliding scale for accounts
in excess of $500,000. This service is billed quarterly, in advance. More detail on this
particular fee structure can be seen under the “Fees” section in this brochure or on our website at
http://www.rgaia.com/fees.
Private Fund Management: RGA provides investment management services to Soundview Equity
Partners LP, the Soundview Private Opportunities Fund, LP, Soundview Asia Partners Holdings,
LP, Soundview Asia Partners Holdings II, LP, each of which is a private investment fund
(collectively, the “Funds”). The Funds are what is commonly referred to as 3(c)(1) funds, a term
which refers to a section of the Investment Company Act of 1940, as amended (the “ICA”). The
Funds are currently open to investors who are “accredited investors” as defined in Rule 501 of
Regulation D under the Securities Act of 1933, as amended (the “Securities Act”), and satisfy the
“qualified client” standard of the Investment Advisers Act of 1940, as amended (the “Advisers
Act”) (the “Investors”). Soundview Equity Partners GP LLC serves as the general partner of the
Funds (the “General Partner”). The text of this brochure relates to SMAs unless a Fund is
specified. RGA assesses clients’ current holdings and ensures alignment with both short-and long-
term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure
to market conditions. Accordingly, the Firm is authorized to perform various functions without
further approval from the client, such as the determination of securities to be purchased or sold
without prior permission from the client for each transaction. Any and all trades are made in the
best interest of the client as part of RGA’s fiduciary duty. However, risk is inherent to any investing
strategy and model. Therefore, RGA does not guarantee any results or returns.
Financial Planning Services: We offer comprehensive financial planning services to clients and
prospects
seeking more detailed and specific goal-based planning advice. For new prospects who
come to us with this service in mind, we will prepare these planning services before suggesting
any asset management services. We help clients work toward their goals in the areas of, Cash Flow
Management, Retirement Planning, Estate Planning, 7 College Funding, Asset Protection, Wealth
Accumulation and Tax wise investment strategies. Our financial planning services may be
included as part of our Investment Management Services relationship and the ultimate fee
charged will be outlined in the agreement with the client. We also provide a variety of standalone
financial planning and consulting services to clients for the management of financial resources
based upon an analysis of current situation, goals, and objectives. Following the initial financial
plan, clients can elect to receive ongoing consulting services including monitoring of the client’s
progress towards its goals, re-evaluation of investment allocations, advising with ongoing issues,
and year-end tax planning. All financial plans will be delivered within 6 months of execution of
the agreement.
Prior to engaging RGA to provide any investment advisory services, RGA requires a written
financial service agreement (“FSA”) signed by the client prior to the engagement of any services.
The FSA will outline services to which the client is entitled and fees the client will incur.
RGA is an asset-based fee investment management firm. The firm does not receive commissions
for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other
commissioned products for clients. The firm is not affiliated with entities that sell financial
products or securities. No commissions in any form are accepted.
RGA does not act as a custodian of client assets, except in the limited capacity of debiting client
accounts for agreed upon management fees. The client always maintains asset control. RGA
places trades for clients under a limited power of attorney through qualified custodian/broker.
Pontera
We provide an additional service for accounts not directly held in our custody, but where we do
have discretion, and may leverage an Order Management System to implement tax-efficient asset
location and opportunistic rebalancing strategies on behalf of the client. Our technology partner
for this solution is Pontera (
https://www.pontera.com/). These are primarily 401(k)
accounts, HSA’s, and other assets we do not custody. We regularly review the available investment
options in these accounts, monitor them, and rebalance and implement our strategies in the same
way we do other accounts, though using different tools as necessary All clients engaging in
Investment Management Services must either engage in Comprehensive Financial Planning or
meet a $500,000 minimum of assets under management. This fee will be assessed and billed
quarterly, in advance in accordance with our regular billing schedule.
If you elect to participate in this program, you will be notified via email when the Firm places trades
through Pontera implementing any and all changes to your account. The fees charged in these
situations are the same as described in the table below under “Fees and Compensation.” Fees are
paid separately on the management of these “held away” assets and clients may be provided an
invoice describing the fees. Suitability documentation will be held with the Plan Custodian and
cannot be changed by the Firm.
Responsibilities of RGA Investment Advisors: It is the responsibility of the Firm to establish and
maintain strategic direction of investment management and investment policy statement.
C. Services Tailored to Clients’ Needs
Services are provided based on a client’s specific needs within the scope of the services provided
as discussed above. A review of the information provided by the client regarding the client’s
current financial situation, goals, and risk tolerances will be performed and advice will be
provided that is in line with available information.
D. Wrap Fee Program
RGA does not offer a Wrap Fee Program.
E. Assets Under Management
As of December 31, 2023, the firm managed approximately $90,764,998 regulatory assets under
management (RAUM) on a discretionary basis and, separately, the Fund accounts, totaling
$18,959,278.