A. Firm Information
Regatta Capital Group, LLC (“Regatta” or the “Advisor”) is
a registered investment advisor with the U.S. Securities
and Exchange Commission (“SEC”), which is organized
as a Limited Liability Company (“LLC”) under the laws of
the State of California. Regatta was founded in November
2007 and is owned and operated by Russell Mohberg (Co-
founder, Partner, and Chief Compliance Officer) and
Spencer Kelly (Co-founder, Partner, and Head of Advisory
Services). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the
advisory services provided by Regatta.
B. Advisory Services Offered
Regatta offers investment advisory services to individuals,
high net worth individuals, pension and profit-sharing
plans, corporations, charitable organizations, and
institutional investors (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. Regatta’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
Regatta provides Clients with wealth management
services, which generally include a broad range of
comprehensive financial planning and consulting
strategies as well as discretionary and non-discretionary
management of investment portfolios.
Investment Management Services – Regatta provides
customized investment advisory solutions for its Clients.
This is achieved through continuous personal Client
contact and interaction while providing discretionary and
non-discretionary investment management and consulting
services. Regatta works with each Client to identify their
investment goals and objectives as well as risk tolerance
and financial situation in order to create a portfolio
strategy. Regatta will then construct a portfolio consisting
of low-cost, diversified mutual funds and/or exchange-
traded funds (“ETFs”) to achieve the Client’s investment
goals. The Advisor may also utilize individual stocks,
bonds, and options, as appropriate, to meet the needs of
its Clients.
Regatta selects, recommends, and/or retains mutual
funds on a fund by fund basis and seeks to use non-retail
or institutional classes when possible. Due to specific
custodial or mutual fund company constraints, material tax
consideration, and/or systematic investment plans,
Regatta may select, recommend, and/or retain a mutual
fund share class that has a higher expense ratio than an
equivalent share class. Regatta will seek to select the
lowest cost share class available that is in the best interest
of each Client and will ensure the selection aligns with the
Client’s financial objectives and state investment
guidelines.
Regatta’s investment strategy is primarily long-term
focused, but the Advisor 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. Regatta 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.
Regatta evaluates and selects investments for inclusion in
Client portfolios only after applying its internal due
diligence process. Regatta may recommend, on occasion,
redistributing investment allocations to diversify the
portfolio. Regatta 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. Regatta 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, changes in the risk tolerance of
the Client, generating cash to meet Clients’ needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
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 earns a new (or increases 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.
All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the Client
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investment advisory agreement; please see Item 12 –
Brokerage Practices.
Private Fund Advisor Services – Regatta may also
recommend that certain Clients who qualify as accredited
investors, as defined by Rule 501 of the Securities Act of
1933, and a “qualified purchaser” as that term is defined
in Section 2(a)(51)(A) of the Investment Company Act of
1940, invest in affiliated pooled investment vehicles (each
a “Fund” and collectively the “Funds”). Investing in
affiliated Funds presents a conflict of interest as
management persons benefit financially from additional
revenue. Additionally, the Advisor will charge its wealth
management fee described in Item 5 below for assets
invested in the Funds. Clients are under no obligation to
invest in affiliated Funds.
The Advisor serves as the investment manager of the
Funds, whereas an affiliated entity serves as the General
Partner. If a Client determines to invest in the Funds, the
amount of assets invested in the Funds shall be included
as part of “assets under management” for purposes of the
Advisor calculating its investment advisory fee per Item 5
below. The management of the Funds is described in the
relevant Fund’s Offering Documents. The Advisor’s
Clients are under no obligation to consider or make an
investment in the Funds. The Advisor does not receive a
separate advisory fee or other forms of compensation for
its investment advisory services to a Funds. Rather, the
Advisor’s only compensation is the advisory fee that it
receives from any value included as a part of its assets
under management. Please
see Item 10 for additional
details.
The Advisor manages each Fund based on the investment
objectives, policies, and guidelines as set forth in the
respective Offering Documents and not in accordance
with the individual needs or objectives of any particular
investor therein. Each prospective investor interested in
investing in a Fund is required to complete a subscription
agreement in which the prospective investor attests as to
whether or not such prospective investor meets the
qualifications to invest in the Fund and further
acknowledges and accepts the various risk factors
associated with such an investment.
In general, investors in the Funds are not permitted to
impose restrictions or limitations. However, the Advisor
may enter into side letter agreements with one or more
investors that may alter, modify, or change the terms of
interest held by investors. Certain types of side letters
create a conflict of interest between the Advisor and the
investors in the Fund and/or between investors
themselves.
For more detailed information on investment
objectives, policies and guidelines, please refer to the
respective Fund’s Offering Documents.
Financial Planning and Consulting Services – Regatta will
typically provide a variety of financial planning services to
individuals and families as part of its wealth management
services or pursuant to a written financial planning or
consulting 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, 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.
Regatta may also refer Clients to an accountant, attorney,
or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the
Advisor will provide a written summary of the 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 the contract date,
assuming all information and documents requested are
provided promptly.
Financial planning and consulting 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 would pose a
conflict, 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.
Retirement Plan Advisory Services
Regatta provides retirement plan advisory services on
behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement
plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and
its Plan Participants. Each engagement is customized to
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the needs of the Plan and Plan Sponsor. Services
generally include:
• Fee Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and
Monitoring
• Investment Oversight (ERISA 3(21))
• Investment Management (ERISA 3(38))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
Communication and Education - Regatta provides
Communication and Education to the Plan and the Plan
Participants, pursuant to the terms of the Advisor’s
agreement with each Plan Sponsor:
• Investment education
• Periodic on-site advisor visits with staff for account
updates and reviews
• Periodic Plan Participant group education
These services are provided by Regatta, serving in the
capacity of a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In
accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of Regatta’s
fiduciary status, the specific services to be rendered, and
all direct and indirect compensation the Advisor
reasonably expects under the engagement.
Transformational Coaching Services
Regatta’s financial advisor, Lisa Margulies, may offer to
Clients of Regatta, as well as the general public,
transformational coaching services. These services
consist of a highly developed series of coaching sessions
focused on identifying barriers to personal fulfillment and
breakthroughs to transforming one’s life.
C. Client Account Management
Prior to engaging Regatta to provide investment 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:
• Client Suitability – Regatta will document the Client
profile with financial statements or financial plans.
Regatta develops a statement that summarizes the
Client’s investment goals and objectives along with the
broad management strategy to be employed to meet
the Client’s objectives and ensure decisions made are
suitable for the Client.
• Asset Allocation – Regatta 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 – Regatta will develop a portfolio
for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – Regatta
will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Regatta does not manage or place Client assets into a
wrap fee program. Investment management services are
provided directly by Regatta.
E. Assets Under Management
As of December 31, 2023, Regatta manages
$1,162,612,228 in Client assets, $982,171,034 of which
are managed on a discretionary basis and $180,441,194
on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.