A. Description of the Advisory Firm
This firm has been in business since August 7, 2007, and the principal owner is Mark Royal Sorensen.
B. Types of Advisory Services
Royal Fund Management (hereinafter "RFM") offers the following services to advisory clients:
Investment Supervisory Services
RFM offers ongoing portfolio management services based on the individual goals, objectives, time
horizon, and risk tolerance of each client. RFM creates an Investment Policy Statement for each client,
which outlines the client's current situation (income, tax levels, and risk tolerance levels) and then
constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches
each client's specific situation. Investment Supervisory Services include, but are not limited to, the
following:
•Investment strategy
•Personal investment policy
•Asset allocation
•Asset selection
•Risk tolerance
•Regular portfolio monitoring
RFM evaluates the current investments of each client with respect to their risk tolerance levels and
time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given
to each client.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment planning; life
insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These
services are based on fixed fees or hourly fees, and the final fee structure is documented in Exhibit II
of the Financial Planning Agreement.
Financial Consulting Services - Advice on Held Away Assets
We offer financial consulting services that primarily involve advising clients on specific financial-related
topics. More specifically, we offer assistance to clients who seek advice in choosing and allocating
investments within their variable annuity or other held away assets.
Selection of Other Advisers
As part of our investment advisory services, we may recommend that you use the services of a third
party money manager ("MM") to manage all, or a portion of, your investment portfolio. After gathering
information about your financial situation and objectives, we will recommend that you engage a specific
MM or investment program. Factors that we take into consideration when making our
recommendation(s) include, but are not limited to, the following: the MM's performance, methods of
analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives.
We will periodically monitor the MM(s)' performance to ensure its management and investment style
remains aligned with your investment goals and objectives.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
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and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature (a 3(21) fiduciary) but, depending on the engagement, we may also agree to serve
as a 3(38) fiduciary. The ultimate decision to act on behalf of the plan shall remain with the plan
sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services), shall be detailed in a written agreement and be consistent with the parameters set forth in
the plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Services Limited to Specific Types of Investments
RFM limits its investment advice and/or money management to mutual funds, equities, bonds, fixed
income, debt securities, ETFs, real estate, REITs, insurance products including annuities and
government securities. RFM may use other securities as well to help diversify a portfolio when
applicable.
We offer Non-Traded REITs from Cantor Fitzgerald. We also offer a StoneCastle Program, which is
an FDIC cash alternative from which StoneCastle will pay us 0.10% of the yield. This presents a
conflict of interest since we have a financial incentive to recommend the StoneCastle Program over
other cash alternatives. You are under no obligation, however, to accept any recommendation that we
may provide.
Participant Account Management
Royal Fund Management, LLC, under the Other Business Name of 401(k) Maneuver, offers assistance
to plan participants who seek advice in choosing and allocating investments within their 401(k), 403(b),
457 or similar defined contribution plan.
Participant Account Management (Non-Discretionary)
Adviser will provide Quarterly Allocation Recommendations on a non-discretionary basis.
Recommendations will consider clients' investment goals and risk tolerance and will be evaluated
based on analysis of current economic and market conditions and trends. The goal of the Quarterly
Allocation Recommendations is to potentially optimize performance over the long term and to provide
downside risk management. Quarterly Allocation Recommendations are sent to the clients via email
within 5 days after the end of each calendar quarter. If client elects to follow any recommendations
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received from Adviser, Client
is solely responsible for implementation of any such recommendations;
Adviser will not implement transactions or act as custodian for any 401(k) accounts or similar defined
contribution accounts.
Participant Account Management (Discretionary)
We use a platform provided by Pontera Solutions, Inc (formerly FeeX, Inc.) ("Pontera") to manage held
away assets such as defined contribution plan participant accounts, with discretion. The Pontera
platform allows us to avoid being considered to have custody of Client funds since we do not have
direct access to or direct use of Client log-in credentials to affect trades. We are not affiliated with
Pontera in any way and receive no compensation from Pontera for using their platform.
A link will be provided to the Client allowing them to connect an account(s) to the platform provided by
Pontera. 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 by Adviser. Client will
receive an email notification every time their account is reviewed.
C. Client Tailored Services and Client Imposed Restrictions
RFM offers the same suite of services to all of its clients. However, specific client financial plans and
their implementation are dependent upon the client Investment Policy Statement, which outlines each
client's current situation (income, tax levels, and risk tolerance levels) and is used to construct a client
specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets.
As part of our portfolio management services, in addition to other types of investments, we may invest
your assets according to one or more strategies developed by our firm. These strategies 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
these strategies may set restrictions on the specific holdings or allocations within the strategy or on the
types of securities that can be purchased in the strategy.
D. Wrap Fee Programs
RFM does not participate in any wrap fee programs.
E. Amounts Under Management
RFM has the following assets under management:
Discretionary
Amounts:
Non-discretionary
Amounts:
Date Calculated:
$1.215.013.663$146.835.754 02/29/2024
F. Plan-Level Retirement Plan Advisory Services
RFM provides a broad range of services to qualified retirement plans ("Plans") with an emphasis on
participant-directed account programs such as 401(k) Plans. For example, the following investment
services may be selected by the Plan and are rendered by RFM as an ERISA fiduciary:
1. Plan-level Investment Advice. RFM will serve in a discretionary investment manager role
(known as an ERISA 3(38) Manager) or in a non-discretionary investment advisor role (known
as an ERISA 3(21) Advisor). In either case, RFM may be working with (i) the investment
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options and asset classes to be offered under the Plan to its participants, (ii) the establishment
of a qualified default investment alternative (known as a QDIA), or (iii) establishing a risk-based
asset allocation for different strategies we might use.
2. Investment Policy Statement. RFM will work with the Plan on the establishment of an
appropriate investment policy statement.
RFM also provides non-fiduciary consulting and support to Plans. For example, RFM provides
investment education to Plan participants about the Plan, how to enroll, and the importance of saving
for retirement. RFM also provides non-fiduciary plan education and information to the employer in its
role as the Plan sponsor.
The complete list of services to be provided to Plans, the RFM advisory fee schedule and all other
governing terms and conditions of the Plan Advisory Services arrangement (which may vary from
those otherwise disclosed in this Form ADV Part 2a), are set forth in the Retirement Plan Investment
Advisory Agreement, which every Plan must execute with RFM.
G. IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
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