Item 1: Cover Page

Rockhaven Wealth Management

Form ADV Part 2A – Firm Brochure

1320 Willow Pass Road

Suite #600

Concord, CA 94520

(925) 222-5386

Dated October 23, 2017

 

 

 

This Brochure provides information about the qualifications and business practices of Rockhaven Wealth Management, “RWM”. If you have any questions about the contents of this Brochure, please contact us at (925) 222-5386. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.

Rockhaven Wealth Management is registered as an Investment Adviser with the State of CA. Registration of an Investment Adviser does not imply any level of skill or training.

Additional information about RWM is available on the SEC’s website at www.adviserinfo.sec.gov which can be found using the firm’s identification number 285017.

Item 2: Material Changes

Item 4: Since the most recent filing of the ADV, the firm has changed its services for Pension Consulting Services (Item 4) and its fees for this service (Item 5)

Future Changes

From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of RWM.

At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our CRD number 285017.

You may also request a copy of this Disclosure Brochure at any time, by contacting us at (925) 222-5386.

Item 3: Table of Contents

Contents

Item 1: Cover Page                                                                                                                            

Item 2: Material Changes

Item 3: Table of Contents                                                                                                                  

Item 4: Advisory Business                                                                                                                 

Item 5: Fees and Compensation                                                                                                       

Item 6: Performance-Based Fees and Side-By-Side Management                                                  

Item 7: Types of Clients                                                                                                                     

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss                                            

Item 9: Disciplinary Information                                                                                                       

Item 10: Other Financial Industry Activities and Affiliations                                                           

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading     

Item 12: Brokerage Practices                                                                                                            

Item 13: Review of Accounts                                                                                                            

Item 14: Client Referrals and Other Compensation                                                                         

Item 15: Custody                                                                                                                                

Item 16: Investment Discretion                                                                                                         

Item 17: Voting Client Securities                                                                                                      

Item 18: Financial Information                                                                                                         

Item 19: Requirements for State-Registered Advisers                                                                    

Form ADV Part 2B – Brochure Supplement                                                                                      

Item 2: Educational Background and Business Experience                                                          

Item 3: Disciplinary Information                                                                                                   

Item 4: Other Business Activities                                                                                                  

Item 6: Supervision                                                                                                                        

Item 7: Requirements for State Registered Advisers       

Item 4: Advisory Business

Description of Advisory Firm

Rockhaven Wealth Management is a Registered as an Investment Adviser with the State of California. We were founded in July 2016.  Tom Norris is the principal owner of RWM. RWM currently reports $268,000 in Discretionary Assets Under Management.

Types of Advisory Services

Educational Courses

RWM provides online education utilizing recorded videos and supporting downloadable materials on a variety of financial topics, which may include topics such as:

  • Cash flow management
  • Debt management
  • Developing a savings plan
  • Creating a basic financial plan
  • Planning for college expenses
  • Retirement readiness
  • Social Security options

Financial Planning

RWM provides financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives.

In general, the financial plan will address any or all of the following areas of concern. The client and advisor will work together to select the specific areas to cover. These areas may include, but are not limited to, the following:

  • Retirement Planning: Our retirement planning services include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (i.e., working longer, saving more, spending less, taking more risk with investments).

If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years.

  • College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to grandchildren (if appropriate).
  • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts.
  • Employee Benefits: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals.
  • Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts.

We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request.

  • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal.
  • Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure.

Cash Flow and Debt Management Plan. This is a three-month financial planning and coaching agreement helping clients to create a spending plan that fits their income, manage debt and create a plan to pay off debt, create an emergency savings account, and begin to address financial goals. Financial coaching is available at the end of the three-month engagement for an additional fee.

Your First Financial Plan This is a limited financial planning engagement in which RWM works with the client to create a basic financial plan covering net worth, cash flow, debt and liabilities, insurance and risk coverage, and retirement planning. Upon delivery of the plan, the client is responsible for implementation of any recommendations. Continued access to financial planning software, advisor email hotline, and an annual review of the plan is available for an additional fee.

Comprehensive Financial Planning

This service involves working one-on-one with a planner over an extended period of time. By paying a monthly retainer, clients get continuous access to a planner who will work with them to design their plan. The planner will monitor the plan, recommend any changes and ensure the plan is up to date.

Upon desiring a comprehensive plan, a client will be taken through establishing their goals and values around money. They may be required to provide information to help complete the following areas of analysis: net worth, cash flow, insurance, credit scores/reports, employee benefit, retirement planning, insurance, investments, college planning and estate planning. Once the client’s information is reviewed, their plan will be built and analyzed, and then the findings, analysis and potential changes to their current situation will be reviewed with the client. Clients subscribing to this service will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. If a follow up meeting is required, we will meet at the client’s convenience. The plan and the client’s financial situation and goals will be monitored throughout the year and follow- up phone calls and emails will be made to the client to confirm that any agreed upon action steps have been carried out. On an annual basis there will be a full review of this plan to ensure its accuracy and ongoing appropriateness. Any needed updates will be implemented at that time.

Investment Management Services

RWM is in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we develop a client’s asset allocation and risk tolerance target and create and manage a portfolio based on that target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background.

Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5 of this brochure.

Pension Consulting Services

Rockhaven Wealth Management offers advisory and consulting services to employee retirement plans (“Plan”) and to the Participants of those plans (“Participants”). The services are designed to assist Plan sponsors and their trustees in meeting their fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”). We will provide discretionary investment management services to institutional retirement (both ERISA and non- ERISA) plans and corporations, other business entities, and the Participants in the retirement Plans of those business entities. RWM will act as an ERISA 3(38) investment fiduciary to qualified plans.

RWM will act as a fiduciary and assist retirement plan sponsors and trustees in implementing, administering and evaluating retirement plans. Factors that RWM evaluates may include plan design, investment performance, plan cost, compliance, recordkeeping, participation levels, deferral percentages, asset allocation, technology and service provider capabilities.

RWM will assist plan sponsors and trustees with investment management of the plan. This may include creating an investment policy statement, model asset allocations including qualified default investment alternatives, selection of investment managers, and monitoring investment options against well-defined risk and return criteria.

Once a plan and service providers are selected, RWM will assist the plan sponsor and its trustees in educating the plan’s Participants on the benefits of the plan and implementing an investment strategy. RWM’s investment management services are predicated on the Participant’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances. RWM will analyze each Participant’s current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance to implement a portfolio consistent with such investment objectives, goals, risk tolerance, and related financial circumstances. RWM will work with Participants to maximize long-term return while not assuming unnecessary risk.

After developing an overall strategy, RWM will aid the Participant in implementing the plan. RWM may exercise discretion under limited power of attorney to effect an investment strategy on behalf of the Participant. RWM may implement changes in the Participant’s investment portfolio in consideration of changes in the Participant’s personal circumstances, investment objectives, and tolerance for risk, the performance record of any of the Participant’s investments, and/or the performance of any fund retained by the Participant, as well as based on changing economic and market outlooks.

On a quarterly basis, or more frequent timeframe if mutually agreed upon, RWM will prepare reports that show investment performance and fees for each Participant. These reports may be prepared through third-party custodians like John Hancock, Vanguard and TD Ameritrade. RWM will also contact Participants at least annually to determine whether there have been any changes in the Participant’s personal financial circumstances, investment objectives, and tolerance for risk.

RWM may utilize third-party software to analyze individual security holdings held in the Participant’s portfolio. RWM will monitor those portfolios and make additional recommendations and implementation decisions from time to time to rebalance and/or reallocate each Participant’s investments in accordance with such Participant’s investment circumstances, as applicable.

Additionally, RWM’s Educational Courses, Cash Flow and Debt Management Planning, and Your First Financial Plan are included for all employees at no extra cost.

Client Tailored Services and Client Imposed Restrictions

We offer the same suite of services to all of our 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. Clients may impose restrictions on investing in certain securities or types of securities. Clients will specify any restrictions they request, on the advisory agreement at the execution of the agreement.

Wrap Fee Programs

We do not participate in wrap fee programs.

CCR Section 260.235.2 Disclosure

For clients who receive our Financial Planning services, we must state when a conflict exists between the interests of our firm and the interests of our client.  The client is under no obligation to act upon our recommendation.  If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through our firm.

Item 5: Fees and Compensation

Please note, unless a client has received the firm’s disclosure brochure at least 48 hours prior to signing the investment advisory contract, the investment advisory contract may be terminated by the client within five (5) business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of advisory service we are performing. Please review the fee and compensation information below.

Educational Courses

Fees for online educational courses range from free to $500 per participant and are payable by credit or debit card. Fees are due upon registration (which provides access to the educational content) and are fully refundable upon request until five days after registration. Clients will have access to the course for 6 months after registration. If the course is not accessed, or not completed, during this time they can re-register at no cost by request via email.

Financial Planning Fee

Financial Planning is offered on a fixed fee basis. The fixed fee will be agreed upon before the start of any work. The fixed fee can range between $250.00 and $5,000.00. The fee is negotiable. If a fixed fee program is chosen, a third of the fee is due at the beginning of process and the remainder is due at completion of work, however, Rockhaven will not bill an amount above $500.00 more than 6 months in advance.

Cash Flow and Debt Management Plan

The fee for this three-month financial planning and coaching program is $397, and is negotiable. Continued access to the online planning portal is available for $15/month and is payable by check or credit card.

First Financial Plan

The fee for this limited financial planning engagement is $697, and is negotiable. Continued access to the online planning portal and an annual plan review is available for $49/month and is payable by check or credit card.

Comprehensive Financial Planning Fee

Our standard advisory fee for the Comprehensive Financial Planning is $150 per month paid in advance. If the Client would like to include investment management services, then there will be an additional fee of 0.50%, per year, based on the average daily market value of the assets. The annual fee is negotiable and is pro-rated and paid in advance on a quarterly basis. No increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current advisory agreement.

Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in advance. Upon termination of the account, any unearned fee will be refunded to the client.

Investment Management Services

Our standard advisory fee is:

Account Value Annual Advisory Fee
$0 – $1,000,000 0.90%
$1,000,000 and above 0.55%

 

The annual fees are negotiable and are pro-rated and paid in advance quarterly basis, and based on the average daily market value of the assets under management. The advisory fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart, resulting in a combined weighted fee. For example, an account with the average daily market value of $3,000,000 would pay an effective fee of 0.67%. This is determined by the following calculation: ($1,000,000 x 0.90%) + ($2,000,000 x 0.55%) = $20,000.00. No increase in the annual fee shall be effective without agreement from the client by signing a new agreement or amendment to their current advisory agreement.

Advisory fees are directly debited from client accounts, or the client may choose to pay by check. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 30 calendar days in advance. Upon termination of the account, any unearned fee will be refunded to the client.

Pension Consulting Services

Clients (Plan Administrators)  will be billed on a monthly or quarterly basis in arrears. The Custodian for the Qualified Plan will debit RWM’s fees from an omnibus account held at the custodian in the name of the Plan, and remit those fees to RWM.  The fee to be charged is notated on both RWM’s advisory agreement, and a separate agreement executed with the Custodian. RWM requires 30 days’ advance notice for termination of this service. Since fees are paid in arrears, upon termination, no refund will be due. Any prorated amount will be calculated and billed to the client for payment.

The current fee schedule will be as follows:

Market Value of Plan Assets Annual Participation Fee
Less than $1,000,000 0.80%
$1,000,000 -$4,999,999 0.50%
Greater than $5,000,000 0.30%

 

RWM is compensated through Sponsor Fees and Participant Fees only. RWM is not paid any commission, service or administrative fees for the sale of mutual funds, and does not receive compensation from any third-party to the Agreement for services.

Educational Courses

Fees for online educational courses range from free to $500 per participant and are payable by credit or debit card. Fees are due upon registration (which provides access to the educational content) and are fully refundable upon request until five days after registration. Clients will have access to the course for 6 months after registration. If the course is not accessed, or not completed, during this time they can re-register at no cost by request via email.

Other Types of Fees and Expenses

Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these commissions, fees, and costs.

Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client’s transactions and determining the reasonableness of their compensation (e.g., commissions).

We do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds.

The total fee charged to clients by adviser and sub-adviser will not exceed 3% of the client’s portfolio assets under management per year.

CCR Section 260.238(j) Disclosure

Please note, lower fees for comparable services may be available from other sources.

Item 6: Performance-Based Fees and Side-By-Side Management

We do not offer performance-based fees.

Item 7: Types of Clients

We provide financial planning and portfolio management services to individuals, high net worth individuals, pension and profit-sharing plans, and business entities.

We do not have a minimum account size requirement.

Item 8: Methods of Analysis, Investment Strategies and Risk of Loss

Our primary methods of investment analysis are fundamental, technical, cyclical and charting analysis.

Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance.

Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices.  However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them.

Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market.

Charting analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy.

We employ the use of sub-advisers (“outside managers”). Our analysis of outside managers involve the examination of the experience, expertise, investment philosophies, and past performance of the outside managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager’s compliance and business enterprise risks. A risk of investing with an outside manager who has been successful in the past is that he/she may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in an outside manager’s portfolio.  There is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily business and compliance operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies.

Passive Investment Management

We primarily practice passive investment management. Passive investing involves building portfolios that are comprised of various distinct asset classes. The asset classes are weighted in a manner to achieve a desired relationship between correlation, risk and return. Funds that passively capture the returns of the desired asset classes are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or exchange traded funds.

Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).

In contrast, active management involves a single manager or managers who employ some method, strategy or technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a designated benchmark. Academic research indicates most active managers underperform the market.

Material Risks Involved

All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other investment or security. Material risks associated with our investment strategies are listed below.

Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition.

Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.

Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio.

Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance.

Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate investments at prices we consider reasonable or favorable, or find buyers at any price.

Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments.

Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates.

Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances.

Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same.

Risks Associated with Securities

Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks.

Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default.

Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks.

Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.

Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations.

Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.

Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price.

Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected.

Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which client’s invest.

Item 9: Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of RWM or the integrity of our management. We have no information applicable to this Item.

Item 10: Other Financial Industry Activities and Affiliations

Tom Norris currently does not participate in other financial industry activities and is not affiliated with other financial firms.

No RWM employee is registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer.

No RWM employee is registered, or have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor.

RWM does not have any related parties. As a result, we do not have a relationship with any related parties.

RWM only receives compensation directly from clients. We do not receive compensation from any outside source. We do not have any conflicts of interest with any outside party.

Disclosure of Material Conflicts

All material conflicts of interest under CCR Section 260.238(k) are disclosed regarding RWM, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice.

Recommendations or Selections of Other Investment Advisers

As referenced in Item 4 of this brochure, RWM recommends clients to Outside Managers to manage their accounts. In the event that we recommend an Outside Manager, please note that we do not share in their advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5) and will be described to you prior to engagement. You are not obligated, contractually or otherwise, to use the services of any Outside Manager we recommend. Additionally, RWM will only recommend an Outside Manager who is properly licensed or registered as an investment adviser.

Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., and accepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities.

This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not shield associated persons from liability for personal trading or other conduct that violates a fiduciary duty to advisory clients. A summary of the Code of Ethics’ Principles is outlined below.

  • Integrity – Associated persons shall offer and provide professional services with integrity.
  • Objectivity – Associated persons shall be objective in providing professional services to clients.
  • Competence – Associated persons shall provide services to clients competently and maintain the necessary knowledge and skill to continue to do so in those areas in which they are engaged.
  • Fairness – Associated persons shall perform professional services in a manner that is fair and reasonable to clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such services.
  • Confidentiality – Associated persons shall not disclose confidential client information without the specific consent of the client unless in response to proper legal process, or as required by law.
  • Professionalism – Associated persons’ conduct in all matter shall reflect credit of the profession.
  • Diligence – Associated persons shall act diligently in providing professional services.

We will, upon request, promptly provide a complete code of ethics.

Our firm and its “related persons” (associates, their immediate family members, etc.) may buy or sell securities the same as, similar to, or different from, those we recommend to clients for their accounts. A recommendation made to one client may be different in nature or in timing from a recommendation made to a different client. Clients often have different objectives and risk tolerances. At no time, however, will our firm or any related party receive preferential treatment over our clients.

In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific securities transactions. Any exceptions or trading pre‐clearance must be approved by our Chief Compliance Officer in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation.

Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest

Neither our firm, its associates or any related person is authorized to recommend to a client, or effect a transaction for a client, involving any security in which our firm or a related person has a material financial interest, such as in the capacity as an underwriter, adviser to the issuer, etc.

Item 12: Brokerage Practices

Factors Used to Select Custodians and/or Broker-Dealers

Rockhaven Wealth Management does not have any affiliation with Broker-Dealers.  Specific custodian recommendations are made to client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm.

  1. Research and Other Soft-Dollar Benefits

We currently receive soft dollar benefits as a result of our relationship with TD Ameritrade Institutional, Division of TD Ameritrade, Inc., member FINRA/SIPC. A full description of these soft dollar benefits can be found below, in the section entitled “Services Available to us via TD Ameritrade”

  1. Brokerage for Client Referrals

We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.

  1. Clients Directing Which Broker/Dealer/Custodian to Use

We do recommend a specific custodian for clients to use, however, clients may custody their assets at a custodian of their choice.  Clients may also direct us to use a specific broker-dealer to execute transactions.  By allowing clients to choose a specific custodian, we may be unable to achieve most favorable execution of client transaction and this may cost clients money over using a lower-cost custodian.  Our primary recommended Custodian is TD Ameritrade.

Services available to us via TD Ameritrade

As disclosed above, RWM participates in TD Ameritrade’s institutional customer program and may recommend TD Ameritrade to clients for custody and brokerage services. There is no direct link between RWM’s participation in the program and the investment advice it gives to its clients, although RWM receives economic benefits through its participation in the program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving RWM participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to RWM by third party vendors. TD Ameritrade may also have paid for business consulting and professional services received by RWM’s related persons. Some of the products and services made available by TD Ameritrade through the program may benefit RWM but may not benefit its client accounts. These products or services may assist RWM in managing and administering client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help RWM manage and further develop its business enterprise. The benefits received by RWM or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, RWM endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by RWM or its related persons in and of itself creates a potential conflict of interest and may indirectly influence RWM’s choice of TD Ameritrade for custody and brokerage services.

Aggregating (Block) Trading for Multiple Client Accounts

Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment.

Item 13: Review of Accounts

Client accounts with the Investment Management Service will be reviewed regularly on a quarterly basis by Tom Norris. During the regular review the account’s performance is compared against like-managed accounts to identify any unacceptable performance deviation. Additionally, reasonable client imposed restrictions will be reviewed to confirm that they are being enforced. Events that may trigger a special review would be unusual performance, addition or deletions of client imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the firm or per client’s needs.

Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in the accounts, such as receipt of dividends and interest.

Item 14: Client Referrals and Other Compensation

We do not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals.

Item 15: Custody

RWM does not accept custody of client funds except in the instance of withdrawing client fees.

For client accounts in which RWM directly debits their advisory fee:

  • RWM will send a copy of its invoice to the custodian at the same time that it sends the client a copy.
  • The custodian will send at least quarterly statements to the client showing all disbursements for the account, including the amount of the advisory fee.
  • The client will prove written authorization to RWM, permitting them to be paid directly for their accounts held by the custodian.

Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.

Item 16: Investment Discretion

For those client accounts where we provide investment management services, we maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney which will grant our firm discretion over the account.  Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client.

Item 17: Voting Client Securities

We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the Client’s investment assets. If the client would like our opinion on a particular proxy vote, they may contact us at the number listed on the cover of this brochure.

In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward you any electronic solicitation to vote proxies.

Item 18: Financial Information

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to clients, and we have not been the subject of a bankruptcy proceeding.

We do not have custody of client funds or securities or require or solicit prepayment of more than $500 in fees per client six months in advance.

Item 19: Requirements for State-Registered Advisers

Tom Norris

Born: 1964

Educational Background

  • 1986, BA, Concordia University Irvine
  • 1990, MDiv, Concordia Seminary

Business Experience

  • 07/2016 – Present, Rockhaven Wealth Management, President and CCO
  • 07/2008 – Present, Bethany Lutheran Church, Teaching Pastor
  • 05/2016 – 08/2016, Signator Investors, Inc., Investment Adviser Representative
  • 10/2013 – 05/2016, Transamerica Financial Advisors, Investment Adviser Representative

Professional Designations, Licensing & Exams

FINRA Series 7: General Securities (This is an examination and not a license or designation)

FINRA Series 66: Uniform Combined State Law (This is an examination and not a license or designation)

Other Business Activities

Tom Norris is a Teaching Pastor at Bethany Lutheran Church. This activity accounts for approximately 10% of his time.

Performance Based Fees

Please refer to Item 6 of this brochure.

Material Disciplinary Disclosures

No management person at Rockhaven Wealth Management has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding.

Material Relationships That Management Persons Have with Issuers of Securities

Rockhaven Wealth Management, nor Tom Norris, have any relationship or arrangement with issuers of securities.

Conflicts of Interest

Pursuant to California Code of Regulations Section 260.238 (k) any material conflicts of interest regarding the investment adviser, its representatives or any of its employees are disclosed to the client prior to entering into any Advisory or Financial Planning Agreement.

Business Continuity Plan

RWM maintains a written Business Continuity Plan that identifies procedures related to an emergency or significant business disruptions, including death of the investment adviser or any of its representatives.

CCR Section 260.238(j) Lower fees for comparable services may be available from other sources.

 

 

 

 

 

 

 

 

 

 

Rockhaven Wealth Management

Form ADV Part 2B – Brochure Supplement

For

Tom Norris

CRD# 6260253

President, and Chief Compliance Officer

Dated September 27, 2016

This brochure supplement provides information about Tom Norris that supplements the Rockhaven Wealth Management (“RWM”) brochure. A copy of that brochure precedes this supplement. Please contact Tom Norris if the RWM brochure is not included with this supplement or if you have any questions about the contents of this supplement.

Additional information about Tom Norris is available on the SEC’s website at http://www.adviserinfo.sec.gov

Item 2: Educational Background and Business Experience

  • 07/2016 – Present, Rockhaven Wealth Management, President and CCO
  • 07/2008 – Present, Bethany Lutheran Church, Teaching Pastor
  • 05/2016 – 08/2016, Signator Investors, Inc., Investment Adviser Representative
  • 10/2013 – 05/2016, Transamerica Financial Advisors, Investment Adviser Representative

Item 3: Disciplinary Information

No management person at Rockhaven Wealth Management has ever been involved in an arbitration claim of any kind or been found liable in a civil, self-regulatory organization, or administrative proceeding.

Item 4: Other Business Activities

Tom Norris is a Teaching Pastor at Bethany Lutheran Church. This activity accounts for approximately 10% of his time.

Item 5: Additional Compensation

Tom Norris does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through RWM.

Item 6: Supervision

Tom Norris, as President and Chief Compliance Officer of RWM, is responsible for supervision.  He/She may be contacted at the phone number on this brochure supplement.

Item 7: Requirements for State Registered Advisers

  1. Tom Norris has NOT been involved in any of the events listed below.
    1. An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following:
      1. An investment or an investment-related business or activity;
      2. Fraud, false statements, or omissions;
  • Theft, embezzlement, or other wrongful taking of property;
  1. Bribery, forgery, counterfeiting, or extortion; or
  2. Dishonest, unfair, or unethical practices.
  1. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following:
    1. An investment or an investment-related business or activity;
    2. Fraud, false statements, or omissions;
  • Theft, embezzlement, or other wrongful taking of property;
  1. Bribery, forgery, counterfeiting, or extortion; or
  2. Dishonest, unfair, or unethical practices.
  1. Tom Norris has NOT been the subject of a bankruptcy petition at any time.