RFL provides management services called (“RFL Advisor Program”) or “Advisor
Program”) with RBC Correspondent Services (“RBC”) and Pershing acting as “custodian”
and offering back office support.
As of December 31, 2018, RFL has $85,526,241.00 of assets under management. All portfolios are managed on a discretionary basis.
RFL’s Investment Advisor Representative (“IA Rep” or “Financial Consultant” in
accordance with the Advisor Program Agreement) conducts an initial interview and
data-gathering questionnaire to determine the client's financial situation and
investment objectives, and to give the client the opportunity to impose reasonable
restrictions on the management of the account. Clients could leave standing
instructions with the IA Rep to refrain from investing securities or types of securities or
invest in limited amounts of securities. The IA Rep recommends a portfolio that may
consist of stocks, bonds, mutual funds, options, CDs, ETFs, and US government
securities. Based on client need, other securities may be considered (e.g., ADRs,
foreign equities, warrants, and commercial paper). An asset allocation will be
determined at the account set-up. Mutual funds will be offered at net asset value
(without sales charge), or may include no load funds.
Quarterly, the IA Rep will notify the client to contact the IA Rep if there have been any
changes in the client's financial situation or investment objectives, or to impose or
modify account restrictions. The IA Rep will contact or attempt to contact the client
periodically but no less than annually on these matters. It is the client's responsibility
to notify the IA Rep at any time there are changes. Clients may call in at any time
during normal business hours to discuss directly with the IA Rep about the client's
account, financial situation, or investment needs. Clients will receive from the
custodian/brokerage firm timely confirmations and at least quarterly statements
containing a description of all transactions and all account activity. The client will retain
rights of ownership of all securities and funds in the account to the same extent as if
the client held the securities and funds outside the program. In addition to custodial
statements, RFL makes available client quarterly Portfolio Review reports prepared by
RBC and are available per client’s request. The reports are customized at the account
set-up. RFL advisory recommends to all clients to review the performance statements
along the custodian statement to insure accuracy.
Financial Planning Services consistent with the individual client's tax status as well as their
financial risk/reward parameters and personal financial objectives. Planning may focus on
investments, insurance planning, taxes, retirement planning, risk management issues, and
goal setting including education funding, and/or estate plans. Investment recommendations
may consist of stocks, bonds, mutual funds, options, CDs, ETFs, and US government
securities. Based on client need, other securities may be considered (e.g., foreign equities,
warrants, and commercial paper). Vehicles such as variable life insurance or variable
annuities, disability and/or life insurance may also be recommended based on client needs
and objectives. The financial plan is only included with the RFL Advisor Program if requested
by the client.
Through its investment advisor representatives, RFL provides financial planning, consulting
and fee-only investment advisory services to individuals, pension and profit sharing plans,
trusts, estates or charitable organizations, corporations or other business entities. No
additional fees for these services.
Third Party Advisors
Cedar Capital/Broadmeadow Capital 155 N. Wacker Drive Chicago IL. 60606
Cedar Capital/Broadmeadow Capital uses a diversified strategy designed to achieve long-
term growth of principal with a slant toward downside protection. Fulcrum group a subsidiary
of RF Lafferty & Co., Inc. exclusively utilizes the Alpha Sector Allocator Premium Global
strategy discipline which takes advantage of relative attractiveness of domestic and
international equities, fixed income, real estate, gold and governments all through ETF
offerings.
Advisors Asset Management, Inc. (“AAM”), 18925 Base Camp Road, Suite 203, Monument, CO80132
AAM offers various strategies from Conservative Taxable, Core Plus Taxable, Credit
Opportunities, Mortgage Investment Portfolio, Short Term Tax Exempt, Core Tax Exempt,
Peroni Method and High 50 Dividend. Although these strategies are available, clients have
exclusively selected the Peroni Method. The Peroni Method generally seeks to provide capital
appreciation by investing in a portfolio managed based on the Peroni Method; the proprietary,
technically-based research strategy of the portfolio manager, Eugene E. Peroni, Jr., utilizing
a multi-cap equity strategy, securities may range from value to growth as market conditions
change or are anticipated. Cash levels generally do not exceed 20% of the value of the
portfolio under regular market conditions.
Broadmeadow Capital LLC 30 S Wacker Suite 1300 Chicago IL 60606 Alpha Sector series
These strategies seek to avoid loss and to participate in the market’s long-term growth by
investing in ETFs primarily equally weighted at rebalancing with a target maximum
allocation capped per asset class. As risk increases and ETFs turn ‘off’, subject to the
maximum cap, the proceeds are invested in a Short-term Treasury ETF. Among others, this
series includes the Broadmeadow AlphaSector Premium (US sector focus) and
Broadmeadow AlphaSector Allocator (global multi-asset class focus) strategies.
Empirical Asset Management Two Newton Executive Park 2227 Washington St, Suite 202 Newton MA 02462 EAM Asset Allocation portfolios are driven by our Rules Based Investing® philosophy and
are designed to meet a broad range of investment objectives and risk tolerances. The series
consists of five models, with equity exposure and risk increasing as we move from
conservative to more aggressive models. Risk Management delivered through diversification
both across and within asset classes, combination of active and passive management, and
precision asset allocation through targeted ETF holdings, periodic rebalancing to enhance
returns and manage risk and a tax conscious approach utilizing ETF investing and tax-
sensitive rebalancing.
State Street Global Advisors One Lincoln Street, Boston, MA 02111-2900. SSGA Strategic ETF Model Portfolios for RBC Correspondent Services RBC Correspondent Services and State Street Global Advisors (SSGA), the investment
management arm of State Street Corporation, have joined together to provide sophisticated
asset allocation strategies on the RBC platform. SSGA Strategic ETF Model Portfolios,
powered by SPDR® ETFs, give you access to a disciplined asset allocation program that can
align with their investment strategy. These ETF portfolios seek to provide diversification
through a wide range of asset classes that have historically been difficult for individual
investors to access.
Strategic Asset Allocation is a core capability of SSGA’s Investment Solutions Group and
forms the foundation for many services we offer. The investment process for a typical
strategic asset allocation begins with return and risk objectives. The portfolio construction
process uses long-term asset class return, risk and correlation forecasts to identify an asset
allocation that efficiently balances these objectives. These allocations are then carefully
refined by our experienced portfolio management team and finalized. We believe the
strategic model portfolios highlighted below prudently span the efficient frontier and can be
utilized as core allocations by investors with a diverse set of return and risk objectives.
ADP Retirement Plan Investment Management Services R.F. Lafferty & Co., Inc. provides investment advisory services to assist plan sponsors, plan
administrators and investment committees to meet their ERISA fiduciary responsibilities
under ERISA § 3(21).
We share fiduciary responsibility with plan administrators and investment committees as it
relates to the assets. As a part of a client’s fiduciary team, R.F. Lafferty & Co., Inc. provides
the investment expertise to implement the plans investment policies and objectives.
ADP Retirement Plan Services solely determines and utilizes outside sources for Trustee and
Custodian services of all plan assets.
ADP Retirement Plan Services acts as the third-party administrator (
record-keeper) for all
plans.
For the purposes of ERISA § 3(21), R.F. Lafferty & Co., Inc. does not exercise any
discretionary authority or control respecting management of the plan or disposition of its
assets or have any discretionary authority or discretionary responsibility in the administration
of the plan. Therefore, we are not a “fiduciary” pursuant to ERISA except to the extent we
render “investment advice” to the plan within the meaning of section 3(21) of ERISA and
Department of Labor regulations there under.
The participants are responsible for any individual investment selections made under the plan.
Under ERISA § 3(21), R.F. Lafferty & Co., Inc. acts as the advisor making investment
recommendations, but it is ultimately up to the plan sponsor and plan participants to decide
whether and how to implement these recommendations. Furthermore, under ERISA § 3(21),
the participants are responsible for any individual investment selections made under the plan.
Under ERISA § 3(21), Mesirow Financial acts as Co-Fiduciary with regard to the plans
Investment Policy Statement. Mesirow Financial offers their services as an option to Plan
Sponsors who seek to develop an Investment Policy Statement for their retirement plans.
Mesirow Financial provides the guidelines for selecting and evaluating investments offered in
the plan. Mesirow Financial provides the Investment Policy Statement and provides services
regarding investment selection, monitoring, benchmarking, and de-selection.
R.F. Lafferty & Co., Inc. works with Mesirow Financial to establish and manage a process to
select, de-select, benchmark and monitor investments offered to plan participants. Together
we will regularly evaluate the plan’s investment offerings in accordance with the Investment
Policy Statement guidelines.
Investment Committee Meetings – R.F. Lafferty & Co., Inc. meets regularly with the Plan
Investment Committees to document the performance of the plan’s investments and to make
any recommendations that may be appropriate for changes. These meetings are documented
and become part of the plan’s due diligence file.
Participant Communication – R.F. Lafferty & Co., Inc. will provide group meetings (up to
quarterly) and individual participant meetings to help participants achieve better financial
results. The schedule, timing and number of meetings shall be determined prior to contract
acceptance.
ERISA 3(21) and 3(38) fiduciary investment advisory services defined by the Employee
Retirement Income Security Act of 1974 (ERISA): An ERISA 3(21) fiduciary investment
advisor serves as an investment fiduciary by making investment recommendations to the plan
sponsor.
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Fees for RFL Advisor Program are computed at an annualized percentage of assets under
management on a sliding scale. All fees are negotiable. There are 3 options available;
SCHEDULE A
MANAGED ACCOUNT FEE SCHEDULE
Please select the appropriate option from below:
● Option 1. __________ (Please Initial)
ASSET TOTAL
ASSET FEE
(Maximum Allowable)
FEE TO
CLIENT
$25,000 - $100,000 *
2.00%
$100,001 - $500,000
1.90%
$500,001 -
$1,000,000
1.75%
$1,000,001-
$2,000,000
1.50%
$2,000,001 -
$3,000,000
1.25%
$3,000,001 -
$5,000,000
1.00%
$5,000,001 -
$10,000,000 .75%
$10,000,001 and
above Negotiable
* Minimum advisory account size is $25,000.
● Option 2. __________ (Please Initial)
Note: Minimum rate of $200/hour to be invoiced quarterly,
in arrears, by R. F. Lafferty & Co., Inc.
Hourly Rate: $____________________
● Option 3. __________ (Please Initial)
Note: All fees to be invoiced in arrears by R. F. Lafferty & co., Inc.
a. Fixed Fee: $____________________
b. Fixed Fee Billing option: ______________ Quarterly
______________ Semi-annually
______________ Annually
For RFL Advisor Program the fee will be payable quarterly in advance. The first payment is
due and payable upon execution of the Agreement and will be assessed pro-rata in the
event the Agreement is executed other than the first day of the new calendar quarter.
Subsequent payments are due and will be assessed on the first day of each calendar quarter
based on the value of the portfolio as of the last day of the previous calendar quarter.
If a financial plan is requested by the client, the fee may be included under the RFL Advisor
Program. In almost all cases the cost is inclusive, and no additional fees required. If the
client requests, the IA Rep will quote a fixed fee ranging from $1,500 to $25,000,
depending upon the nature and complexity of services, the client’s financial situation, and
the anticipated time to be incurred. The IA Rep may require the full fee to be paid in
advance or a retainer fee (e.g., 50%) to be paid in advance with the balance due on
delivery of the written plan. The IA Rep may apply financial planning fees to offset first year
fees of the RFL Advisor Program, should the client choose to implement the Program.
These fees are for advisory services only and do not include any transaction fees or
commissions, which may be charged separately by the broker/dealer’s custodial firm. See
the section heading Brokerage Practices for more information. Mutual funds are purchased
at NAV or no-load, however transaction fees may apply.
Payment of fees may be paid direct by the client, or client may authorize RBC or Pershing as
the custodian holding client funds and securities to deduct RFL advisory fees direct from the
client account as prepared by RBC or Pershing on behalf of RFL. The custodian will provide
periodic account statements to the client. Such statements will reflect all fee withdrawals
made on behalf of RFL. It is the client’s responsibility to verify the accuracy of the fee
calculation.
Fees as published on the fee schedule may be negotiable.
Fees are not collected for services to be performed more than six months in advance.
In addition to fees paid for advisory services with respect to clients' investments in mutual
funds, and in accordance with the mutual fund’s prospectus, clients pay additional fees on
the mutual fund investment because the mutual funds also pay advisory and/or
management fees to an investment advisor.
IA Reps of RFL are also Registered Representatives (“RRs”) of RFL, a broker/dealer, and as
such may receive commission-based compensation for the sale of securities and other
investment products. RFL and its IA Reps do not double-dip, and will either receive fee-
based compensation or commissions on specified assets. Mutual funds recommended under
advisory services will be “no-load” or “load-waived.” Client will not pay the advisory fee for
mutual funds held in the RFL Advisor Program that were purchased from RFL as a
broker/dealer with a front-end sales load until the client has held those shares for at least
two years from the date of the initial purchase. In the case where a client invests in a
mutual fund, the client may also indirectly pay for the expenses and advisory fees charged
by the mutual fund companies in which they invest. Clients are not obligated to purchase
investment products recommended, or to purchase through our firm or affiliated firms.
RFL’s primary business is as a broker/dealer.
For the RFL Advisor Program, services will continue until either party terminates the
agreement upon receipt of written notice. If termination occurs prior to the end of a calendar
quarter, a pro-rata refund of unearned fees will be made to the client, provided that the
minimum annual fee requirement in the amount of $100.00 has been satisfied. Upon
termination of the Agreement, it is solely Client’s responsibility to issue instructions regarding
disposition of the assets in the account. As of the date of termination, RFL will no longer be
the investment advisor of record, and it will be Client’s responsibility to monitor the timely
disposition of the account and take all future actions regarding the management of the
account.
For financial planning, the client may terminate the Agreement at any time and a refund of
the unearned fees, if any, will be made based on time and effort expended before termination.
The Agreement for financial planning terminates upon delivery of the plan. When the IA Rep,
in writing, confirms with client that the financial plan has been completed, no refunds will be
made, and payment is due in full.
Termination of Advisory Relationship. A client agreement may be terminated at any time, by either party, for any reason upon
written notice of either party. The client has the right to terminate an agreement without
penalty within five (5) business days after entering into the agreement. Clients will receive,
where applicable, a prorated refund of any prepaid advisory fees. Additionally, if a client
doesn’t receive the Brochure Document within 48 hours prior to signing the contract client
has (5) business days in which to cancel the contract, without penalty. Any prorated refund
will be based upon actual services incurred up to and at the time of termination.
If termination occurs prior to the end of a calendar quarter, a pro-rata refund of unearned
fees will be made to the client.
The Advisory Agreement contains a pre-dispute arbitration clause. Client understands that
the agreement to arbitrate does not constitute a waiver of the right to seek a judicial forum
where such a waiver would be void under the federal securities laws. Arbitration is final and
binding on the parties.
General Information about Fees
Fee Calculation
The fee charged is calculated as described above and is not charged on the basis of a share
of capital gains upon or capital appreciation of the funds or any portion of the funds of an
advisory client (Section 205(a)(1) of the Advisers Act).
Termination of Advisory Relationship.
A client agreement may be terminated at any time, by either party, for any reason upon
written notice of either party. The client has the right to terminate an agreement without
penalty within five (5) business days after entering into the agreement. Clients will receive,
where applicable, a prorated refund of any prepaid advisory fees. Any prorated refund will be
based upon actual services incurred up to and at the time of termination.
Mutual Fund Fees
All fees paid to RFL for investment advisory services are separate and distinct from the fees
and expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund's prospectus. These fees will generally include a management fee,
other fund expenses, and a possible distribution fee. If the fund also imposes sales charges,
a client may pay an initial or deferred sales charge. A client could invest in a mutual fund
directly, without the services of RFL. In that case, the client would not receive the services
provided by RFL which are designed, among other things, to assist the client in determining
which mutual fund or funds are most appropriate to each client's financial condition and
objectives. To the extent that client assets are invested in money market funds or cash
positions, the fees for monitoring those assets are in addition to the fees included in the
internal expenses of those funds paid to their own investment managers, which are fully
disclosed in each fund’s prospectus. Accordingly, the client should review both the fees
charged by the funds and the fees charged by RFL to fully understand the total amount of
fees to be paid by the client and to thereby evaluate the advisory services being provided.
Trading and other Costs
All fees paid to RFL for investment advisory services are separate and distinct from transaction
fees and/or custodian fees charged by broker dealers associated with the purchase and sale
of equity securities and mutual funds. In addition, fees do not include the services of any co-
fiduciaries, accountants, brokers or attorneys.
Direct Debiting of Client Accounts
Advisory fees may be directly debited from a client account only if the client provides written
authorization permitting RFL’s fees to be paid directly from the client's account held by an
independent custodian and the custodian agrees to send to the client a statement, at least
quarterly, indicating all amounts disbursed from the account including the amount of advisory
fees paid directly to RFL.
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RFL does not charge Performance-Based Fees. RFL does not engage in Side-By-Side
Management.
TYPES OF INVESTMENTS
RFL is disclosing those risks and opportunities for basic types of securities used in the Advisor
Program. Investing in securities involves risk and the potential loss.
● Stock represents ownership in a company. If the company prospers and grows, the
value of the stock should increase. Even if a company is profitable, the stock prices
are subject to “market risk” which is attributable to investor attitudes. Stock
ownership in more established companies is more conservative, while younger
companies provide the most risk and reward opportunities.
● Debt Securities (corporate or municipal bonds) are basically promissory notes that pay
interest and the return of principal at the end of a specified term. Credit risk is the
chance the issuer will fail to pay the interest payments on the security or to pay the
principal at maturity. Interest rate risk is that the market value of the bonds will go
down when interest rates go up. Prepayment risk is the chance that a bond will be
paid off early. For example, if interest rates fall, a bond issuer may decide to pay off
its debt. When this happens, the investor may not be able to reinvest the proceeds in
an investment with as high a return or yield.
● Mutual Fund is an investment pool, which may include money market instruments,
stocks, bonds, or other investment vehicles. Professional money managers research,
select, and monitor the performance of the securities the fund purchases. It is easier
to achieve diversification through ownership of mutual funds rather than through
ownership of individual stocks or bonds. Even with no-load or load-waived funds,
there are mutual fund expenses paid to the fund company. Investors may have to
pay taxes on capital gains distribution received by the fund, but not distributed to the
investor. Mutual funds redeem shares at net asset value (“NAV”) at the end of the
trading day.
● Exchange Traded Fund (“ETF”) holds securities to match the price performance of a
certain market index or commodity price. ETFs can track stock indexes and sectors,
bonds and precious metals. ETFs are subject to the same market risks as the index
or sector they are designed to track. ETFs can be bought and sold throughout the day
like stocks. ETFs may be an index fund or a fully transparent actively managed fund.
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RFL provides advisory services to individuals, pension and profit sharing plans, trusts,
estates, charitable organizations, corporations and other business entities.
RFL sets the initial minimum account size under the RFL Advisor Program at $50,000. RFL
may waive this minimum in its sole discretion.
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Methods of analysis may include, charting, fundamental, technical, cyclical, or a
combination thereof, based on the investment style of the IA Rep. Asset allocation
strategies are utilized as well. The IA Rep also evaluates the investments to determine
whether they correspond with the client’s financial objectives. The IA Rep will design and
propose a portfolio to assist the client in achieving his/her financial goals. Some IA Reps
may use margin as an investment strategy, whereas other IA Reps may use this strategy
based on a client’s needs.
By its nature, financial planning looks to the long-term. If a financial plan is provided, the
client's short-term cash needs and emergency funds are evaluated first, and then
investment and insurance strategies are designed to help the client attain his or her
financial goals. Casualty insurance (e.g. homeowner's, auto, liability, etc.) is reviewed only
at the client's request, and would be provided by an outside casualty firm.
While there is risk in all investments, some carry a greater degree of risk or higher costs.
There is no guarantee that the investment strategy selected for the client will result in the
client’s goals being met, nor is there any guarantee of profit or protection from loss. For
those investments sold by prospectus, clients should read the prospectus in full.
As a broker/dealer, RFL may buy and sell a variety of investments including but not limited
to: stocks, bonds, variable life, term, health and/or disability insurance, variable annuities,
mutual funds, US government securities, CDs, ETFs, options, and limited partnerships. As
an RIA, under the RFL Advisor Program the investments may be more limited, but can be
adjusted based on client need. All transactions will be monitored and reviewed by
supervision and required licensing required FINRA Exam 65 and/or 66.
RFL is disclosing those risks and opportunities for basic types of securities used in the
Advisor Program.
Client assets are managed by both outside managers. AAM/Peroni uses a proprietary method
of equity selection developed over two generations and is called Peroni Method.
Broadmeadow is a global investment risk avoidance management method monitoring relative
strength and volatility. The manager will take any client out an asset whereby they assess
any potential risk. The discipline controls and insures the portfolio weighting in any one asset
will not exceed 25% other than United States Treasury Bills.
The asset management discipline factors in fundamental as well as technical criteria using
tactical asset allocation with an eye toward trend following and monitoring both relative
strength and volatility with changes made in keeping with the age, asset base and risk
tolerance of each and every client.
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An investment advisor must disclose material facts about any legal or disciplinary event that
is material to a client’s evaluation of the advisory business or of the integrity of its
management personnel. As a state-registered firm, we are required to report an event that
is over 10 years old. In 1999, NASD (now FINRA, a self-regulatory organization) fined RFL
$5,000 for supervision violations for failure to establish, maintain, and enforce written
supervisory procedures relating to trade reporting and anti-competitive practices in regards
to such reporting failures. In 2013, The Firms (AML) Policies, Procedures, and internal
controls were not reasonably designed to monitor or detect, the cause and the reporting of
suspicious transactions, as required by the rule 3011(A) and rule 3310(A). The firm was
fined $50,000.00. In 2013, SEC rule 10B-10, SEC rules 606, 611(A)(B) AND (C) of
regulation NMS, FINRA Rule 2010, NASD rule 3010 - RFL. failed to provide written
notification disclosing to its customers that the transactions were executed at an average
price, or erroneously disclosed that the transactions were executed at a average price. The
matter was resolved by an executed (AWC) and fined $22,000.00. In 2015, RFL executed
an AWC for a settlement for a fine (5,000.00) related to trade reporting and compliance
engine (Trace).
10. OTHER FINANCIAL ACTIVITIES and AFFILIATIONS
RFL’s primary business is financial management, of which investment management is a major
component. RFL also offers comprehensive financial planning and consulting services. In
addition, RFL advisers may be registered representatives of RF Lafferty & Co., Inc. and may
be insurance licensed. These advisers may recommend securities and/or insurance products
to clients of RFL and may earn reasonable and customary commissions on the sale of such
securities and/or insurance products. Comparable insurance products may be available from
other sources at a lower price.
IA Reps of RFL are associated with RFL as Registered Representatives. R.F. Lafferty & Co.,
Inc. is a general securities broker/dealer having membership in the Financial Industry
Regulatory Authority. RFL is a diversified financial services company engaged in the design
and sale of investment products. We may recommend securities, asset management, or
insurance products offered by RFL or its affiliates. If clients purchase these products through
us, we will receive the normal commissions or fees associated, but RFL will not “double-dip”.
Thus, a conflict exists between our interests and those of advisory clients. The client is under
no obligation to purchase products recommended, or to purchase products either through us
or through RFL.
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PERSONAL TRADING
RFL has adopted a Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of
1940, as amended, to prevent violations of federal securities laws. The Code of Ethics is
predicated on the principle that RFL owes a fiduciary duty to its clients. Accordingly, RFL
expects all employees to act with honesty, integrity and professionalism and to adhere to
federal securities laws. All officers, directors, members and employees of RFL and any other
person who provides advice on behalf of RFL and is subject to RFL’s control and supervision
are required to adhere to the Code of Ethics. RFL’s Code of Ethics allows the purchase of IPOs
or private placements only with prior permission from RFL’s Chief Compliance Officer. Clients
may request to receive, at no cost, a copy of RFL’s Code of Ethics, which contains its policies
on employee trading, gifts, and outside business activities. Gifts of nominal value are
acceptable, and all employees must disclose any outside business activities generating
revenue, which must be approved by RFL’s Chief Compliance Officer.
Employee Trading Policy
From time to time, RFL may recommend to clients that they purchase or sell specific securities
or investments in which RFL or its related personnel have some financial interest. In addition,
RFL or individuals associated with RFL may buy, sell, or hold in their personal accounts the
same securities that RFL recommends to its clients and in accordance with its internal
compliance procedures. Such trades will occur simultaneously with or after trades placed on
behalf of clients.
Occasionally, investment objectives of clients are similar to that of RFL’s IA Reps, accordingly,
this may lead to personal investments made in the same securities that are recommended to
clients. However, RFL will always place the interests of clients ahead of
RFL and its employees. RFL’s policy is designed to avoid conflicts of interest with our clients
and we will not violate the Advisor's fiduciary responsibilities to our clients.
Participation or Interest in Client Transactions
RFL, as a broker/dealer is engaged in the investment banking business and market making.
Advisory and brokerage clients are limited from purchasing the stocks of companies while RFL
has current investment banking activity with the company, as these stocks will be placed on
the restricted list and no recommendations of these securities may be made. RFL Brokerage
Clients may purchase these securities on an unsolicited basis during the investment banking
period. If an RFL advisory client wishes to purchase a new issue security, the firm will not
take compensation (selling concession) on the transaction. The stocks of these companies
may be recommended to advisory and brokerage clients after the investment banking activity
has ceased.
General securities transactions
To minimize conflicts of interest, and to maintain the fiduciary responsibility RFL has for its
clients established the following policy: An officer, director, or employee of RFL shall not buy
or sell securities for a personal portfolio when the decision to purchase is substantially derived,
in whole or in part, by reason of employment with RFL, unless the information is also available
to the investing public on reasonable inquiry. No person associated with RFL shall prefer his
or her own interest to that of any client. Personal trades in securities being purchased or sold
for clients may be affected simultaneously with or after trades are effected for clients. RFL
personnel may not anticipate trades to be placed for clients. The client will always receive the
best executed price available at the time of trading.
Principal Trades
RFL, as a broker/dealer acts as a market maker. RFL does enter riskless principal trades with
brokerage client accounts. RFL does not enter into any principal trades with advisory
accounts.
Agency Cross Transactions
RFL does not enter any agency cross trades with advisory accounts.
Investment Management Services Reviews
While the underlying securities within Investment Management Services accounts are
continuously monitored, these accounts are reviewed no less frequently than annually.
Accounts are reviewed in the context of each client's stated investment objectives and
guidelines, ensuring that the structure of the portfolio is coordinated with these objectives.
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It is the objective of RFL to provide a means of allocating trading and investment opportunities
between advisory clients on a fair and equitable basis and in compliance with all applicable
state and federal guidelines. With respect to clients’ accounts with substantially similar
investment objectives and policies, RFL may often seek to purchase or sell a security in each
account. RFL will aggregate orders only when such aggregation is consistent with RFL’s duty
to seek best execution and is consistent with the investment objective of each client. No client
account will be unfairly favored over any other account.
Each client that participates in an aggregated order will participate based on the average
execution price in that security. All transaction costs will be allocated
pro rata based on each
client’s participation in the transaction. All securities purchased or sold, whether the order is
filled completely or partially, will then be allocated
pro rata based on the assets of each
account.
Selection or recommendation of broker/dealers
Because IA Reps are RRs with RFL, if clients freely choose to implement advice through us,
the broker/dealer is RFL. Under FINRA supervision rules, compliance monitoring is more
efficient by using RFL but required.
RFL performs "due diligence" on mutual funds, limited partnerships, and insurance products.
Only those investments that meet firm requirements will be on RFL’s "approved product list"
and be offered for sale to clients.
RFL does not have the incentive to select or recommend a broker/dealer based on its interest
in receiving client referrals.
Certain clients may direct RFL to use particular brokers for executing transactions in their
accounts. To the extent brokerage transactions are placed with particular broker dealers for
execution as directed by a client, RFL’ ability will achieve best execution available. Clients who
direct RFL to use particular broker dealers may pay higher commissions than those that do
not. RFL reserves the right to decline acceptance of any client account that directs the use of
a broker dealer other than RF Lafferty & Co., Inc., if RFL believes that the broker dealer would
adversely affect RFL’s fiduciary duty to the client and/or ability to effectively service the client
portfolio.
Soft Dollar Practices
RFL does not receive compensation or benefits in the form of “soft dollars” for research,
products and/or other services on investment advisory accounts.
please register to get more info
RFL Advisor Program: Each IA Rep is responsible to review accounts under his/her
supervision. The review may be done on a daily basis but no less than monthly. Changes
can occur in the portfolio at any time based on fundamental news regarding the economy,
client investments, and/or performance. A more comprehensive account review is done, on
a quarterly basis with an eye towards the asset allocation. Based on the IA Rep’s
philosophy and the client’s investment objectives, some portfolios will be more actively
traded and other securities will be held for the long term.
In addition, investment returns will be measured against the appropriate benchmarks in each
asset class. More frequent reviews may be triggered by material changes in variables such as
the client's individual circumstances, or the market, political or economic environment.
Reports
Clients will receive statements at least quarterly. Additionally, monthly statements will be
generated as a result of investment activity by the client's separate custodian. Confirmation
statements will be issued for all trading activity. Monthly and/or quarterly statements will
include portfolio holdings, dates and amounts of transactions, and current and prior statement
values. It's recommended to clients to review the custodian confirms and statements vs. the
quarterly reports to insure consistency and accuracy.
Financial Planning Reviews
Financial plans are designed by client request. Financial plans do not receive any
scheduled review or reports, except as re-engaged by the client. The IA Rep suggests that
clients meet with the IA Rep annually for reviews. Financial Planning Services terminate
upon the delivery of services. While the advice may include the recommendation for a
review or follow-up services, it is the client’s obligation to secure additional or follow-up
services with the IA Rep at the client’s discretion.
These client accounts will be reviewed as contracted for at the inception of the advisory
relationship.
Under the RFL Advisor Program, clients will receive a quarterly report, which will include at a
minimum commentary, portfolio summary, and portfolio allocation comparison. The report
design may include other pages and will be designated by the client at the account set-up.
The IA Rep can also prepare post-meeting communications and financial planning documents
upon request or at the IA Rep’s discretion. It's recommended to clients to review the custodian
confirms and statements vs. the quarterly reports to insure consistency and accuracy.
Management Reports
All client accounts are reviewed by the Branch Office Managers of RFL various office locations
and is reviewed by compliance staff and principals of the firm.
please register to get more info
RFL does not directly or indirectly receive or give any economic benefit for providing
investment advice or other advisory services to our clients from or to anyone other than our
clients.
Client Referrals & Other Compensation
Referral Fees Paid
RFL does not pay finders (solicitors) fees.
Referral Fees Received
RFL may offer various platforms or investment strategies based on client objectives; Resource
II and/or Total Strategy Cedar Capital, Sate Street and other platforms that are sponsored by
RBC.
Sales Awards
RFL in its capacity as a broker/dealer may receive incentive awards from mutual fund
companies. All allowable compensation is disclosed in the mutual fund prospectus.
Commission rates are set by each fund, and clients do not pay up for the additional
compensation. RFL may also receive additional compensation on stocks, bonds, partnerships,
and insurance, as may be applicable in the normal course of running a securities brokerage
business.
Advice offered by IA Reps in their capacity as RRs of RFL or agents of insurance companies,
may involve investments in mutual funds, variable insurance or variable annuities, which pay
commissions (including 12(b)-1 fee “trails” or other compensation) from the respective
product sponsor. All allowable compensation is disclosed in the prospectus.
Referrals & Other Compensation
Referral Fees Paid
RFL does not pay finders (solicitors) fees.
please register to get more info
RFL does not have authority to withdraw funds or to take custody of client funds or securities.
RBC as custodian maintains client funds and securities and is responsible for calculating and
deducting advisory fees on behalf of RFL.
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RFL may requests that it be provided with written discretionary authority to determine the
amounts of securities that are bought or sold. Any limitations on this discretionary authority
shall be included in this written authority statement. Clients may change or amend these
limitations as required. All such amendments shall be submitted in writing. When authorized
by the client, RFL generally has discretionary authority to make the following determinations
without obtaining the consent of the client before the transactions are effected: (1) which
securities are bought and sold for the account and (2) the total amount of securities to be
bought and sold. RFL’s authority in making investment related decisions may be limited by
account guidelines, investment objectives and trading restrictions, as agreed between RFL
and the client. RFL without discretion cannot perform automatic rebalancing, without prior
consent to each and every transaction.
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RFL does not vote proxies on behalf of its clients. Therefore, although RFL may provide
investment advisory services relative to client investment assets, RFL’s clients maintain
exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of
securities beneficially owned by the client shall be voted and (2) making all elections relative
to any mergers, acquisitions, tender offers, bankruptcy proceeding or other type events
pertaining to the client’s investment assets. RFL and/or the client shall correspondingly
instruct each custodian of the assets to forward to the client copies of all proxies and
shareholder communications relating to the client’s investment assets. The client may contact
RFL for additional information as relates to the proxy voting.
please register to get more info
Prepayments
RFL does not require or solicit prepayments of more than $500 in fees per client, six months
or more in advance.
Financial Condition
An investment advisor must provide financial information if a threshold of fee prepayments is
met; there is a financial condition likely to impair the ability to meet contractual commitments;
or, a bankruptcy within the past ten years. RFL does not have any disclosure items in this
section.
Bankruptcy
RFL has not ever been subject to a bankruptcy.
19. REQUIREMENTS FOR STATE ADVISORS
RFL advisers must pass and maintain the appropriate licensing requirement and
registration. To be an RIA you must have a FINRA Exam Series 63 & 65 and/or Series 66 or
a professional designation that allows you to conduct RIA business. Licensed insurance
agents will only offer services to clients residing in states in which the agent is registered.
Disclosures
Some RFL advisers may have disclosure information. The adviser will provide a Supplemental
Disclosure to all potential clients. In addition, the Supplemental Disclosure will be provided
upon request.
There are no disclosures of material facts related to arbitration or disciplinary actions involving
the management person.
There are no material relationships maintained by the advisory business or management
persons with the issuer of securities.
EDUCATION AND BUSINESS STANDARDS
Persons associated with RFL who provide investment advice to clients are required to have a
requisite licensing and qualifications, including several years of investment experience or
general business experience. Each IAR must also be registered in each State in which they
provide advisory services.
Officers of RIA BIOGRAPHICAL INFORMATION
Management and Supervision
Education and Business Background
Name: Robert Hackel CCO Investment Adviser
Ownership N/A
Year of Birth: 1972
Education: Pace University, NY, BA, Finance, 1994
Background: R.F. Lafferty & Co., Inc., NY, NY, Chief Operating Officer/Chief Compliance
Officer RIA, 12/1996 - Present
No reported disclosures
Name: Henry Hackel CEO Broker Dealer/President Of RIA
Ownership 75% or more
Year of Birth: 1943
Education: City College of New York, NY, BBA 1965
Brooklyn Law School, NY, JD 1968
Background: R.F. Lafferty & Co., Inc., NY, NY, President/Chief Compliance Officer BD,
1968-present
Pro-Ex LLC, NY, NY, President, 9/2000 – 01/2008
Harbor Capital Management, Stanford, CT, General Partner, 10/1991 –9/05
No reportable disclosures
Form ADV Part 2B
R.F. Lafferty & Co., Inc. (“RFL”)
Name of Supervised Person/IA
Rep
Robert “Rob” Hackel
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience
Education and Business Background
Name: Robert (“Rob”) Hackel
Year of Birth: 1972
Education: Pace University, NY, BA, Finance, 1994
Business: R.F. Lafferty & Co., Inc., NY, NY, Vice-President/Chief Compliance Officer RIA,
12/1996 - Present
Disciplinary Information
Rob Hackel does not have any disclosure items.
Other Business Activities
Rob Hackel is in the business of selling securities and insurance as fully disclosed in ADV 2A.
He does not have any other outside business activities.
Additional Compensation
All fee, commission, trail commissions, and sales awards are paid through RFL as fully
disclosed in ADV 2A. Mr. Hackel does not receive any additional compensation.
Supervision
Rob Hackel formulates his own investment advice. As the RIA Chief Compliance Officer, he
is responsible for supervision of advisory activities. Compliance staff will monitor Mr.
Hackel’s trading. Rob Hackel reports to Henry Hackel, the president of the firm. Henry
Hackel may be contacted at the phone number of the main office as shown on the cover
page. All disclosure items about the IA Rep are included in the ADV 2B supplemental
brochure.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first
brought, and the status.
Form ADV Part 2B
Brochure Supplement
Name of Registered Investment
Advisor
R.F. Lafferty & Co., Inc.
Address 40 Wall Street 19th Floor, New York, NY
10005
Phone Number 212-293-9090
Website Address
www.rflafferty.com Name of Supervised Person/IA
Rep
Michael J Bartolotta
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov
Educational Background and Business Experience
Name: Michael Bartolotta
Year of Birth: 1964
Mr. Michael Bartolotta is located;
333 Westchester Ave
White Plains NY 10604
914-220-9900
Michael Bartolotta, born in 1964, is Independent Contractor located at 333 Westchester
Ave. White Plains NY 10604. Mr. Bartolotta’s primary focus is developing relationships with
companies that utilize ADP for their 401(k) services.
Prior to joining RF Lafferty in 10/2015 Mr. Bartolotta was a Financial Advisor for Fulcrum
Securities & Fulcrum Advisory Services 9/2009-3/2016, responsible for developing
relationships with ADP clientele
He is also a Chartered Retirement Planning Counselor SM (CRPC) certified from the College
For Financial Planning.
Mr. Bartolotta is FINRA Series 6, 7 and 66 registered with RF Lafferty & Co., Inc.
Disciplinary Information
Mr. Bartolotta has events to disclose. Clients may view his history of any criminal or
disciplinary events and any customer complaints on the Investment Adviser Public Disclosure
site using his name or CRD #4450916.
Other Business Activities
Mr. Bartolotta no outside business activity.
Additional Compensation
Mr. Bartolotta does not receive any additional compensation beyond his commissions and fees
earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Bartolotta. Mr. Hackel can be reached at
212-293-9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding the subject of a bankruptcy petition, disclose that fact, the date
the petition was first brought, and the current status.
Form ADV Part 2B
William Dipence
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: William Dipenice
Year of Birth: 1951
Mr. William Dipenice is located;
333 Westchester Ave
White Plains NY 10604
Phone: (800) 783-1343
Business Experience Employment
Mr. Dipenice has over 30 years in the financial industry and has been with RF Lafferty from
07/2016 and has worked with John Hancock 4/80 -3/95, HSBC Brokerage 3/95 - 12/02,
Quick & Reilly 2/02 - 5/03, Capital Brokerage 06/03 -1/04, Terra Securities Corp 1/04-
11/04, Met Life Securities 11/04 -06/06 , Chase Investment Services 06/06 -06/12 and
Wells Fargo Advisers 06/12 to 7/16 prior to joining RF Lafferty.
Mr. Dipenice is FINRA Series 6, 7, 26, 63 and 66 registered with RF Lafferty.
None
Other Business Activities
PGB Energy Inc. Supply Natural Gas and Electric conversions to commercial properties.
Home office sales. --Non-financial sales position.
Supervision
Robert Hackel is responsible for supervising Mr. Dipenice. Mr. Hackel can be reached at
(212-293-9074).
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first
brought, and the current status.
Louis J. Ciavarella
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: Louis J. Ciavarella
Year of Birth: 1950
Investment adviser with RF Lafferty located;
150 North Radnor Chester Road
Suite F-200
Radnor, PA 19087
Phone: (877) 301-9988
Mr. Ciavarella started his financial career with 6/2009 Smith Barney in Berwyn,
Pennsylvania. He assisted clients develop strategies for portfolio construction, provided
investment advice and estate planning. Smith Barney later merged with Morgan Stanley and
became Morgan Stanley Smith Barney. Prior to Smith Barney, Mr. Ciavarella held positions
in marketing, program management and sales management in the information service
business of Unisys, a Fortune 500 company. Mr. Ciavarella has been a registered
investment advisor with Fulcrum Securities since February 2012 to February 2016.
Mr. Ciavarella earned a Bachelor of Art degree in Marketing from Michigan State University.
None
Other Business Activities
Mr. Ciavarella is FINRA Series 7 & 66 registered with RF Lafferty.
Additional Compensation
Mr. Ciavarella does not receive any additional compensation beyond his commissions and fees
earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Ciavarella. He can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first brought,
and the current status.
Form ADV Part 2B
Janice Arrott Ginsburg
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience
Name: Janice Arrott Ginsburg
Year of Birth: 1950
Janice Arrott Ginsburg, is an investment adviser with RF Lafferty located;
150 North Radnor Chester Road
Suite F-200
Radnor, PA 19087
Phone: (877) 301-9988
Education: University of Miami in Coral Gables, FL, Bachelor of Education and Mathematics, 1971
Florida Atlantic University in Boca Raton, FL, Education Administration, 1975
Business Background:
Fulcrum Securities, LLC, First Vice President, Wealth Management, 2/2012 to 2/2016
Janney Montgomery Scott LLC, Vice President, Wealth Management, 8/1989 to 2/2012
Thomson McKinnon Securities, Inc., Registered Representative, 2/1984 to 8/1989
Merrill Lynch, Registered Representative, 11/1981 to 2/1984
Ms. Ginsburg was awarded the designation of Certified Financial Planner CFP®
The awarded designation was obtained through extensive training and testing. This advisor is
held to the highest ethical standards along 30 hours annually of Continuing education.
None
Other Business Activities
Ms. Ginsburg is FINRA Series 7, 63 registered with RF Lafferty. Ms. Ginsburg is a member of
the Financial Planning Association of the Philadelphia Tri-State Area.
Additional Compensation
Ms. Ginsburg does not receive any additional compensation beyond his commissions and fees
earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Ms. Ginsberg. Mr. Hackel can be reached at 212-
293-9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first
brought, and the current status.
Form ADV Part 2B
Stephen N. Moss, Jr.
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Education and Business Background
Name: Stephen J. Moss
Year of Birth: 1968
Stephen J. Moss, is an investment adviser with RF Lafferty located;
150 North Radnor Chester Road
Suite F-200
Radnor, PA 19087
Phone: (877) 301-9988
Mr. Moss has been employed in the securities industry since 8/2004. He completed training
with AXA Equitable as a registered representative in 10/ 2004 - 10/2008. Prior to joining RF
Lafferty he was employed with Fulcrum Securities (July 2013 - Feb 2016), Woodbury Financial
Services, Inc. from December 2008-July 2013. Mr. Moss attended Delaware County
Community College where he earned an Associate Degree in Natural Sciences. He continued
his education at the University of South Florida in Tampa as genetics major and finally
transferred to Drexel University working towards a degree in mathematics.
Mr. Moss has events to disclose. Clients may view his history of any disciplinary events and
any customer complaints or judgment liens on the Investment Adviser Public Disclosure site
using his name or CRD #4849568.
Other Business Activities
Mr. Moss is FINRA Series 7 & 66 licensed with RF Lafferty.
Mr. Moss is also the principal and 100% owner of Moss Insurance Group, Inc., a Pennsylvania
Corporation and licensed insurance agency. He currently devotes 25 hours per month, zero
of which is during trading hours, to this business. Mr. Moss is holds Life, Accident and Health
Insurance licenses in PA, NJ, NY, MD, NC, and FL. Mr. Moss also works at Overbrook Golf
Club.
Additional Compensation
As a licensed insurance agent, Mr. Moss may receive additional compensation beyond his fees
and commissions earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Moss. Mr. Hackel can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding. The subject of a bankruptcy petition, disclose that fact, the date
the petition was first brought, and the current status.
Form ADV Part 2B
Van D. Olmstead, Jr.
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett
- Compliance if you did not receive RFL’s brochure or if you have any questions about the
contents of this supplement. Additional information about IA Reps is available on the SEC’s
website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Education and Business Background
Name: Van D. Olmstead
Year of Birth: 1943
Van D. Olmstead, is an investment adviser with RF Lafferty located;
150 North Radnor Chester Road
Suite F-200
Radnor, PA 19087
Phone: (877) 301-9988
Mr. Olmstead is responsible for providing investment advisory services and brokerage services
to individual and institutional clients seeking professional advice. Mr. Olmstead was awarded
a Bachelor of Arts Degree by West Chester University in 1969. He attended Delaware Law
School of Widener University and the University of Delaware.
Mr. Olmstead was awarded the designation of Certified Financial Planner (CFP®) in 1990 and
the designation of Accredited Wealth Management Adviser (AWMA®) in 2006.Mr. Olmstead
has been employed in the securities industry since September of 1973. He completed training
with White, Weld, Inc. as a representative registered in December of 1975 when he passed
the Series 7 a New York Stock Exchange examination. Prior to joining RF Lafferty, he was
employed with Fulcrum Securities 9/2010-1/2016, Janney Montgomery Scott of Philadelphia
from 5/2001-9/2010 and Legg Mason 1/1989-5/2001.
None
Other Business Activities
Mr. Olmstead is FINRA Series 4, 7, 24 and 79 registered with RF Lafferty.
Mr. Olmstead is the President of the Kiwanis Club of Wilmington, DE.
Mr. Olmstead is the Vice President and a board member of the Kiwanis Foundation of
Wilmington, Inc. in West Chester, PA.
Mr. Olmstead is a member of the Board of Trustees for Congregation Beth Emeth in
Wilmington, DE.
Moss Insurance as a sales agent
Additional Compensation
Mr. Olmstead does not receive any additional compensation beyond his commissions and fees
earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Olmstead. Mr. Hackel can be reached at 212-
293-9034
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first
brought, and the current status.
Form ADV Part 2B
Advisor
10005
Phone Number 212-293-9090
Website Address
www.rflafferty.com Name of Supervised Person/IA
Rep
Kevin Cory
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Richard
Crockett - Compliance if you did not receive RFL’s brochure or if you have any questions
about the contents of this supplement. Additional information about IA Reps is available on
the SEC’s website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: Kevin Cory
Year of Birth: 1965
Mr. Kevin Cory is located;
40 Wall St
New York NY 10005
212-293-9900
Kevin Cory, born in 1964, is Independent Contractor located at 40 Wall St. New York NY
10005. Mr. Cory’s primary focus is developing relationships with clients and utilize platforms
Prior to joining RF Lafferty in 05/09/2017 Cory was a Financial Advisor for Chapin Davis
01/04/2010 till 03/10/2017, responsible for developing relationships with clientele
Mr. Cory is FINRA Series 7, 63 and 66 registered with RF Lafferty & Co., Inc.
Mr. Cory has events to disclose. Clients may view his history of any criminal or disciplinary
events and any customer complaints on the Investment Adviser Public Disclosure site using
his name or CRD #4450916.
Other Business Activities
Mr. Cory does have outside business activity. JOSEPH CORY HOLDINGS - TRUCKING COMPANY.
DIRECTOR - May be during business hours. November 2017 -Consulting Services 8 hours hours per
week during trading hours. April 2018 COO w-2 employee may be during business hours. Jan 2019
Advisory board member Awayk Health, non compensation attend quarterly meetings. St Joseph's School
- School Pre-K to 8 - Director - 0 compensation Awayk LLC- April 20,2018 Board member-inventory
light CPAP provider for the transportation and first responder unions- zero compensation
Additional Compensation Mr. Cory does receive any additional compensation beyond his commissions and fees earned
for providing advisory services on his outside business activities.
Supervision Robert Hackel is responsible for supervising Mr. Cory. Mr. Hackel can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding the subject of a bankruptcy petition, disclose that fact, the date
the petition was first brought, and the current status.
R.F. Lafferty & Co., Inc.
Address 40 Wall Street 19th Floor, New York, NY
10005
Phone Number 212-293-9090
Website Address
www.rflafferty.com Name of Supervised Person/IA
Rep
Athanasios Tomaras
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Thomas Herity -
Compliance if you did not receive RFL’s brochure or if you have any questions about the
contents of this supplement. Additional information about IA Reps is available on the SEC’s
website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: Athanasios Tomaras
Year of Birth: 1970
Investment adviser with RF Lafferty located;
3980 Tampa Road Suite 202
Oldsmar FL 33467
Phone: (212-293-9090)
Mr. Tomaras started his financial career at H & R Block Advisors Inc. in 1996. Mr. Tomaras
has been a registered investment advisor with RF Lafferty & Co., Inc. since July 2016.
Mr. Tomaras earned a Bachelor of Science degree from the University of Florida in chemistry
in May 1993
Mr. Tomaras does have disclosures that are available to review at
www.finrabrokercheck.com
Other Business Activities
Mr. Tomaras is FINRA Series 7 & 24,52,63,65 registered with RF Lafferty.
Additional Compensation
Mr. Tomaras does not receive any additional compensation beyond his commissions and fees
earned for providing advisory services. Mr. Cory may be compensated for his activities as a
commission-based broker at RF Lafferty & Co., Inc.
Supervision
Robert Hackel is responsible for supervising Mr. Tomaras. He can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first brought,
and the status.
Address 40 Wall Street 19th Floor, New York, NY
10005
Phone Number 212-293-9090
Website Address
www.rflafferty.com Name of Supervised Person/IA
Rep
John Fredrick Heidenreich
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Thomas Herity -
Compliance if you did not receive RFL’s brochure or if you have any questions about the
contents of this supplement. Additional information about IA Reps is available on the SEC’s
website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: John Fredrick Heidenreich
Year of Birth: 1958
Investment adviser with RF Lafferty located;
40 Wall Street
New York NY 10005
Phone: (212) 293--9090
Mr. Heidenreich started his financial career in June 1980 with Merrill Lynch, Pierce, Fenner &
Smith Inc. One Beacon Street, Boston MA 02108
He assists clients in developing strategies for portfolio construction, provides investment
advice and offers financial planning.
B.S. Lehigh University – 1980
M.B.A. Fordham University – 1999
Chartered Financial Analyst (CFA) - 1999
Mr. Heidenreich does have a disclosure event which is disclosed on FINRA Broker check.
www.finrabrokercheck.com Other Business Activities
Mr. Heidenreich is FINRA Series 7 & 24,63 & 65 registered with RF Lafferty.
Spencer Trask Ventures Inc, nka Augment Securities - Broker dealer - former employer - consulting
agreement - start date 2/25/2016 - Hours - TBD - performing job during business hours.
Additional Compensation
Mr. Heidenreich does receive additional compensation beyond his commissions and fees
earned for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Heidenreich. He can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first brought,
and the current status.
R.F. Lafferty & Co., Inc.
Address 40 Wall Street 19th Floor, New York, NY
10005
Phone Number 212-293-9090
Website Address
www.rflafferty.com Name of Supervised Person/IA
Rep
Robert Joseph Stravinski
Date of Last Revision February 25, 2019
This Brochure Supplement provides information about IA Reps that supplements the RFL
brochure. You should have received a copy of that brochure. Please contact Robert Hackel -
Compliance if you did not receive RFL’s brochure or if you have any questions about the
contents of this supplement. Additional information about IA Reps is available on the SEC’s
website
at:www.adviserinfo.sec.gov Educational Background and Business Experience Name: Robert Joseph Stravinski
Year of Birth: 1967
Investment adviser with RF Lafferty located;
40 Wall Street
New York NY 10005
Phone: (212) 293--9090
Mr. Stravinski started his financial career in July 1995 with John Hancock Financial Services,
1493 Old Meadow Road, McLean, VA.
He assisted clients develop strategies for portfolio construction, provided investment advice
and estate planning.
Mr. Stravinski received a Bachelor of Science majoring in Marketing and English from Albright
College in 1990. He also earned a Master of Business Administration from George Mason
University in 1999. Over the past 23 years Mr. Stravinski has worked predominantly in the
group benefits market, working with employers to create the most cost effective and robust
benefits platform. This includes but is not limited to group and individual insurance products
and retirement plans.
Disciplinary Information
Mr. Stravinski does not have any disclosure events.
Other Business Activities
Mr. Stravinski is FINRA Series 6 & 7,63 & 65 registered with RF Lafferty.
SHEEHAN INSURANCE GROUP, INVESTMENT RELATED: PARTIALLY 6611 JEFFERSON ST., PO BOX 764,
HAYMAKER, VA 20168, INSURANCE SALES, POSITION: INSURANCE BROKER, START DATE: 7/2003, 30
HRS/MO DEVOTED, 30 HRS/MO DEVOTED DURING TRADING HOURS, SERVICE SALES OF EMPLOYER
GROUP INSURANCE PRODUCTS AND INCLUDED INSURANCE PRODUCTS.
Additional Compensation
Mr. Stravinski does receive additional compensation beyond his commissions and fees earned
for providing advisory services.
Supervision
Robert Hackel is responsible for supervising Mr. Stravinski. He can be reached at 212-293-
9074.
Requirements for State-Registered Advisers
The supervised person has NOT been involved in one of the events listed below;
An award or otherwise being found liable in an arbitration claim alleging damages in excess
of $2,500.
An award or otherwise being found liable in a civil, self-regulatory organization, or
administrative proceeding
The subject of a bankruptcy petition, disclose that fact, the date the petition was first brought,
and the current status.
please register to get more info
Open Brochure from SEC website