Firm Description Roof, Eidam & Maycock, LLC (“REM”) is an independently owned Registered Investment Advisor,
registered with the U.S. Securities and Exchange Commission and the California Department of
Corporations. REM has been providing investment advice to institutional investors since 1992. As
of December 31st, 2019, we have $617,240,615 in assets under management. $599,717,249 of
which is managed on a discretionary basis.
Principal Owners
The principal owners of REM include Gary Edmund Roof, Don Henry Eidam, Jr., Randall Robert
Maycock and Juan Carlos Peralta.
Types of Advisory & Consulting Services
Investment Advice: REM will design and recommend an investment portfolio, as well as specific
investment recommendations, and will assist in implementing such recommendations. REM will
also provide portfolio review meetings, quarterly composite portfolio performance reports and
additional ancillary services. REM will be compensated for such services through payment of a
Management Fee pursuant to the client's purchase of financial products.
Advisory Management Fee: The maximum Management Fee charged by REM is 1.00% of gross
assets under management (valued at fair market value), subject to a minimum annual
Management Fee of $2,500. The fair market value of assets in a client's account under
management will be determined on the last business day of each calendar quarter. Fees are
negotiable and shall be billed quarterly in advance.
The graduated Management Fee Schedule is as follows:
Valuation of Portfolio of Assets under Management Annual Fee Percentage First $1,000,000 0.75%
Next $1,000,000 0.50%
Next $8,000,000 0.25%
Above $10,000,000 0.15%
Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer
plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting
employer plan sponsors in establishing, monitoring and reviewing their company's participant-
directed retirement plan. As the needs of the plan sponsor dictate, areas of advising could include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of
a statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid Participants in developing strategies to meet their investment
objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants
about their retirement plan offerings, different investment options, and general guidance
on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory
services with respect to the following types of assets: employer securities, real estate (excluding
real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or
assets, other illiquid investments, or brokerage window programs (collectively, “Excluded
Assets”). All retirement plan consulting services shall be in compliance with the applicable state
laws regulating retirement consulting services. This applies to client accounts that are retirement
or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security
Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts
appointment to provide services to such accounts, our firm acknowledges its fiduciary standard
within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan
Consulting Agreement with respect to the provision of services described therein.
Our Retirement Plan Consulting services are billed on a percentage of Plan assets under
management. The total estimated fee, as well as the ultimate fee charged, is based on the scope
and complexity of our engagement with the client. The maximum fee as based on a percentage
of managed Plan assets will not exceed 1.00%. The fee-paying arrangements will be determined
on a case-by-case basis and will be detailed in the signed consulting agreement.
Additional Fees
You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange
traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and
other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer
fees and other fees and taxes on brokerage accounts and securities transactions. These fees are
not included within the wrap-fee you are charged by our firm.
We do not recommend or offer the wrap program services of other providers. Our investment
advisory representatives receive a portion of the advisory fee that you pay us, either directly as a
percentage of your overall fee or as their salary from our firm. In cases where our investment
advisory representatives are paid a percentage of your overall advisory fee, this may create an
incentive to recommend that you participate in a wrap fee program rather than a non-wrap fee
program (where you would pay for trade execution costs) or brokerage account where
commissions are charged. This is because, in some cases, we may stand to earn more
compensation from advisory fees paid to us through a wrap fee program arrangement if your
account is not actively traded.
LPL Financial has a trading platform with select exchange traded funds (“ETFs”) that do not
charge transaction fees. The no-transaction-fee ETF trading platform is available to clients
participating in LPL Financial’s Strategic Wealth Management (“SWM”) and Strategic Asset
Management (“SAM”) programs. The limited number of ETFs available on the no-transaction fee
platform may have higher overall expenses than other types of securities and ETFs not included
in the platform.
Additionally, Charles Schwab & Co., Inc. (“Schwab”) recently eliminated transaction fees for U.S.
listed equities and exchange traded funds. Since we pay trading costs as a part of our Wrap Fee
Program, our costs in administering the program have decreased. Furthermore, we now have a
financial incentive to use these products without transaction fee.
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Clients
Description
REM provides investment advice to charitable organizations and institutions. REM provides
consulting services to pension plans. We do not offer discretionary investment advice & financial
planning to pension plans unless otherwise agreed upon.
Account Minimums
A minimum of $250,000 is required to establish an institutional advisory relationship with REM
and subject to a minimum annual fee of $2,500. A minimum of $267,000 is required to establish
a pension consulting relationship with REM. Exceptions to these minimums may be made on a
case-by-case basis.
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Evaluation
Our firm does not utilize outside portfolio managers. All asset management accounts are
managed by our in-house professionals on a wrap fee basis only.
Tailored Relationships REM provides customized services tailored to the unique investment needs of each of their
clients. Clients may impose restrictions on investing in certain securities or types of securities.
Such restrictions must be submitted to REM in writing. Client-imposed restrictions may affect
REM’s ability to perform its stated investment strategy, and therefore investment performance
may deviate from that of other client portfolios managed in accordance with the same strategy.
Performance-Based Fees & Side-by-Side Management
REM does not accept any performance-based fees. REM generally avoids investment vehicles in
which the fund managers engage in side-by-side management.
Methods of Analysis, Investment Strategies & Risk of Loss
REM will utilize fundamental, technical and cyclical methods when analyzing securities. They will
consider financial newspapers and magazines, research materials prepared by others, corporate
rating services, annual reports, prospectuses, filings with the SEC, and company press releases.
REM will consider implementing strategies for both the long term (securities to be held at least a
year) and short term (securities to be held less than a year). REM may also purchase securities
on margin.
REM builds custom portfolios for their client accounts based on the overall risk tolerance of each
client. REM establishes model portfolios based on the various associated risks and applies the
models to each client’s portfolio.
REM portfolios typically include mutual funds and exchange traded funds (“ETF”). Investing in
these instruments, as with all securities, involves the risk of loss, and clients should be prepared
to bear these losses. Mutual funds and ETFs, like stocks, generally fluctuate in value and may
decline significantly over short time periods. Perhaps the most significant risk associated with
mutual funds and ETFs is market risk. This risk is defined by the perception of investors and the
day-to-day fluctuations associated with any portfolio. Market risks include, but are not limited to:
fiscal and monetary policy decisions, general economic conditions, geopolitical uncertainty,
inflation or deflation concerns, commodity price fluctuations, and currency valuations.
Some of the mutual funds will contain fixed-income securities. Fixed-income assets have two
main sources of risk. Interest rate risk is the risk that a rise in interest rates will cause the price of
a debt security held by the fund to fall. Securities with longer maturities typically suffer greater
declines than those with shorter maturities. Credit risk is the risk that an issuer of a debt security
will default (fail to make scheduled interest or principal payments), potentially reducing income
distributions and market values. This risk is increased when a security is downgraded or the
perceived creditworthiness of the issuer deteriorates.
We also employ the use of Covered Call strategies in the management of certain client accounts.
The risks associated with this type of strategy involve having the underlying stock called away.
Each contract has a strike price at which the writer of the contract agrees to allow the purchaser
call the stock away from the writer. This can create a taxable event whereby the writer of the
option is required to recognize a capital gain on the underlying security. Furthermore, the market
price could appreciate beyond the strike price, forcing the writer to sell their holdings below current
market value.
Our firm also utilizes various Alternative Investments, such as Hedge funds, Real Estate
Investment Trusts (“REITs”), Business Development Companies (“BDCs”), and Limited
Partnerships which involve a high degree of risk and can be illiquid due to restrictions on transfer
and lack of a secondary trading market. They can be highly leveraged, speculative and volatile,
and an investor could lose all or a substantial amount of an investment. Alternative investments
may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures
often result in delayed tax reporting. Compared to mutual funds, these products are subject to
less regulation and often charge higher fees. Alternative investment managers typically exercise
broad investment discretion and may apply similar strategies across multiple investment vehicles,
resulting in less diversification.
Proxy Voting
REM will not vote proxies for its clients’ accounts. Clients will obtain information on their proxy
votes directly from the custodian. Clients may contact REM if they have any questions on a
particular proxy solicitation.
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Managers
Our firm manages all assets in house, so communication with your portfolio manager(s) takes
place on a regular basis as needed (daily, weekly, monthly, etc.) to ensure your most current
investment goals and objectives are understood by your portfolio manager(s). In most cases, we
will communicate such information as part of our regular investment management duties.
Nevertheless, we will also communicate information when you ask us to, when market or
economic conditions make it prudent to do so, etc.
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Clients are always free to directly contact their portfolio manager(s) with any questions or
concerns they have about their portfolios or other matters.
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Disciplinary Information REM has not been subject to any legal or disciplinary events.
Other Financial Industry Activities and Affiliations
Representatives of our firm are licensed insurance agents. However, to eliminate any potential
conflicts of interest, we will rebate all commissions earned from any insurance products sold
against client advisory fees.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
REM has adopted a Code of Ethics designed to comply with Rule 204A-1 under the Investment
Advisers Act of 1940. This Code establishes rules of conduct for all partners and employees of
REM and is designed to, among other things, govern personal securities trading activities in the
accounts of partners and employees. The Code is based upon the principle that REM and its
employees owe a fiduciary duty to REM’s clients to conduct their affairs, including their personal
securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead
of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or
potential conflicts of interest or any abuse of their position of trust and responsibility. Pursuant to
Section 206 of the Advisers Act, both REM and its employees are prohibited from engaging in
fraudulent, deceptive or manipulative conduct. The purpose of the Code is to preclude activities
which may lead to or give the appearance of conflicts of interest, insider trading and other forms
of prohibited or unethical business conduct. A full copy of our Code of Ethics is available upon
request.
Periodic Reviews
Advisory accounts are reviewed at least every 12 months but may be reviewed more frequently
based on client need. The annual review is an in-depth review of the client's investment plan. The
reviews are conducted by Gary E. Roof, partner, Don H. Eidam, Jr., partner, Randall R. Maycock,
partner, or Juan Carlos Peralta, partner.
Review Triggers Additional reviews may be triggered by client need and/or market conditions affecting specific
clients.
Regular Reports REM provides clients with quarterly reports on their investment portfolios. The reports include
information on holdings and performance relative to benchmarks.
Client Referrals & Other Compensation REM does not receive or pay any fees for referral or solicitation of clients or have any other formal
compensation arrangements.
In an effort to keep our clients informed as to the services we offer and the various financial
products we utilize, our employees may attend conferences or events subsidized by product
providers. These trips are educational in nature, and are not dependent upon the use of any
specific products. While a conflict of interest may exist given that these trips are at least partially
funded by product sponsors, we will always adhere to our fiduciary duties in selecting appropriate
investments for our clients.
Selecting Brokerage Firms
If a recommendation is appropriate, we recommend that our clients use LPL Financial (“LPL”) and
Charles Schwab & Co., Inc. (“Schwab”), FINRA-registered broker-dealers, members SIPC, as the
qualified custodians (collectively “Custodians”). We are independently owned and operated and
not affiliated with Custodians. Custodians will hold your assets in a brokerage account and buy
and sell securities when we instruct them to. While we recommend that you use Custodians, you
will decide whether to do so and open your account with either Custodian by entering into an
account agreement directly with them.
The factors used by REM in selecting a broker/dealer affiliation include:
• the nature and quality of the approved investment products;
• the nature and quality of the investment research & due diligence;
• the nature, efficiency and quality of services provided;
• the nature, efficiency and quality of best execution practices;
• the cost effectiveness to clients; and
• the nature, quality and availability of research reports to clients.
Because LPL and Schwab maintain restricted approved-lists of Mutual Funds and Limited
Partnerships available to REM, a client's investment selection may be limited to those particular
Mutual Funds and Limited Partnerships on such approved-lists.
LPL and Schwab Research and Soft Dollars LPL and Schwab conduct a limited amount of investment research on stocks, bonds, mutual
funds, ETFs, limited partnerships and real estate investment trusts. Research and compliance
support provided by LPL and Schwab is used to service all of REM’s client accounts. REM does
not receive any soft-dollar compensation.
LPL and Schwab Order Aggregation The aggregation or blocking of client transactions allows REM to execute transactions in a timely,
equitable, and efficient manner, and seeks to reduce overall transaction costs to clients. REM will
aggregate client transactions where possible and when advantageous to clients. In these
instances, clients participating in any aggregated transactions will receive an average share price
and transaction costs will be shared equally and on a pro-rata basis.
Schwab Custody and Brokerage Costs
For our clients’ accounts it maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging commissions or other fees on trades that it
executes or that settle into your Schwab account. For some accounts, Schwab may charge a
percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s
commission rates and/or asset-based fees applicable to our client accounts were negotiated
based on our commitment to maintain a minimum threshold of our clients’ assets in accounts at
Schwab. The overall commission rates and/or asset-based fees paid are lower than they would
be if we had not made the commitment. In addition to commissions or asset-based fees Schwab
charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have
executed by a different broker-dealer but where the securities bought or the funds from the
securities sold are deposited (settled) into your Schwab account. These fees are in addition to
the commissions or other compensation paid to the executing broker-dealer. Because of this, in
order to minimize your trading costs, we have Schwab execute most trades for your account.
Products and Services Available to us from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms.
They provide us and our clients with access to its institutional brokerage – trading, custody,
reporting and related services – many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services. We do not believe that
maintaining assets at Schwab in order to avoid paying Schwab quarterly service fees presents a
material conflict of interest.
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