About RMB West RMB West, LLC (“RMB West”, the “Adviser” or “we”) is a Delaware limited liability company
formed on April 21, 2011. RMB West is based in Denver, Colorado. Its principal owner is RMB
Capital Management, LLC (“RMB Capital”). RMB Capital is a wholly-owned subsidiary of
RMB Capital Holdings LLC (“RMB Holdings”). Richard M. Burridge and Frederick Paulman
are the principal owners of RMB Holdings. RMB West operates as a division of RMB Capital
called RMB Retirement Plan Solutions. All personnel working for RMB West are employees of
RMB Capital.
RMB West, through RMB Retirement Plan Solutions, provides non-discretionary advisory and
consulting services and solutions to employer organizations which sponsor and/or administer
employee retirement plans. RMB West focuses on assisting its clients in improving the
performance, design and operation of their sponsored retirement plans. RMB West tailors its
consulting and advisory services to meet the needs of its clients. These services typically
include, but are not limited to, the following:
• Recommending investments based on a prudent and documented fiduciary process that
includes a comparison among available investments in a given asset class and/or
investment style using many factors, including but not limited to, performance, risk,
management, investment process, fees and style consistency, and monitoring
recommended investments for consistency with the selection factors;
• Recommending appropriate services and service providers;
• Providing ERISA fiduciary (and fiduciary risk) education and training;
• Providing investment education and individualized advice to retirement plan
participants;
• Benchmarking of investment performance, plan fees and costs, investment options, and
services provided by a retirement plan’s service providers;
• Initiating and managing the request for proposal/search process for new retirement
plan service providers; and
• Overseeing retirement plan administration and compliance procedures.
As of December 31, 2019, RMB West had $1,358,510,876 in assets under advisement, all of which
is non-discretionary.
About RMB Capital As noted above, we are affiliated with RMB Capital, which is a separately registered investment
adviser. RMB Capital is an independent, majority employee-owned firm offering advisory
services and investment solutions to a diverse range of clients. RMB Capital was established in
Chicago, Illinois, on April 1, 2005 with a team of 19 employees. Since then, RMB Capital has
grown to approximately 180 employees with additional offices in Denver, Colorado; Jackson
Hole, Wyoming; Lake Forest, Illinois; Bloomington, Minnesota; Milwaukee, Wisconsin; New
York, New York; St. Joseph, Michigan; Atlanta, Georgia; and Washington, D.C., and satellite
offices in Skaneateles, New York; Rochester, New York; and Oak Brook Terrace, Illinois.
As an independent firm, RMB Capital is able to make autonomous decisions without the
influence of corporate ties or shareholder influences. RMB Capital’s business is structured to
help ensure its clients’ best interests are the driving force behind its practices and
recommendations.
RMB Capital services its clients through two primary business units: Wealth Management and
Asset Management. Its Wealth Management business focuses on providing holistic solutions to
its client’s financial needs while its Asset Management business provides separately managed
accounts and other investment products that serve as the building blocks for its clients’
investment portfolios.
A copy of RMB Capital’s Form ADV Part 2A brochure is available to clients and prospective
clients of RMB West upon request by contacting RMB Capital’s Compliance Department at (312)
993-5800 or
[email protected]. Additional information about RMB Capital also is
available on the website of the United States Securities and Exchange Commission at
www.adviserinfo.sec.gov.
As of December 31, 2019, RMB Capital had $8,664,870,131 regulatory assets under management.
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RMB West is compensated for its services either on a fixed fee basis or based upon a percentage
of assets of the client’s retirement plan. The amount of fees charged by RMB West, as well as
the specific manner in which such fees are charged, are customized for each client and set forth
in a written agreement with the client. RMB West’s fees are negotiable and are dependent on
the scope and depth of the services provided. Fees generally are payable in advance at the
beginning of each quarter and are prorated to cover the period from either: (1) the time of
execution of the advisory agreement, or (2) the effective date of the written agreement with the
client through the expected completion of the project or the time period covered by the
agreement. Clients either pay fees directly to RMB West or instruct their retirement plan service
providers to deduct and remit the fees from the retirement plan assets or from excess revenue
generated by the retirement plan’s investments.
Since RMB West clients may have different fee structures and may pay different fees, there is an
incentive for RMB West to focus its efforts on those clients that generate higher fees for RMB
West. RMB West has procedures designed and implemented to help ensure that clients are
treated fairly and to help mitigate this conflict.
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RMB West provides advisory and consulting services to for-profit and non-profit employer
organizations which sponsor and/or administer employee retirement plans, including defined
benefit pension plans, defined contribution plans (such as 401(k), 403(b), and 457 plans), profit-
sharing plans, and Taft-Hartley plans. RMB West’s clients are generally considered to be
institutional clients and are named fiduciaries of the retirement plans they sponsor.
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Method of Analysis
RMB West’s method of analysis follows a prudent and documented process to help ensure that
its retirement plan sponsor clients meet the requirements of the “Prudent Man Rule” (as
described in ERISA §404).
RMB West’s investment research is based on interviews with investment managers and
retirement plan service providers and includes subscriptions to third-party sources of
information. RMB West’s analysis includes searching databases of investment analytics and
research information covering a substantial amount of investment products and securities. Such
databases are also used in the ongoing performance monitoring of investment alternatives for
retirement plan sponsors.
While we have confidence in the veracity of the information we receive, there is the risk that
such information contains inaccuracies which could lead to improper or misguided
recommendations.
Investment Strategies
The investment strategies recommended are those deemed to be appropriate, based on the
client retirement plan’s objectives, for the management of the retirement plan’s assets.
Generally, open-end mutual funds and/or other investment managers are recommended to
allow reasonable diversification among asset classes and investment styles.
Risk of Loss All investments in securities and other financial instruments involve substantial risk of
volatility (potentially resulting in rapid declines in market prices and significant losses) arising
from any number of factors that are beyond the control of RMB West. Legal, tax, and regulatory
changes could occur which in certain cases materially adversely affect the ability of an account
to pursue its investment strategies or achieve its investment objective.
Although RMB West believes that its recommendations should mitigate the risk of loss through
a careful selection and monitoring of investments, an investment is nevertheless subject to loss,
including possible loss of the entire amount invested. No guarantee or representation is made
that an investment will be successful, and the investment results will vary substantially over
time.
Investment Selection RMB West employs an independent process when recommending investments for client
retirement plans that mitigates most conflicts of interest and reduces risk and liability. First,
RMB West works with each client to understand their investment objectives for the investment
options related to the client’s retirement plan. Next, RMB West reviews the universe of
investment options available to start our screening process. Our screening process includes:
1. Reviewing investments in our analytic system and remove any mutual funds that are
not scoring appropriately (i.e. generally less than 7 in our 10 point scoring system);
2. Completing additional quantitative analysis to identify finalists for recommendation.
This recommendation includes factors specific to the category of retirement plan
investments requested by the client;
3. Performing a qualitative screening that includes, if practicable, an interview with the
portfolio manager for the potential retirement plan investment to evaluate the portfolio
manager’s skills and identify any other potential issues.
RMB West feels our evaluation and diligence process leads to retirement plan investment
options that meet the attributes and investment objectives required by each client. As part of
this process, RMB West documents the rationale for its recommendations in order to help the
client meet its fiduciary obligations as retirement plan sponsor/administrator. In addition,
RMB West also monitors its recommendations quarterly to help ensure that action is taken
without undue delay, if necessary.
RMB West does not imply, represent, or warrant that its services or its methods of analysis can
or will predict future results, identify market tops or bottoms, or insulate clients and their
retirement plan participants from losses, including material losses due to major market
corrections or crashes, or detect fraud or negligence on the part of the manager of any
recommended retirement plan investment or any recommended service provider.
RMB West, from time to time, will use the services of RMB Capital to assist in RMB West’s due
diligence process. No guarantees are provided that a client’s goals or objectives or those of its
retirement plan participants can or will be achieved.
There can be no assurance that the methods described above will be successful or that clients will not
suffer losses. Investing in securities involves risk of loss that clients should be prepared to bear. Private
funds and mutual funds have different risks depending on the strategy implemented by the manager of
the private funds and mutual funds. Cybersecurity RMB West’s information and technology systems may be vulnerable to damage or interruption
from computer viruses, network failures, computer and telecommunication failures, infiltration
by unauthorized persons and security breaches, usage errors by its professionals, power
outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes.
Although RMB West has implemented various measures to protect the confidentiality of its
internal data and to manage risks relating to these types of events, if these systems are
compromised, become inoperable for extended periods of time or cease to function properly,
RMB West may have to make a significant investment to fix or replace them. The failure of these
systems and/or of disaster recovery plans for any reason could cause significant interruptions
in RMB West’s operations and result in a failure to maintain the security, confidentiality or
privacy of sensitive data, including personal information relating to clients. Such a failure could
harm RMB West’s reputation or subject it or its affiliates to legal claims and otherwise affect
their business and financial performance. RMB West will seek to notify affected clients of any
known cybersecurity incident that may pose substantial risk of exposing confidential personal
data about such clients to unintended parties.
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As described in Item 4 (Advisory Business), RMB West is affiliated with RMB Capital and
operates as a division of RMB Capital called RMB Retirement Plan Solutions. In light of that
affiliation, there is a conflict of interest between RMB West’s interest in providing advisory and
consulting services to its clients and the Wealth Management and Asset Management services
provided by RMB Capital offered to other clients. RMB Capital’s clients generally include
individuals, high-net-worth individuals, corporate pension and profit-sharing plans, pooled
investment vehicles, charitable organizations, foundations, endowments, mutual funds,
corporations, government entities, Taft-Hartley funds and other institutions. RMB Capital
provides certain services to its clients through affiliated entities that serve as a general partner
or an investment manager of private funds, through divisions (such as RMB West), or through
joint ventures. To mitigate this conflict, RMB West does not recommend any investment
products managed by RMB Capital to its clients. RMB West may, however, in some
circumstances, recommend RMB Capital’s wealth management services to persons related to
RMB West’s clients. In addition, RMB West from time to time makes investment
recommendations and provides other services to RMB Capital in respect of RMB Capital’s own
sponsored 401(k) employee retirement plan (the “RMB Capital 401(k) Plan”), for which it does
not receive a fee. Personnel of RMB West may have individual accounts in the RMB Capital
401(k) Plan, which may create a conflict of interest.
Certain RMB Capital staff members, none of whom are part of RMB West, are registered with
FINRA as a representative of unaffiliated distributors of mutual funds managed by RMB
Capital or its affiliates.
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Code of Ethics RMB Capital has adopted a Code of Ethics for all supervised persons of RMB Capital describing
its high standard of business conduct and fiduciary duty to clients. The Code of Ethics includes
provisions relating to personal securities trading procedures and employee reporting and
attestations, among other things. All supervised persons at RMB Capital must acknowledge the
terms of the Code of Ethics as a new employee, annually, or as amended. Since RMB West is a
wholly-owned subsidiary of RMB Capital and all personnel of RMB West are employees of
RMB Capital, the Code of Ethics applies to RMB West and all such personnel.
Personal Trading From time to time, employees or related persons of RMB West will invest in securities that are
also held in RMB Capital client accounts. All transactions in these and other securities must
comply with the Code of Ethics. The Code of Ethics requires, among other things, that
employees and related persons of RMB Capital, including RMB West and its personnel:
▪ Are limited in their ability to trade in such securities if RMB Capital is trading for client
accounts on the same day;
▪ Must report all personal trading and accounts to RMB Capital’s Compliance Department
to review compliance with these standards;
▪ Must hold any securities purchased for their personal accounts for a minimum period.
In certain circumstances and upon written request, RMB Capital will permit transactions in a
security that would otherwise be prohibited under the Code of Ethics.
Participation or Interest in Client Transactions RMB West does not directly buy or sell for itself securities that it also recommends to clients,
but accounts sponsored by RMB Capital, including RMB Capital’s own sponsored 401(k)
employee retirement plan, may hold such securities. Any transactions in RMB Capital’s 401(k)
plan that are directed by employees of RMB Capital, including RMB West personnel, would be
subject to the Code of Ethics. RMB West’s clients and prospective clients may request a copy of
the Code of Ethics by contacting RMB Capital’s Compliance Department at (312) 993-5800 or
[email protected].
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RMB West assists its clients with the selection of retirement plan service providers which may
also be registered broker-dealers. RMB West’s evaluation and subsequent recommendation of
such a service provider is based solely on the entity’s capabilities as a third-party administrator
or recordkeeper and not on the entity’s brokerage, trading or research capabilities. RMB West
does not execute any trades for its clients nor does it receive any “soft dollar” payments or other
benefits from any broker-dealer.
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RMB West periodically monitors investments recommended to clients and provides periodic
reports summarizing the client’s retirement plan design, investment performance, and advisory
fees. RMB West generally meets with clients on an annual, semi-annual or quarterly basis,
depending on the client’s preference, to review the recent period’s data, recommended changes
and discuss possible changes in the client’s investment objectives and needs. Clients must
inform RMB West of any interim changes that would indicate a need to change investment
recommendations.
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RMB West refers related persons of its clients to RMB Capital for wealth management services
in certain circumstances. Currently, RMB West does not receive additional compensation for
such referrals.
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RMB West does not have custody or any other form of access to its clients’ assets or the assets of
the retirement plans sponsored and/or administered by its clients. Such assets are held by the
custodian of the applicable retirement plan for the exclusive benefit of the retirement plan’s
participants.
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RMB West does not have discretionary authority for the selection of any securities or other
investments for client accounts. When recommending investments, RMB West observes the
investment policies, guidelines, limitations and restrictions of the retirement plans sponsored
and/or administered by its clients, which must be provided to RMB West by the client in
writing. The selection of investments for a client’s retirement plan is generally subject to the
approval of the trustees or similar governing body of such retirement plan. For most retirement
plans, the participants in the retirement plan direct the investment of their retirement plan
accounts.
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RMB West does not provide proxy voting services on behalf of its clients, unless required to do
so by law. If requested by a client, RMB West may provide general consulting services to help
the client understand its responsibilities relating to proxy voting. All proxy notices, if and to the
extent received by RMB West, are sent directly to the client. If required by law to vote client
proxies, RMB West will follow the policies and procedures adopted and implemented by RMB
Capital in respect of voting client proxies. Additional information regarding RMB Capital’s
proxy voting policy and procedures can be obtained by contacting RMB Capital by email at
[email protected] or by phone at (312) 993-5800. Clients of RMB West may request
information on votes cast by RMB West, if any, by making a request by phone or email.
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Registered investment advisers are required in this section to provide you with certain financial
information or disclosures about RMB West’s financial condition. RMB West has no financial
commitment that impairs its ability to meet contractual and fiduciary commitments to clients,
and has not been the subject of a bankruptcy proceeding.
PRIVACY POLICY DECEMBER 2019 FACTS WHAT DOES RMB CAPITAL MANAGEMENT, LLC (“RMB”) DO WITH YOUR PERSONAL INFORMATION? WHY? Financial companies choose how they share your personal information. Federal law gives consumers
the right to limit some but not all sharing. Federal law also requires us to tell you how we collect,
share, and protect your personal information. Please read this notice carefully to understand what
we do.
WHAT? The types of personal information we collect and share depend on the product or service you have
with us. This information can include:
▪ Social security number
▪ Income and Assets
▪ Investment Experience
▪ Risk tolerance
▪ Transaction history
▪ Account Balances
HOW? All financial companies need to share customers’ personal information to run their everyday
business. In the section below, we list the reasons financial companies can share their customers’
personal information; the reasons RMB chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information Does RMB Share? Can you limit this sharing? For our everyday business purposes - such as to process
your transactions, maintain your accounts(s) or respond
to court orders and legal investigations.
Yes No
For our marketing purposes - to offer our products and
services to you
Yes Yes
For joint marketing with other financial companies No We don’t share For our affiliates’ everyday business purposes -
information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes –
information about your creditworthiness
No We don’t share
For our affiliates to market to you Yes Yes For non-affiliates to market to you No We don’t share To limit our sharing Call toll free: 1-800-601-5228
Please note: If you are a
new customer, we can begin sharing your information 30 days from the date
we sent this notice. When you are
no longer our customer, we continue to share your information as
described in this notice. However, you can contact us at any time to limit our sharing.
Questions? Call toll free 1-800-601-5228 or visit
www.rmbcapital.com an
d www.rmbfunds.com. Continued Privacy Policy, continued Who we are Who is providing this notice? RMB Capital Management, LLC, RMB West, LLC, Iron Road Capital
Partners, LLC, RMB Mendon Managers LLC, RMB Logan Stone Managers
LLC, South LaSalle Managers, LLC, RMB Rail-Splitter Managers LLC and,
RMB Investors Trust.
What we do How does RMB protect my personal information? To protect your personal information from unauthorized access and use,
we use security measures that comply with federal law. These measures
include computer safeguards and secured files and buildings.
How does RMB collect my personal information?
We collect your personal information, for example, when you
▪ Enter into an investment advisory contract
▪ Open an account
▪ Tell us about your investment or retirement portfolio
▪ Provide your employment information
▪ Show your Driver’s license information
Why can’t I limit all sharing?
Federal law gives you the right to limit only
▪ sharing for affiliates’ everyday business purposes—information about
your creditworthiness
▪ affiliates from using your information to market to you
▪ sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to
limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else? Your choices will apply to everyone on your account - unless you tell us
otherwise.
Privacy Policy, continued Definitions Affiliates Companies related by common ownership or control. They can be
financial and nonfinancial companies.
▪
RMB West, LLC
▪
Iron Road Capital Partners, LLC
▪
South LaSalle Managers, LLC
▪
RMB Mendon Managers LLC
▪
RMB Logan Stone Managers LLC
▪
RMB Rail-Splitter Managers LLC
▪
RMB Investors Trust
Non-affiliates Companies not related by common ownership or control. They can be
financial and nonfinancial companies.
▪
RMB Capital Management doesn’t share with non-affiliates so they can
market to you. Joint Marketing A formal agreement between non-affiliated financial companies that
together market financial products or services to you.
▪
RMB Capital Management doesn’t jointly market.
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Open Brochure from SEC website