Concordia Wealth Management, LLC, (“Concordia”) is a registered investment advisor formed in 2012. Robert Rodriguez is the sole owner of Concordia. Concordia provides wealth management services to its clients who include individuals, high net worth individuals, trusts and corporations. Concordia helps clients achieve life goals through the proper management of their financial resources. Concordia designs a client - specific strategy for each client. In doing so, Concordia is concerned with data gathering, goal setting, identification of financial and non-financial issues, and preparation of alternatives, recommendations and implementation of and periodic reviews and revisions of a client’s plan. Services provided by Concordia are depending on the goals a client wishes to achieve. Services can be integrated or limited to a specific goal.

The initial meeting with a prospective client is free of charge and is considered an exploratory interview to determine the needs of a prospective client and Concordia’s ability and resources to service such needs.

Concordia is strictly a fee-only firm. We do not receive commissions for purchasing or selling annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. We are not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted.
Types of Agreements
The following agreements define our typical client relationships:
Financial Planning Agreement
A financial plan is designed to help the client with all aspects of financial planning without ongoing investment management after the financial plan is completed.

The financial plan may include, but is not limited to: a net worth statement; a goal based cash flow statement; a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations. Detailed investment advice and specific recommendations are provided as part of a financial plan. Implementation of the recommendations is at the discretion of the client. After delivery of a financial plan, future face-to-face meetings may be scheduled as necessary.
Investment Advisory Agreement
As an investment advisor, Concordia supervises and directs the investment of an account of a client with prior consultation with the client. Concordia’s investment decisions and advice for the account(s) it manages are in accordance with the objectives and guidelines agreed to with the client. On a periodic basis, Concordia reviews, with the client, the account to ensure the performance is consistent with the objectives and guidelines which were agreed to. Concordia also reviews changes in a client’s circumstances or goals which may require that the investment portfolio be adjusted.
Family Office Services Agreement
Under a family office services agreement, Concordia provides a highly customized list of services to its clients. The scope of services provided depends on each family’s needs and services revolve around the financial, philanthropic and human capital development needs of our clients and their families. Our financial capital services include but are not limited to integrated financial planning, budget preparation and supervision, cash flow management, investment management, estate planning, property management, tax preparation coordination and trust services. Philanthropic services include strategic philanthropic planning, individual philanthropy oversight and operations coordination. Human capital development services include family governance, family mission formulation and review, leadership training coordination and mentoring of future generations.

The scope of services to be provided under a family office services agreement is provided to the client in writing prior to the start of the relationship.
Tailored Relationships
Our advisory services are individually tailored to the specific needs, goals and objectives for each client. Clients may impose restrictions on investing in certain securities or types of securities.

Agreements may not be assigned without client consent.
Fiduciary Statement
Concordia and our employees are fiduciaries who must take into consideration the best interests of our clients. We will act with competence, dignity, integrity, and in an ethical manner, when dealing with clients. Concordia will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. As a fiduciary, we have the obligation to deal fairly with our clients. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Wrap Fee Programs
Concordia does not participate in a Wrap Fee Program.
Client Assets
As of December 31, 2019, Concordia manages $168,422,717 in assets under management; $157,658,836 is managed on a discretionary basis and $10,763,881 is managed on a non- discretionary basis. please register to get more info

Advisory fees
Concordia Wealth Management, LLC charges fees which are dependent on the type of service being offered to the client.
Financial Planning Services
Concordia anticipates what it believes a typical financial planning exercise will entail and details its fee structure in a financial planning agreement typically as a flat fee. Fees are typically paid upon completion for basic financial plans or may require a deposit and milestone-based payments for more complex plans. In the event that the client’s situation dictates further investigation or planning beyond that discussed at the initial client meeting, a revision to the fee may be necessary, but would be discussed with the client prior to a change in work being performed.
Investment Advisory Services
The annual fee for both discretionary and non-discretionary investment advisory services is typically charged as a percentage, ranging between 0.20% to 1.0%, of the average daily value of investable assets under management when available; or of the month-end balances where our portfolio management system does not receive a direct feed from the custodian; or as a flat fee as detailed in the investment advisory agreement signed between Concordia and the client. Fees are charged quarterly and paid in arrears. The fee percentage charged fluctuates based on the size of the account, the types of investments to be made, frequency of transactions and/or the services to be provided.

The client or Concordia may terminate an investment advisory agreement by written notice to the other party, generally requiring a sixty-day notice. At termination, fees will be calculated on a pro-rated basis for periods less than a full billing cycle (based upon the number of calendar days in the quarter the agreement was in effect, including any required notice period.)
Family Office Services
The annual family office services fee is a flat fee more fully detailed in the family office services agreement signed between Concordia and the client. Family office service fees charged are dependent on the scope and level of family office services provided. Fees may be charged monthly or quarterly and paid in arrears. The client or Concordia may terminate a family office services agreement by written notice to the other party. At termination, fees will be calculated in accordance with the termination provisions contained within the family office services agreement.
Fee Billing and Payment
Fees for investment advisory services are invoiced quarterly and family office services are invoiced monthly or quarterly and paid in arrears. Clients either sign standing letters of authorization with a specific custodian or sign wire instructions authorizing the custodian to deduct Concordia’s fees from a designated account. A custodian, with a client’s pre-approval, may pay fees as invoiced and presented by Concordia pursuant to Concordia’s fee schedule and investment advisory agreement.
Termination of Agreement
A client or Concordia may terminate any of the aforementioned agreements at any time by notifying the other party in writing and paying the agreed upon fee detailed in the particular agreement signed between Concordia and the client. At termination, investment advisory service will be billed on a pro-rated basis for periods less than a full billing cycle (based upon the number of calendar days in the quarter the agreement was in effect, including any required notice period.) A family office services agreement may be terminated by written notice to the other party. At termination, fees will be calculated in accordance with the termination provisions contained within the family office services agreement.

Concordia reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in Concordia’s judgment, to providing proper financial advice.
Other Compensation
Neither Concordia nor any of its supervised persons (employees) accept compensation for the sale of securities or other investment products.

General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums and payment terms are negotiable depending on client’s unique situation – such as the size of the aggregate related party portfolio size, family holdings, low cost basis securities, or certain passively advised investments and pre-existing relationships with clients. Certain clients may pay more or less than others depending on the amount of assets, type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the engagement, special skills needed to solve problems, the application of experience and knowledge of the client’s situation.

Concordia’ fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Concordia’ fee, and Concordia shall not receive any portion of these commissions, fees, and costs. All fees paid to Concordia for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and variable annuity sub-accounts to their shareholders. These fees and expenses are described in each fund’s or sub account’s prospectus. These fees will generally include a management fee, other 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 or sub-account directly, without the services of Concordia. In that case, the client would not receive the services provided by Concordia which are designed, among other things, to assist the client in determining which mutual funds or sub-accounts are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds/sub-accounts and the fees charged by Concordia to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar or lower fees. please register to get more info

Neither Concordia nor any of its Supervised Persons (employees) accepts performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Concordia does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. please register to get more info

As described in Item 4, Concordia provides investment advice to individuals, high net worth individuals, corporations and trusts. Client relationships vary in scope and length of service.
Account Minimums
Concordia does not provide financial planning, investment advisory services, financial advisory or family offices services that require a minimum dollar value of assets under management. please register to get more info

Methods of Analysis
We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).

Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock.
Investment Strategies
Concordia designs investment strategies for its clients based on the client’s needs, expected rate of return, risk tolerance and investment horizon. Concordia selects asset classes consistent with the identified return, risk and time horizon identified above. Specific investment vehicles and manager selection (mutual funds, separately managed accounts, ETFs) are selected based on the Firm’s due diligence which includes but is not limited to the following: review of manager process, past performance, cost, adherence to invest style, size of firm and fund, length of time fund/manager has been in existence, liquidity, volatility, complementarity with other parts of the portfolio and tax considerations. The Firm provides clients with a formalized investment policy statement which addresses the investment strategy, portfolio implementation, portfolio monitoring and portfolio performance review.
Risk of Loss
All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks:


• Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. please register to get more info

Concordia and its employees have not been involved in legal or disciplinary events related to past or present investment clients. please register to get more info

Financial Industry Activities
Concordia is not registered as a broker-dealer, and none of its management persons are registered representatives of a broker-dealer. Neither Concordia nor any of its management persons is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor. Neither Concordia nor any of its management persons have a material relationship or arrangement with any other related person or financial industry entity.
Other Investment Advisors
Concordia does not recommend or select other investment advisors for its clients. please register to get more info

Personal Trading
Code of Ethics
Concordia employees must comply with a Code of Ethics and Statement for Insider Trading (“Code”). The Code describes the Firms’ high standard of business conduct, and fiduciary duty to its clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information

Robert Rodriguez, Managing Member and Chief Compliance Officer reviews all employee trades each quarter.

Concordia’s employees must acknowledge the terms of the Code at least annually. Any individual not in compliance with the Code may be subject to termination.

Clients and prospective clients can obtain a copy of Concordia’s Code by contacting Robert Rodriguez at (978) 371-7044.
Participation or Interest in Client Transactions – Personal Securities Transactions
Concordia and its employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code, described above, is designed to assure that the personal securities transactions, activities and interests of the employees of Concordia will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities, primarily mutual funds, have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Concordia’s clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code and designed to reasonably prevent conflicts of interest between Concordia and its clients.
Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross
Concordia and its employees do not recommend to clients, or buy or sell for client accounts, securities in which they have a material financial interest. It is Concordia’s policy that the Firm will not affect any principal or agency cross securities transactions for client accounts. Concordia will also not cross trades between client accounts. please register to get more info

Research and Other Soft Dollar Benefits
Concordia does not receive formal soft dollar benefits from broker/dealers.
Brokerage for Client Referrals
Concordia does not receive client referrals from broker/dealers.
Directed Brokerage
Concordia does not have any affiliation with product sales firms. Specific custodian recommendations are made to clients based on their need for such services. Concordia recommends custodians based on the proven integrity and financial responsibility of the firm, availability of investment selections most suited to the client’s needs, and the best execution of orders at reasonable commission rates.

Concordia does not receive fees or commissions from any of these arrangements.

Concordia in seeking to obtain the best execution of portfolio transactions may consider the quality and reliability of brokerage services, as well as research and investment information and other services provided by brokers and dealers. Factors considered by Concordia in selecting brokers and dealers may include the following: price, the broker's or dealer's facilities, reliability and financial responsibility; the ability of the broker or dealer to effect securities transactions, particularly with regard to such aspects as complexity of the trade, timing, order size and execution of orders; and the research and other services provided by that broker or dealer to Concordia that are expected to enhance our general portfolio manager capabilities, notwithstanding that a client may not be the direct or exclusive beneficiary of such services. Commission rates, being a component of price, are one factor considered together with other factors. Accordingly, Concordia in its discretion, may cause a client to pay a commission for effecting a transaction that may be in excess of the amount another broker would have charged for effecting that same transaction and this may be done where Concordia has determined in good faith that the commission is reasonable in relation to the value of the brokerage and/or research services provided by the broker or dealer to client(s). While not routine, the client may direct Concordia to use a particular broker-dealer to execute some or all transactions for the client. This brokerage direction must be requested by the client in writing. In that case, the client will negotiate terms and arrangements for the account with that broker-dealer, and Concordia will not seek better execution services or prices from other broker-dealers or be able to “batch” client transactions for execution through other broker- dealers with orders for other accounts managed by Concordia. By directing brokerage, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case.
Directed Brokerage – Other Economic Benefits
Concordia does not receive benefits from broker/dealers other than research and investment information as noted above.
Trade Aggregation
Trade aggregation is the act of trading a large block of a security in a single order. Shares of a purchased security are then allocated to the appropriate accounts in the appropriate proportion. The main purposes of order aggregation are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a larger quantity. Concordia does not aggregate or block trades. As a result, clients purchasing securities around the same time may receive a less favorable price than other clients. In addition, not aggregating trades may result in higher transaction costs, as a client will not benefit from lower transaction cost which might be achieved if the trade was aggregated. please register to get more info

Reviews
Robert Rodriguez, Managing Member and Chief Compliance Officer reviews all accounts on a monthly basis, more frequently when market conditions dictate or at any time upon request of the client. Robert Rodriguez is responsible for recommending investments based on a client’s investment planning objectives and risk tolerance. Other conditions that may trigger a review are changes in market, political or economic conditions, tax laws, new investment information, and changes in a client's own situation.
Reporting
Clients receive periodic communications on at least an annual basis. Investment Advisory Agreement clients receive quarterly portfolio reviews and may request an additional portfolio review at any time.
Financial Planning – Reviews and Reporting
Financial Planning clients will be reviewed and receive reports as contracted for at the inception of the engagement. please register to get more info

Other Compensation
Concordia does not receive any economic benefits (other than normal compensation and benefits described in Item 12) from any firm or individual for providing investment advice.
Compensation – Client Referrals
Concordia has received client referrals over the years from current clients. Concordia does not compensate referring parties for these referrals. please register to get more info

Custody – Fee Debiting
Concordia prepares and sends quarterly invoices for fees to all clients. Clients then either pay Concordia fees directly or clients sign a standing letter of authorization or a detailed letter instructing/authorizing the custodian to pay us a certain fee. Client investment assets will be held with a custodian agreed upon by the client and Concordia. The custodian is advised in writing of the limitations of Concordia’s access to the account. The custodian sends a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to Concordia.

Concordia does not act as a custodian of client assets. The client always maintains asset control. Concordia places trades for some clients under a limited power of attorney.
Custody – Trusteeship
Robert Rodriguez acts as trustee for certain client trusts. Where Robert Rodriguez acts as trustee, Concordia typically will not serve as the investment adviser on the account, except in specific instances as requested by the client. This form of custody is offered on a limited basis. Concordia complies with the SEC’s Custody Rule with regard to the custody of the trust assets. The Firm has engaged an independent accountant to perform an annual surprise examination.
Custody – Account Statements
As described above and in Item 13, clients receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. All assets are held at qualified custodians and the custodians provide monthly account statements directly to clients at their address of record, by secure email or with password protected online access. At the discretion of the client, Concordia is provided with copies of monthly statements or given password protected online access to statements. Concordia also utilizes account aggregation software to access the daily or monthly activity and performance of many of its clients. The availability of a client’s daily activity and performance is dependent upon the client’s custodian and the availability of a data feed to the account aggregation entity utilized by Concordia. Clients are urged to carefully review such statements and compare such official custodial records to the reports that Concordia provides. Concordia reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. please register to get more info

Concordia has both non-discretionary and discretionary relationships with its clients. For those clients that have chosen to sign discretionary Investment Advisory Agreements, we accept discretionary authority to manage securities accounts on behalf of clients and determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. A limited power of attorney is a trading authorization for this purpose. Discretionary clients sign a limited power of attorney so that we may execute the trades on client’s behalf. For those clients that have chosen to sign non-discretionary Investment Advisory Agreements we will make recommendations to the client and, if client decides to accept such recommendations, client will directly execute the recommendations via signed written instruction provided to the custodian. In all client relationships, the client approves the custodian to be used and the commission rates paid to the custodian. please register to get more info

Concordia does not have any authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for securities maintained in their portfolios; clients receive these proxies directly from either custodians or transfer agents. If requested, Concordia may provide advice to clients regarding proxy votes. If any conflict of interest exists, it will be disclosed to the client. Clients may contact Robert Rodriguez at (978) 371-7044 for information about proxy voting. please register to get more info

Concordia 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. Concordia does not require prepayment of fees of both more than $1,200 per client, and more than six months in advance; and therefore, is not required to provide a balance sheet to clients. This page is intentionally blank
Form ADV Part 2B – Investment Adviser Brochure Supplement
Concordia Wealth Management, LLC
Form ADV Part 2B Investment Adviser Brochure Supplement
Supervisor:
Robert Rodriguez
Supervised Person:
James Daron

March 2020

This brochure supplement provides information about the Firm’s Supervised Persons that supplements the Concordia Wealth Management, LLC’s brochure. You should have received a copy of that brochure. Please contact Robert Rodriguez, Managing Member and Chief Compliance Officer if you did not receive Concordia Wealth Management, LLC’s brochure or if you have any questions about the contents of this supplement.

Additional information about the Firm’s Supervised Persons is also available on the SEC’s website at www.adviserinfo.sec.gov. You may search this site using a unique identifying number, known as a CRD number for each Supervised Person. 37 Main Street, Suite 1 Concord, MA 01742 (978) 371-7044 (978) 208-2165 [email protected]

Item 2 - Educational Background and Business Experience
Education and Business Background
Concordia requires that advisors in its employ have a bachelor's degree and further coursework demonstrating knowledge of financial planning. Examples of acceptable coursework include: an MBA, a CFP®, a CFA, a ChFC, JD, CTFA, EA or CPA. Additionally, advisors must have work experience that demonstrates their aptitude for financial planning and investment management.
Supervisor
Robert Rodriguez Born: 1957
CRD# 2051214
Education:
Boston University Bachelor of Arts in Economics Master of Arts in Economics

The Wharton School, University of Pennsylvania Master of Business Administration in Finance
Professional Background:
Concordia Wealth Management, LLC 2012 – Present Managing Member and Chief Compliance Officer

Finaccess Advisors, LLC 2009 – 2012 Chief Executive Officer Investment Committee

Finaccess International, Inc. 2004 – 2009 Managing Director

J.P. Morgan 1991 – 2004 Vice President, Emerging Markets Bankers Trust Co. 1987 – 1991 Vice President, Emerging Markets Marine Midland Bank 1982 – 1985 Loan Officer Bank of Boston 1980 – 1982 Loan Officer Development Program
Supervised Person
James Daron Born: 1971
CRD# 6424663
Education:
Franklin Pierce University Bachelor of Science in Marketing
Professional Background:
Concordia Wealth Management, LLC 2015 – Present Investment Manager Concordia Wealth Management, LLC 2013 – 2015 Senior Accountant Asset Management Partners 2011 – 2012 Senior Accountant and Operations Manager
Item 3 - Disciplinary Information
Neither Concordia nor any Supervised Persons have been involved in any activities resulting in a disciplinary disclosure.
Item 4 - Other Business Activities
Robert Rodriguez acts as trustee for certain client trusts. Where Robert Rodriguez acts as trustee, Concordia typically will not serve as the investment adviser on the account, except in specific instances as requested by the client. Additional disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry Activities and Affiliations above.

As disclosed in Form ADV Part 2A Item 5 – Fees and Compensation, neither Concordia nor any Supervised Persons receive commissions, bonuses or other compensation based on the sale of securities or other investment products.
Item 5 - Additional Compensation
No Supervised Person receives any economic benefit outside of regular salaries or bonuses related to amount of sales, client referrals or new accounts.
Item 6 - Supervision
Robert Rodriguez, Managing Member and Chief Compliance Officer, supervises James Daron, as named in this Form ADV Part 2B Investment Adviser Brochure Supplement. Robert Rodriguez supervises all supervised persons by holding regular staff, investment and other ad hoc meetings. In addition, Robert Rodriguez regularly reviews client reports, emails, and trading, as well as employees’ personal securities transaction and holdings reports. Robert Rodriguez can be reached at (978) 371-7044. please register to get more info