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           PowerPoint Presentation Disclosure Statement

 

 

Robbins Financial Advisory Service, Inc. is a federally registered investment advisory firm doing business as Robbins Wealth Management (RWM). See Part II of Form ADV for a complete listing of all states where RWM is able to conduct business. RWM does not actively pursue business in other states. However, we do work with clients in multiple other states under de minimus rules. RWM will promptly become a notice filer in any state where our client base exceeds the de minimus thresholds.

 

ADVISORY FEES

 

When a client is investing in a Mutual Fund or a Variable Annuity, they are actually paying two advisory fees. One fee is paid to the mutual fund, or variable annuity sub-account as measured by the investments expense ratio, and the other to Robbins Financial Advisory Service, Inc. (hereinafter “RWM”). The only compensation, be it soft dollar or otherwise, that RWM receives is directly from its clients. RWM does not receive or accept kick-backs or privileges from mutual fund companies, or insurance companies for variable annuities.

 

Block Trading

Block trading allows an adviser to execute transactions in a more timely, equitable, and efficient manner and seeks to provide multiple clients with the same average price per share.

Our block trading policy revolves around to fact that we do not have discretion over client assets. In some instances we will execute a block trade within a client's portfolio across multiple accounts to ensure the same average price for the transaction. On rare occasion when multiple clients have all been deemed both "suitable" and tax-advantaged (meaning that the transaction will not impose an undesired tax consequence to the client) for a transaction (buy or sell); and all simultaneously authorized a transaction in the same security, we will execute a block trade to ensure each client the same average price. This scenario only applies when the recommendation has a timely nature.

If the recommendation is not timely, but represents a firm-wide strategy shift, then recommendations will typically be disseminated at regularly scheduled reviews. This second scenario presents an inherent challenge as our firm does not have discretion over client assets. When multiple clients are deemed to be "interested parties" in either a buy or sell recommendation, our first step is to make contact with each effected client. Trades are placed and potentially available for a block trade only if a batch of several clients all provide verbal or written authorization within a narrow window of time. With respect to a sell recommendation, the clients with the largest dollar amount at stake, not assets under management, in the specific investment will be contacted first. With respect to a buy recommendation, we will attempt to contact all suitable clients based on prospective investment size, which is itself usually a function of assets under management.

Access persons are permitted to participate in block trades assuming that the issue is neither oversubscribed or a private placement.

TRADE ALLOCATION

As a matter of policy, an adviser's allocation procedures must first and foremost be fair to all clients. Our policy prohibits any allocation of trades in a manner that advantages any particular client(s) or group of clients.

Trade allocations on oversubscribed issues will be based upon the intended investment amount, which is often a function of assets under management relative to all suitable accounts. Allocations on issues, which are not oversubscribed, will be allocated based on each client's expressed interest in the issue.

IPOs

Initial public offerings (“IPOs”) are offerings of securities which frequently are of limited size and limited availability. IPOs may also become “hot issues” which are offerings that trade at a premium above the initial offering price.

In the event that RWM participates in an IPO, we will allocate IPO shares fairly and equitably among our advisory clients according to a specific and consistent basis so as not to advantage any client. If the IPO is oversubscribed, any and all employees are expressly excluded from participation in the allocation of shares. 

PROXY VOTING

As disclosed in our advisory agreement, Robbins Financial Advisory Service, Inc., as a matter of policy and practice, has no authority to vote proxies on behalf of advisory clients because we do not hold discretion over client assets. We may offer assistance as to proxy matters upon client’s request, but the client always retains the proxy voting responsibility. If the client is a trust for which an employee is the trustee, then it is the trustee’s responsibility, as a fiduciary, to vote proxies in the best interest of the income beneficiaries and remaindermen.


Trade Errors

RWM holds fiduciary responsibility to effect orders correctly, promptly and in the best interests of our clients. In the event any error occurs in the handling of any client transactions, due to our action, or inaction, we will expeditiously seek to identify and correct any errors without disadvantaging the client or benefiting RWM in any way.

If the error is the responsibility of RWM, any client transaction will be corrected and we will be responsible for any client loss resulting from an inaccurate or erroneous order.

 

GRAPHS AND CHARTS

 

No graph or chart contained in this presentation can or should be relied upon in making investment decisions.

 

SELECTION OF INVESTMENTS FOR SAMPLE MORNINGSTAR DATA AND GRAPHS

 

In recognition of your uniqueness, Robbins Wealth Management customizes all recommendations to each individual client basis. The investments selected for display in this presentation are for illustrative purposes only. They are not intended to be taken as specific recommendations for any given investor. The investments and strategies discussed or recommended in this report may be unsuitable for investors depending on their specific investment objectives and financial position. Past performance is not necessarily a guide to future performance. The price or value of the investments or investment classes to which this presentation relates, either directly or indirectly, may fall or rise against the interest of the investor. This blend of investments was chosen because they closely approximate the type of advisory services currently offered by RWM. The portfolio size of $360,000 was arbitrarily chosen. It should not be assumed that recommendations made in the future will be profitable or will equal the performance of the securities selected for this illustration. These selections do not reflect any actual transactions and should therefore be understood that they do not represent actual choices made. However, the firm-wide performance data does represent actual performance. There is no guarantee that these figures will be attained in future application. Any projected figures may change materially due to actual market conditions or any deviation from assumptions. As with any projections, real or implied, the results are only as valid as the specific estimates on which they are based. The information and data contained in this report were obtained from sources believe to be reliable. This presentation is for illustration purposes only and does not represent any guarantee that figures presented will be obtained.

 

All reports and graphs are models and DO NOT reflect actual account balances or trading. Model results are limited as they are based on unique assumptions, such as investment time horizon and risk preference. RWM customizes all investment recommendations to each unique clients’ objectives, preferences, and suitability.

Our regulatory disclosure, Part II of Form ADV, is available for you to view.

The current PowerPoint Presentation is updated through: 

August 13, 2010

 

 

                                            

                                            

©2010 Robbins Wealth Management. All rights reserved.