Realta Investment Advisors, Inc. (“Realta Investment Advisors” or “RIA”) is an investment advisory firm that is registered with the U.S. Securities and Exchange Commission since June 6, 2007. RIA is wholly owned by Orange Street Holdings, Inc. RIA provides ongoing investment advice and management of client assets through its investment advisor representatives, to whom we refer as “Financial Advisors.” Financial Advisors provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange-traded funds (“ETFs”), variable annuity subaccounts, real estate investment trusts (“REITs”), equities, fixed income securities, advisory programs offered by us or third-party investment advisory firms, and options. Our Financial Advisors may also offer advice related to RIA-approved direct participation programs, private placements, and other alternative investments, such as alternative energy programs, leasing programs, and real estate programs. Through our Financial Advisors, we provide a variety of investment management services, including portfolio management (implemented by Realta Investment Advisors or an independent, third-party money manager), investment consulting, financial planning, and estate planning. Our Financial Advisors may provide advice in areas such as wealth management, investment consulting, portfolio management, asset allocation, cash management/treasury services, and/or financial and estate planning. RIA's Financial Advisors may market under the Realta brand or under a business name of their choosing. When marketing under a business name other than Realta, a Financial Advisor will distinguish between business done by Realta and other non-Realta business lines in which an Advisor may engage. Our advisors who use their own brand name have been instructed to disclose on advertising and client correspondence that their advisory services are offered through us, and when applicable, their brokerage services are offered through our affiliated Broker Dealer. RIA is also affiliated with Realta Equities, Inc. (“REI”), a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”), and many RIA Financial Advisors are also registered with REI as a broker-dealer registered representative. Therefore, in such a case, Financial Advisors can offer a client both investment advisory and brokerage services. When acting as a registered representative, these representatives will charge commissions on a per-transaction basis when implementing their advice for clients. Before engaging with a Financial Advisor, clients should take time to consider the differences between an advisory relationship and a brokerage relationship to determine which type of service best serves the client’s investment needs and goals. Clients should speak to the Financial Advisor to understand the different types of services available through Realta either through RIA or REI when the Financial Advisor is registered with both entities, and to determine which assets will be managed on an advisory basis and which assets will be sold through a brokerage basis. Financial Advisors who are dually registered as general securities representatives of its affiliated broker-dealer, Realta Equities, Inc. may recommend an investment as part of your advisory relationship and charge a fixed annual fee as described in this brochure and pursuant to your advisory agreement, or, if it is in your best interest, may make recommendations in their capacity as a brokerage representative that you purchase securities in a brokerage account for which you will pay a commission. Your Financial Advisor will disclose any commission he or she will earn on these sales and will compare that cost to what he or she estimates it would cost you to hold the investment in your advisory account over time. Although cost is always a consideration when determining 2 of 38 if a purchase is in your best interest, it is not the only factor. Your advisor will present his or her reasons to you verbally at the time of the recommendation or in writing on the firm’s disclosure forms signed by you. In this Brochure, when RIA describes a service or process, it is speaking solely to RIA’s service or process when providing investment advice under an advisory agreement. This Brochure does not speak to the services and processes of its affiliated broker-dealer REI. This Brochure does not describe services provided by your Financial Advisor when he or she is serving you as a general securities representative of REI. 3 of 38 INVESTMENT ADVICE Our Financial Advisors provide advice that is tailored to the individual needs of the client based on the financial information and the investment objective(s) communicated by the client. Clients may impose restrictions on investing in certain securities or groups of securities by notifying the Financial Advisor in writing (including in the Investment Advisory Agreement). Clients’ proposed restrictions may or may not be accepted by Realta. PORTFOLIO MANAGEMENT SERVICES -- WRAP FEE PROGRAMS VERSUS TRADITIONAL MANAGEMENT PROGRAMS Some of our Financial Advisors participate in "wrap fee" programs, by providing portfolio management services. Under a wrap fee program, advisory services and transaction services are provided for one fee. This is different from a traditional management program whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. For these accounts, depending upon the platform or program, Realta Investment Advisors, its Financial Advisors, the Custodian, or another third-party may:
• Assist clients in the identification of investment needs and objectives.
• Develop an investment policy and/or asset allocation strategy designed to meet the client’s objectives.
• Recommend specific investment style and asset allocation strategies.
• Evaluate Money Managers and investment vehicles meeting style and allocation criteria.
• Negotiate fees to be paid to Money Managers.
• Assist in identification of appropriate Money Managers and investment vehicles suitable to the client’s goals.
• Manage client assets directly, eliminating the necessity for a Money Manager.
• Assist in identification of an RIA Financial Advisor to manage client assets.
• Engage selected Money Managers and investment vehicles on behalf of the client.
• Perform ongoing monitoring and due diligence of an individual Money Manager’s performance and management.
• Review the client’s account for adherence to objectives, policy guidelines, and/or asset allocation on a periodic basis.
• Recommend reallocation among Money Managers or styles within the program.
• Hire or fire Money Managers utilized by clients.
• Provide reporting to the client regarding the performance of his/her/its account. RIA and the Financial Advisor each receive a portion of the wrap fee for their services. Wrap fee programs may be more expensive than traditional programs that charge transactional fees, dependent upon the number of transactions you anticipate in your account. Consult your Financial Advisor for which program is best suited for your needs. ADVISORY SERVICES RIA provides its clients with investment management and consulting services through investment advisor representatives (IARs), who are registered with our firm. Through our relationships with Wells Fargo Advisors (Wells Fargo), Axos Advisor Services (Axos) and AssetMark we make available Advisory Platforms, which our IARs can utilize to manage your advisory accounts. 4 of 38 Advisory Platforms Wells Fargo In November 2016, First Clearing, LLC merged and consolidated its operations into Wells Fargo Advisors, LLC. The resulting firm is now known as Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker- dealer and non-bank affiliate of Wells Fargo & Company. WFCS operates its brokerage and advisory business under the trade name “Wells Fargo Advisors.” First Clearing is also a trade name used by WFCS when carrying customer accounts and acting as custodian for funds and securities deposited through introducing firms such as REI or as a result of transactions it processes for customer accounts. If you open an account through a program sponsored by Wells Fargo, you will receive the applicable program disclosure brochure prepared and distributed by Wells Fargo. First Clearing is the trade name used by Wells Fargo for clearing and custodial services of our Affiliate Broker- Dealer (Realta Equities, Inc. or REI) and therefore the decision to use Wells Fargo sponsored programs is a main factor in also recommending First Clearing and vice-versa. This affiliation presents a conflict of interest in that RIA is incented to refer accounts to programs sponsored by RIA or Wells Fargo because the assets will be maintained with its affiliate or affiliate’s clearing firm, which provides direct and indirect income to REI. The Firm mitigates this conflict by disclosing this conflict of interest in this Brochure and by periodically monitoring account activity and best execution. In addition, the firm believes it enjoys lower costs and efficiencies in utilizing its affiliate BD in such a fashion. Regardless, clients are encouraged to discuss programs at other qualified custodians with their Financial Advisor to determine the most suitable option in this regard. Programs on the Wells Fargo platform include:
• Private Investment Management
• Asset Advisor (Non-Discretionary)
• Allocation Advisors
• Masters
• Personalized Unified Managed Account
• Wells Fargo Compass
• Private Advisor Network
• CustomChoice
• FundSource and Pathways. Axos Axos Clearing LLC under its trade name Axos Advisor Services (“Axos Clearing” or “Axos Advisor Services”) makes available a variety of products and services to independent investment advisors for use with their clients (the “Services”). The Services also include any of the proprietary software or online portals or mobile applications used by and/or offered by or through Axos Advisor Services including, but not limited to, the Liberty platform and other platforms or mobile applications offered by Axos Advisor Services or any affiliates of Axos Advisor Services (collectively, the “Axos Advisor Services Technology”). Axos Clearing is the trade name used by Axos Advisor Services for clearing and custodial services of our Affiliate Broker-Dealer (Realta Equities, Inc. or REI) and therefore the decision to use Advisory Programs on the Axos Advisor Services platform is a main factor in also recommending Axos Clearing and vice-versa. This affiliation presents a conflict of interest in that RIA is incented to refer accounts to programs sponsored by RIA because the assets will be maintained with its affiliate or affiliate’s clearing firm, which provides direct and indirect income to REI. The Firm mitigates this conflict by disclosing this conflict of interest in this Brochure and by periodically monitoring account activity and best execution. In addition, the firm believes it enjoys lower costs and efficiencies in utilizing its affiliate BD in such a fashion. Regardless, clients are encouraged to discuss 5 of 38 programs at other qualified custodians with their Financial Advisor to determine the most suitable option in this regard. Programs on the Axos Advisory Platform include:
• RIA Advisory Program AssetMark We have entered into a co-advisory relationship with AssetMark, Inc. (AssetMark). AssetMark is a registered investment adviser with the Securities and Exchange Commission (SEC) and provides consulting services and AssetMark Platform access to our Financial Advisors. AssetMark makes a number of different Advisory Programs available to clients through the Platform. RIA has also entered into an agreement to offer the AssetMark Advisor Managed Portfolios (AMP) program to its clients. AMP is an open architecture, discretionary program for which RIA Financial Advisors serve as the account managers on a discretionary basis. Through the AMP program, your Financial Advisor has access to and can select from stocks, bonds, mutual funds, and ETFs to construct a portfolio based on your profile and objectives. AMP is a wrap fee program whereby the management fee and the administrative fee are combined. Programs on the AssetMark Advisory Platform include:
• Guided Portfolios
• Single Strategy Portfolios
• Separately Managed Accounts
• Unified Managed Accounts
• Multiple Strategy Accounts
• Advisor Managed Portfolios While you may be solicited to establish an account through any of the programs described in this document, not all programs offered are suitable for you. Therefore, your Financial Advisor must analyze your financial situation to recommend a program or service that is suitable for you. Further, it should be noted while you receive individualized treatment from your Financial Advisor, if you have an account managed by us (i.e. the RIA Financial Advisor is responsible for selecting underlying portfolio holdings within client accounts) you will receive more personalized RIA treatment than if your account is managed by selected third-party money managers (i.e. the selected money manager is responsible for selecting underlying portfolio holdings within client accounts). IAR Managed Programs Wells Fargo Platform PRIVATE INVESTMENT MANAGEMENT (PIM) AND ASSET ADVISOR PROGRAMS RIA participates in the Private Investment Management (PIM) and Asset Advisor programs sponsored by Wells Fargo. PIM and Asset Advisor are wrap-fee programs, so they do not bill transaction costs separately from the overall management fee, provided that the number of transactions per calendar year does not exceed 120. The cost for additional transactions will be billed directly to your account; however, the Financial Advisor (at his or her sole discretion) may elect (but is not obligated) to pay these fees rather than pass them through to you. Both programs allow the RIA Financial Advisor to provide on-going supervision and management services. PIM is an Advisor Directed program whereas Asset Advisor is a Client Directed program. All client accounts through the PIM and Asset Advisor programs must be established through First Clearing. 6 of 38 The description provided in this section regarding the Wells Fargo sponsored programs we manage is intended to provide you with a brief summary of each program. Wells Fargo will provide you with a full description and disclosure document at the time you establish an account through either the PIM or Asset Advisor programs. Please note that some restrictions Wells Fargo places on PIM accounts for its own clients are not necessarily applicable to RIA clients, such as the ability to include certain types of securities (such as low-priced stocks or concentrated positions) in the account. ADVISER AS PORTFOLIO MANAGER PROGRAM (APM) Each program described in this section requires that we enter into an advisory agreement together for services to be provided. Either of us may end the agreement by providing notice to the other party. In the event you end our services (in writing, pursuant to the advisory agreement), we will terminate the agreement effective with your notification. We may end our services by providing you with written notice. There are other events which may constitute constructive termination of your agreement – please consult your advisory agreement for more details about termination. RIA generally requires using First Clearing as the qualified custodian and clearing broker/dealer for all client accounts established within the Adviser as Portfolio Manager Program (APM). The conflicts discussed above are equally applicable to these programs and mitigated in the same fashion. In the APM program, your adviser will engage you in a traditional advisory relationship, where you pay a fee on assets under management, but also incur ticket charges for trades. The cost for transactions will be billed directly to your account; however, the Financial Advisor (at his or her sole discretion) may elect (but is not obligated) to pay these fees rather than pass them through to you. This program allows the RIA Financial Advisor to provide personalized on-going supervision and management services over your account(s) in the program. APM is an Advisor Directed program. Client accounts are usually established through First Clearing, however the APM program is flexible in that your adviser may recommend other custodians approved by RIA if it is in the best interest of the client. Your adviser may also choose to engage and enroll you in a third-party money manager’s program directly or through a service such as Envestnet, AssetMark, or SEI. Further information about their services and programs are disclosed in their ADV Disclosure Brochure. Third-Party Money Manager Programs – Separate Account Manager Programs RIA participates in separate account manager programs sponsored by Wells Fargo. Through these programs, RIA Financial Advisors assist you in allocating your assets among one or more third-party money managers. Currently, we participate in the following Wells Fargo sponsored wrap-fee programs:
• Allocation Advisors
• Masters
• Wells Fargo Compass, and
• Private Advisor Network RIA also participates in the Private Advisor Network Investment Consulting Service (Network) platform, a program sponsored by Wells Fargo. Under the Masters and Network programs, RIA Financial Advisors assist you in determining and selecting third-party money managers who will be provided discretionary authority to select investment options to manage your assets. Under the Allocation Advisors and Compass programs, the Wells Fargo Advisory Services Group will be provided discretionary authority as it serves as the third-party money manager. 7 of 38 Through the Master’s program, RIA Financial Advisors may be provided discretionary authority to select and remove underlying third-party money managers. Under this type of arrangement, your RIA Financial Advisor does not have to receive your authorization to add or remove a money manager. When you do not grant discretionary authorization to select and remove third-party money managers, you must provide us and the custodian, i.e. First Clearing, with written instructions to add or change a money manager. The description provided in this section regarding the Wells Fargo sponsored programs we manage is intended to provide you with a brief summary of each program. Wells Fargo will provide you with a full description and disclosure

document at the time you establish an account through any of the programs. In addition, you will receive a copy of all third-party money managers who manage your assets. Only third-party money managers that are registered as investment advisers or are exempt from investment adviser registration will be recommended. Mutual Fund Wrap-Fee Programs RIA participates in two mutual fund wrap-fee programs sponsored and administered by Wells Fargo:
• CustomChoice
• FundSource and Pathways. CustomChoice is a non-discretionary client directed mutual fund wrap program. You must execute the CustomChoice Client Agreement to participate in this program. Accounts through this program are managed by us on a non-discretionary basis. There are approximately 5,000 no-load, load waived, and institutional share class mutual funds from which to choose. You must approve all implementation decisions made through this program. FundSource is a discretionary mutual fund wrap program based on Wells Fargo research-driven Optimal Blends or Customized Blends. You must execute the FundSource Program Agreement to participate in this program. All assets are managed by Wells Fargo who is given discretionary authority to implement changes within your account based on your individualized situation and based on information provided by you to your Financial Advisor. Portfolios are comprised of mutual funds selected by Wells Fargo. Before May 2011, Pathways was a stand-alone advisory program offered by Wells Fargo. Pathways is now an asset allocation option within the FundSource Program that allows you to allocate assets among mutual fund portfolios (Pathways Funds) which are administered by Russell Investment Company (Russell). Russell will provide a selection of optimal blends of model investment portfolios or accept instructions from you with respect to a custom blend in various funds that are operated and administered by Russell, based on its evaluation of your financial goals, circumstances and risk tolerances. Russell is responsible for evaluating and retaining one or more investment management organizations to manage each Pathways Fund. The portfolios are designed for a specific investor. You must execute the Pathways Program Agreement to participate in this program. We are not related to Russell, and Wells Fargo and Russell are not related entities. A portion of the fee charged for Pathways is paid to Russell for its investment advisory services. We provide you with consulting services when selecting optimal blend mutual fund portfolios constructed by Wells Fargo for the FundSource program and by Russell for the Pathways program. You may also create your own customized mutual fund portfolio blend. The description provided in this section regarding the Wells Fargo sponsored programs we manage is intended to provide you with a brief summary of each program. Wells Fargo will provide you with a full description and disclosure document at the time you establish an account through any of the programs. Pathway’s clients will also receive all necessary disclosure documents relating to Russell. 8 of 38 Axos Advisor Services (Axos) Platform RIA Advisory Program In this program, our IARs provide investment management services either through constructing their own portfolios or by engaging with third-party, non-affiliated registered investment advisors (money managers) to assist with the advisory services to their clients or a combination of the two. The IARs work with each of their clients to identify their respective risk profiles and investment objectives and provide portfolios that are optimized for each of their clients. The recommended portfolio will typically include investments such as mutual funds, exchange-traded funds, variable annuities, stocks, bonds, direct participation programs or a combination of these products. A portion of your account may also remain in cash or a money market fund. If the IAR engages a third-party money manager, RIA will enter into sub-advisory agreements with these third- party money managers. RIA will be acting as the Registered Investment Adviser and the Client will be paying the combined investment advisory fees to RIA. RIA will then use the payment of the combined fee to pay its sub- advisor. In some cases, for greater transparency, the combined fee may be itemized on Client’s statements. We recommend you meet with your Financial Advisor (a.k.a. IAR) on a regular basis to review your financial situation, investment objectives and current holdings, and you should make your Financial Advisor aware of changes to your circumstances, on a timely basis. In this program, transactions are placed through our affiliated broker-dealer, Realta Equities, and its unaffiliated clearing broker-dealer and custodian, Axos Clearing, LLC. AssetMark Platform Advisor Managed Portfolios (AMP)AMP is an open architecture, discretionary program for which RIA IARs serve as the Account Managers on a discretionary basis. RIA IARs have discretionary authority on how to invest all client assets in these accounts, provided they act in line with the client’s risk profile and investment objectives. AMP accounts can be invested in stocks, bonds, mutual funds, and ETFs selected by the IARs. AMP is a wrap fee program whereby the management fee and the administrative fee are combined. Depending on the account registration and/or the investments held within the account, Brokerage Fees may be charged by the custodian selected by the client through consultation with the IAR. The custodian may also charge an account maintenance fee that the client will pay on an annual basis 3rd Party Manager Programs (TAMP)AssetMark provides account administration, custody, brokerage and advisory services; the Platform is therefore considered a “wrap program.” AssetMark has developed internet- based software which provides RIA IARs the ability to directly monitor their Clients’ Accounts, download information concerning changes in the Platform, and access current information relating to the Platform. Investment Strategies are available through three general “Solution Types” (or “Solutions”) on the Platform.
• Model Portfolios – Client Accounts are allocated among securities and other investment vehicles on a non-discretionary basis pursuant to Model Portfolios provided by “Portfolio Strategists” (also referred to as “Model Providers”). Model Portfolios include mutual fund and ETF investment strategies and Separately Managed Accounts (“SMA”). SMA Model Portfolios are allocated among securities and other 9 of 38 investment vehicles in accordance with the model and are typically selected for a specific asset class. AssetMark will serve as the Overlay Manager with regard to SMA accounts, as described below.
• Individually Managed Accounts (“IMA”) – The Client Account is managed and individual Client Account trades are implemented on a discretionary basis by a “Discretionary Manager” (also referred to as an “Investment Manager”). For some IMAs, AssetMark serves as the Discretionary Manager; for others, a third-party manager serves as Discretionary Manager and AssetMark has no role in trading for the IMA.
• Individual Mutual Fund (“IMF”) – Client accounts are allocated to a single mutual fund and is intended to complement other Solution Types available on the AssetMark Platform, as part of the Client’s overall Portfolio. The IMF’s used in this advisory service can be Proprietary or third-party funds. Each IMF is not available at all Custodians. Clients should be aware that the Platform Fees charged by AssetMark for this service can be higher or lower than those charged by others in the industry or directly from the third- party mutual fund provider, and that it can be possible to obtain the same or similar services from other investment advisers at lower or higher rates. AssetMark may waive the Platform Fee in its discretion. A Prospectus for any individual mutual fund made available under this Solution Type can be obtained upon request from AssetMark or the Client’s Financial Advisor. Clients should review fund prospectuses and consult with their Financial Advisor if they have questions regarding these IMF Solution Types. The mutual funds shares selected for use can be institutional or retail shares, and can include administrative service fees, sub-transfer agency fees and/or 12b-1 fees, that are fees borne by Clients. See Servicing Fees Received by Custodians, including AssetMark Trust Company and Share Class Use for a discussion of 12b-1 fees, administrative service fees and sub-transfer agency fees and the Fees & Investment Minimums table at the back of this Disclosure Brochure for the Platform Fees charged IMFs. Some Solution Types are available through third-party Investment Management Firms unaffiliated with AssetMark. Other Solution Types are proprietary Strategies available through APS, or Individual Mutual Funds. FINANCIAL PLANNING SERVICES Realta Investment Advisors may provide financial planning to clients. Financial planning services are offered on a comprehensive or à la carte (limited focus) basis. Financial plans may encompass all or some of the following areas of financial concern to the client:
• Estate Planning Goals
• Retirement Planning
• Education Planning
• Insurance Planning/Risk Management
• Investments
• Asset Allocation Review and Recommendations The Financial Advisor obtains appropriate information from the client through personal interviews (including a discussion of current financial status, future goals, and attitude towards risk) and reviews the documents and data supplied by the client. A written financial plan may be prepared and provided. The implementation of financial plan recommendations is entirely at the discretion of the client. Financial plans are not limited in any way to products or services provided by any particular company. However, in general, only products and services that Realta Investment Advisors is able to provide will be offered. ADVISORY SERVICES TO RETIREMENT PLANS AND PLAN PARTICIPANTS CONTRACTED BY PLAN SPONSOR 10 of 38 RIA offers various levels of advisory and consulting services to employee benefit plans and/or to the participants of such plans (“Participants”). The services are designed to assist plan sponsors (“Plan Sponsors”) in meeting their management and fiduciary obligations to the Participants under the Employee Retirement Income Securities Act (“ERISA”) and the Pension Protection Act of 2006 (“PPA”). Generally, investment advice provided to Plan Sponsors and Participants is regulated under ERISA and the PPA. We will provide a set of services to Plan Sponsors and their Participants which may include all or some of the offerings described below. Plan Sponsors must make the ultimate decision to retain us for pension consulting and other advisory services including services at the participant level. The Plan Sponsor is free to seek independent advice about the appropriateness of any recommended services for the plan. The following services are provided for general informational purposes. Not all clients contracting for retirement plan services will receive every level of service described below. The exact scope and types of services provided will be agreed upon with each client and listed in the client agreement. The services provided to employee benefit plans (“the Plan”) and their Plan Sponsors may include the following: Investment Policy Statement. RIA may assist with the drafting and adoption of an Investment Policy Statement (IPS) for each Plan. Cash Flow Analysis. RIA may assist the Plan’s oversight committees with the review of the quarterly cash flow analysis as provided by the plan provider. Selection of Qualified Default Investment Alternative. RIA may recommend to the client an investment fund product or model portfolio meeting the definition of a “Qualified Default Investment Alternative” (“QDIA”) in ERISA Regulation 2550.404c-5(e)(3). The QDIA shall be reflected in the IPS. Investment Performance Monitoring or Analysis. RIA may assist the Plan’s oversight committees with the review of the quarterly investment performance of the Plan’s investment options. Under applicable circumstances, RIA will monitor the appropriateness and continued suitability of each of the investments with a view to complying with the “broad range” requirement under ERISA Section 404(c). Asset Allocation Analysis. RIA may assist the Plan’s oversight committees with the review of the quarterly asset allocation analysis as provided by the Plan provider. Performance Reports. RIA may prepare reports evaluating the performance of the Plan’s investment manager(s) or investments, as the case may be, as well as comparing the performance thereof to benchmarks set forth in the IPS. The information used to generate the reports will be derived from statements provided by the client. Education Services to Plan Committee. RIA may provide training for the members of the Plan Committee with regard to their service on the committee, including guidance with respect to fiduciary duties. Participant Education Services. RIA may conduct in-person, group sessions and provide printed educational materials (which may include posters, payroll stuffers, and emails) to Participants, providing information to them about the investment options under the Plan and providing information on how to complete plan enrollment paperwork. Services provided under an “Eligible Investment Advice Arrangement,” as defined under the PPA, shall be governed by a separate agreement. Expense Analysis. RIA may assist the Plan’s oversight committees with the review of the investment expense characteristics for each of the investment options. Investment Structural Analysis. RIA may assist the Plan’s oversight committees with the review of the Investment Structural Analysis for each of the investment options. Third Party Product or Service. Advisory services provided to retirement plans may be solely provided by Financial Advisors, or in combination with third parties and their retirement plan services. RIA may use the product or service offered by a third party in providing services to a client and the Plan. Plan Search Support. RIA may manage the preparation, distribution, and evaluation of Request For Proposals, finalist interviews, and conversion support. Additional Services. Services as agreed upon by RIA and client. Services for Plan Participants. Plan Sponsors retain RIA and its Financial Advisors to provide services to Participants pursuant to an “eligible investment advice arrangement,” as defined under the PPA. The scope of 11 of 38 the services and fees are established and approved in advance by the Plan Sponsor and shall be clearly set forth in the executed agreement for services. Financial Advisors will meet with individual Participants to collect pertinent information regarding their financial circumstances and investment objectives. Financial Advisors will then deliver advice either by:
• providing direct investment advisory services to the Participant (in which case the RIA fee will not vary based on the advice given to the Participant)
• generating portfolio recommendations for a Participant based on an unbiased computer model that has been certified and audited by an independent third party. ADVISORY SERVICES TO RETIREMENT PLAN PARTICIPANTS NOT CONTRACTED BY PLAN SPONSOR Participants also directly retain RIA and its Financial Advisors to provide direct advisory services by executing a Realta Investment Advisors Investment Advisory Agreement. The services and fees are set forth in the executed agreement and approved by participant in lieu of the plan sponsor. Participants may elect to roll-over retirement plan assets to an individual account at RIA under the same Financial Advisor who provided advisory services while those assets were maintained within the original qualified plan. SUB-ADVISORS RIA, at times, engages other registered investment advisors to assist with advisory services to its clients. In this case, RIA will enter into a sub-advisory agreement with these sub-advisors. In these cases, RIA will be acting as the Registered Investment Advisor and the client will be paying the combined investment advisory fees to RIA. RIA will then use the payment of the combined fee to pay its sub-advisor. PROGRAM CHOICE DISCLOSURES The specific advisory program selected by the client may cost the client more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account, the historical or expected size or number of trades for the account, the types of securities and strategies involved, and the number and range of supplementary advisory and client-related services provided to the account. Investment recommendations and advice offered by RIA and its advisors do not constitute legal, tax, or accounting advice. Clients should coordinate and discuss the impact of the financial advice they receive from a RIA advisor with their attorney and accountant. Clients should also inform their advisor promptly of any changes in their financial situation, investment goals, needs, or objectives. Failure to notify the advisor of any material changes could result in investment advice not meeting the changing needs of the client. In some cases, an independent investment advisor may engage the investment advisory services of a RIA advisor to manage a portion of the investment advisor’s client accounts. PROGRAM CHOICE CONFLICTS OF INTEREST Clients should be aware that the compensation to RIA, its affiliates, and your advisor will differ according to the specific advisory program chosen. This compensation to RIA, its affiliates, and your advisor may be more than the amounts we would otherwise receive if you participated in another program or paid for investment advice, brokerage, and/or other relevant services separately. As a result of the differences in fee schedules and other sources of compensation that exist among the various advisory programs and services offered by RIA and your advisor, we have a financial incentive to recommend a particular program or service over other programs or services available through RIA. 12 of 38 REGULATORY ASSETS UNDER MANAGEMENT As of December 31, 2022, Realta Investment Advisors had discretionary assets under management of approximately $670,588,410. The firm has $110,145,861 non-discretionary assets under management.