March 2023 RMG Advisors Disclosure Documents

 Date:  March 29, 2023 

Risk Management Group LLC d/b/a RMG Advisors 

14 South Adams Street 

Rockville, MD 20850 

301-838-4111 

301-838-4211 (f) 

welcome@rmgadvisors.com 

 Websites 

www.rmgadvisors.com 

www.thefedcorner.com 

This Form ADV Part 2 (Investment Advisor Brochure) provides information about the qualifications and business practices of Risk Management Group LLC d/b/a RMG Advisors (“RMG” or “We”). If you have any questions about the contents of this brochure, please contact Jamie S. Lapin, CFP®, CDFA®, AIF® using one of the methods listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration is mandatory for all persons meeting the definition of investment advisor and does not imply a certain level of skill or training.   

 Additional information about Risk Management Group LLC d/b/a RMG Advisors is available on the SEC’s website at: www.adviserinfo.sec.gov  (Investment Advisor Firm – CRD #122366). 

Item 2.  Material Changes  

Since our last ADV Part 2A Brochure annual amendment filing in March 2022, the following material changes have been made:  

Item 4 – RMG offers only non-wrap programs to clients.  

Item 4 – RMG updated its assets under management and assets under advisement as of January 3, 2023. 

Item 4, 5 and 12 – RMG offers asset management services through SEI. 

Item 5, 10, 12 and 14 – RMG investment adviser representatives are no longer affiliated with Grove Point Investments as registered representatives. 

Item 5 – RMG removed our tiered fee schedule for Held Away assets. 

Item 5 – The financial planning fee may be waived by RMG at their discretion for clients with a minimum of $5 million in assets under management with RMG. 

Item 7 – Divorce-related planning is billed in advance with a minimum 10-hour retainer.  

Item 7 – RMG generally has a $1 million minimum investment amount. 

Item 3. Table of Contents

Item 4. Advisory Business 

Advisory Firm  

Risk Management Group LLC d/b/a RMG Advisors is an investment adviser located and registered with the State of Maryland and is a limited liability company (LLC) formed under the laws of the State of Maryland. Jamie S. Lapin is the Managing Member and 100% Owner of RMG Advisors. RMG Advisors filed its initial application to become registered as an investment adviser in Maryland in 2000, which became effective April 7, 2000. 

Jamie S. Lapin provides investment and financial advisory services and became a CERTIFIED FINANCIAL PLANNER™️ in 1982. At RMG, we consider it our responsibility to provide reasoned, seasoned financial planning, investment advice and implementation of your plan to help you develop and meet your needs and objectives. RMG’s aim is to provide quality personal service and guidance, build strong relationships and help simplify and improve your financial affairs.  

Introduction 

The investment advisory services of RMG are provided to you through appropriately licensed and qualified individuals who are investment adviser representatives of RMG. RMG’s investment adviser representative designations include CERTIFIED FINANCIAL PLANNER™️ and Accredited Investment Fiduciary®. Both organizations mandate certificants maintain strict fiduciary standards in order to retain these designations. 

Advisory Services  

Financial Planning 

RMG provides financial planning consistent with your goals and objectives, financial and tax status, and risk tolerance. Planning may be comprehensive or segmented to focus on specific needs and objectives including but not limited to investments, insurance, taxes, life transition, and estate planning. There may be a printed document and/or planning discussion. With your approval, there may be conversation with your other professionals and/or family members as a part of the process. 

RMG provides both comprehensive and modular financial planning services. Most often the consultation with businesses, individuals or families is focused on comprehensive financial planning. It may also have to do with one or more specific issues such as retirement, divorce, life transition, college planning, philanthropy, estate or other financial decisions that do not necessarily involve securities.  

Special Projects 

RMG may work with you to help you accomplish special projects on a wide range of financially based endeavors. These special projects may include but are not limited to developing strategies for complex estate planning including philanthropic and multi-generational planning, blended family planning and special needs trust planning. When used, financial planning reports based on our planning work together may include spreadsheets, graphic presentations and text intended to help you understand how your current plan or recommendations might lead to your accomplishing your financial goals. This does not constitute a guarantee of success, even if all recommendations are followed.  

Investment Management Services 

RMG may provide you with supervisory and management services. Accounts may be directly managed or placed under institutional management with select organizations whose methodologies meet our objectives for your portfolio. Managers are selected after careful due diligence and are monitored closely as to strategy, performance and ethics. While these third-party managers control investment selection, we provide guidance and direction to support your needs and goals. Change of managers, risk levels, payouts and other salient factors remain under our jurisdiction. Managed money is subject to internal management fees and possible other costs, attunement to which is also part of our monitoring and due diligence process. For a small number of clients, RMG has allowed client-managed account options for clients who want to manage or hold a portion of their assets outside the management services provided by RMG. Any additional fees will be disclosed in the Advisory Agreement with the client.   

Investment Management Services are based on your individual needs. Data gathering begins with an initial interview and is undertaken to determine your financial situation and investment objectives as well as your needs, goals, concerns and investment preferences. You may set appointments during normal business hours to discuss your account, financial situation or investment needs. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives.  We are always reasonably available to consult with you relative to the status of your Account.  You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities.  

It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you.  We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts.  

Conflicts may arise in the allocation of investment opportunities among accounts that we manage.  We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved.  However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner.  If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. 

SEI Asset Management Program 

RMG has entered into a Sub-Advisor Agreement with SEI Investments Management Corporation (“SIMC”), a registered investment advisor. This agreement allows RMG to allocate client assets for participation in SIMC’s Sub-Advised Program. RMG is responsible to determine whether participation in the program is appropriate for our clients. Under the program, SIMC provides discretionary investment management services to RMG and makes available investment strategy models of or investment managers appointed by SIMC. These models seek to achieve particular investment goals and are not tailored to individual clients. RMG may allocate client assets to one or more of SIMC’s models which match a client’s objectives. SIMC then invests the allocated funds in accordance with the selected models as updated from time to time by SIMC or investment managers appointed by SIMC. In most cases, SIMC will implement those models and execute transactions; in others, the investment manager will do so. 

The SEI Program is a non-wrap program. If you enroll in the SEI Sub-Advised Program, RMG will assist you in the establishment of a SEI Program Account (the Account) at SEI Private Trust Company (SPTC). RMG and SEI, through an advisory arrangement, will have discretionary authority over the assets and transactions in the Account. SPTC is the custodian of this program. All account transactions are processed and cleared through SPTC.  

RMG may choose to invest its clients’ assets into model portfolios of mutual funds and exchange-traded funds (“ETFs”) created by SIMC. This includes the SEI Asset Allocation Models (“SEI Asset Allocation Models”) that consist of allocations to SEI Funds and SEI ETFs.  

RMG helps you determine which strategy is best for your situation and monitor the account. RMG will direct SEI to reallocate your investments in accordance with your changing needs. SEI has the authority to replace a previously selected portfolio manager or SEI Fund without your prior approval.   

Divorce and Mediation Services 

Jamie Lapin undergoes regular training and certification in various fields of financial planning.  

We can help you better discern reasonable divorce settlements by sharing extensive knowledge of the intricate financial details concerning tax issues, capital gains, dividing pensions, etc. We work with you and/or your counsel as advisors and sometimes as mediators as part of a collaborative team, bringing an innovative and creative approach to settling cases. We’ll provide you with information that informs and illustrates the financial result of a variety of divorce settlements. Jamie Lapin may appear as an expert witness as needed and agreed to. Depending on needs and objectives, there may be physical reports during our work together. Those often include reports for financial planning related to divorce and are comprised primarily of spreadsheets and graphic presentations, the objective of which is to help you and your team understand settlement options and their impact on your financial future.  

Federal Retirement Planning Services 

We provide federal employees and their families advice that is specific to their needs. Federal employees have unique benefits under the FERS program that have special rules and regulations. RMG will help clients navigate retirement dates, calculating their FERS annuity, discussing survivorship, FEHB, FEGLI, FEDVIP, TSP, FLTCIP, and other relevant components. In addition to the specifics, RMG helps clients contextualize how these benefits relate to the rest of their lives to help achieve their financial goals.  

Educational Services 

Advisors teach classes or are invited as speakers by various organizations. These events include presentations designed to help those in our community better understand financial decisions. RMG considers that an opportunity to give back to the community and as such generally accepts no honorarium. We do not control whether the sponsoring organizations may choose to charge a fee for attendance. 

Investment Advice Relating to Retirement Accounts 

Part of RMG’s advice may include discussion of whether to maintain retirement investment proceeds in your current retirement account, transfer them to another vehicle or make distributions. We do so as a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. When making a recommendation to transfer retirement accounts RMG’s compensation following such a transaction creates conflicts of interest so RMG operates under a special rule that requires that we act in your best interest and not put our interest ahead of yours. 

Under this special rule’s provisions, RMG must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC: 

• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of RMG ahead of yours when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that RMG gives advice that is in your best interest;
• Charge no more than is reasonable for the services RMG provides; and
• Give you basic information about conflicts of interest.

RMG earns investment advisory fees on assets managed by our firm, which creates a conflict. RMG has taken steps to manage this conflict of interest. RMG has adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described above, (ii) not recommend investments which result in RMG receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by RMG and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. 

Variable Sub-Account Management Services 

RMG offers variable insurance sub-account management services. RMG offers guidance on variable annuity or variable life contracts by monitoring sub-accounts available from the insurance company issuing the variable annuity or variable life contract. Guidance is provided within the content of your overall financial goals. Your responsibilities include notifying us of any updates regarding financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives related to these insurance products. RMG will monitor your sub-accounts and recommend exchange of sub-accounts as necessary and in accordance with your investment objective and risk tolerance.  

Wrap Fee Programs 

RMG only offers advisory services through traditional, non-wrap fee programs. Whenever a fee is charged to a client for services described in this brochure, RMG will receive all or a portion of the fee charged. In these traditional management programs, advisory services are provided for a fee, but transaction costs are billed separately on a per-transaction basis, if applicable. 

As of January 3, 2023, we had $77,674,290 in assets under direct management on a discretionary basis, and $0 in assets on a non-discretionary basis. In addition, we also had approximately $26,539,458.08 in assets under advisement.  

Item 5. Fees and Compensation 

RMG’s fee schedule is as diverse and modular as our services offered. Financial Planning as a stand-alone process is generally done on a flat fee basis contingent upon the amount of work required by your needs. Often, in going through the process, we may determine that the scope of work needs to be expanded. In such cases, by agreement, the quoted fee may be renegotiated based on the additional work the plan requires. Review and modifications are billed annually, and are generally half the original planning cost, unless there is a major change in the scope of work. Modes and forms of compensation for planning and additional financial services, outside of the ongoing advisory fees and divorce services, may be paid monthly, quarterly, or as a lump-sum. Divorce services are paid on an hourly retainer. 

Our ongoing advisory services are charged as a percentage of assets under management. Hourly charges are often billed in advance as a 10-hour retainer for divorce-related planning or other consulting work with unspecified timelines based on specific client needs. You will be informed at least quarterly of the status of your retainer balance. Unused funds are returned to you within 30 days of notification of terminus of service and retainer replenishment is due on an immediate basis as drawdown reduces the balance by half. If we terminate the process early, our usual and customary hourly fee of $350.00 (or $400.00 for mediation, $450.00 for Court/Court prep) will be applicable to time spent on your behalf, with any remainder due to the client or RMG to be paid within 30 days. 

AUM billing is in arrears and calculated based on actual time under management. Funds are generally billed directly through your portfolio. Billing is “householded” (grouped by family members in the same household under our management) to allow you and your family, including your partner, parents and children, to take advantage of the cost reductions listed below. Payments are due, and will be assessed, on the first day after the end of each calendar quarter based on the value of the account assets under management as of the close of business on the last business day of the previous quarter. The quarterly fee payments for the first and last billing periods are pro-rated to reflect the actual days that client’s accounts were subject to management by RMG.  

The quarterly fee will be automatically deducted, with your written approval, from an existing investment account managed by RMG or paid to RMG upon receipt of billing invoice. The payment may also be made directly by check, ACH or credit card through AdvicePay with your written authorization. Additionally, the custodian will provide monthly or quarterly account statements to you, which will reflect these authorized withdrawals.  

SEI is paid directly through expenses of each manager used to manage client accounts, whether SIMC or third-party managers. Other transaction costs are also charged to the client, including without limitation execution charges imposed by unaffiliated broker/dealers or exchanges, wire transfer fees, auction fees, and transfer taxes.   RMG and SEI have discretion to pick the investments and move the client assets between SEI portfolio strategies. When fees are deducted from an account, SEI is responsible for calculating the fee for RMG, debiting the fee from the client’s account and sending RMG’s portion of the fee to us. When a cash position is used as a strategy and a certain portion of the client’s account is allocated to cash, an advisory fee will be charged on the cash position. 

SEI Fund and ETF Models-Based Program 

Under the SEI Asset Allocation Models, SIMC provides non-discretionary services to RMG through the publication of investment models consisting of allocations to these different funds (i.e., SEI Funds, SEI ETFs, third-party funds, or third-party ETFs) allocated to the models. Specifically, SIMC: (1) makes available the models, developed and periodically updated by SIMC designed to achieve the model’s stated investment objective or goal based upon SIMC’s capital market assumptions and any other criteria that SIMC, in its sole discretion, determines is relevant; and (2) periodically publishes for consideration by firm revisions to a model’s percentage asset allocations among the underlying SEI Funds, SEI ETFs, third-party funds, or third-party ETFs, or adds, removes, or otherwise changes the individual SEI Funds, SEI ETFs, third-party funds, or third-party ETFs underlying an existing model. 

SIMC and its affiliates earn fees from the SEI Funds and SEI ETFs, which costs are indirectly borne by Clients invested in these models. As a result, SIMC does not charge RMG or its clients a direct fee for the use of the SEI Asset Allocation Models. In addition, SEI Private Trust Company (“SPTC”), the custodian to the Client and an affiliate of SIMC, will not charge a custodial platform fee on Client assets invested in SEI mutual funds, SEI ETFs and third-party non-transaction fee (NTF) mutual funds. Clients participating in the SEI Sub-Advised Program will not pay a custodial platform fee, however, the Client will pay an annual advisory fee to SIMC as Sub-Advisor stated in their advisory agreement with RMG.    

The custody of all funds and securities are maintained by SPTC. A complete description of SEI’s advisory services and fees, custody fees and account minimums will be disclosed in their onboarding documents provided to you by RMG prior to or at the time an agreement for services is executed and the account is established.   

SEI may also charge transaction fees, which are separate and apart from RMG’s fee, and from which RMG does not directly benefit. These fees will be itemized on the account statement. You should review and verify the accuracy of the fee calculation, however, RMG performs quarterly back-end audits of (RMG) fees calculated and deducted from your accounts. The custodian bills your accounts on the agreed upon advisory service fees. 

Each quarter, SEI sends you an account statement that includes details of the fees charged to your account. You may terminate the SEI Program Account at any time by notifying RMG. Termination will be effective upon 30 days written notice to the other party. If services are terminated within five business days of executing the client agreement, services will be terminated without penalty. After the initial five business days, you will be responsible for payment of fees for the number of days services were provided by RMG and SEI prior to receipt of the notice of termination.  

Fees for financial advisory services may be negotiated based on householding of accounts, the complexity of the client's situation, the plan for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client’s household. The financial planning fee may be waived by RMG at their discretion for clients with a minimum of $5 million in assets under management with RMG. 

In addition to the ongoing planning advice we provide as a part of our service model, we sometimes provide specialized consulting services under the umbrella of special projects. These may include but are not limited to assistance with life transition, be it illness planning, divorce or advanced estate planning. These services are priced based on an estimate of time and effort to be expended and costs may be renegotiated if the time required grossly exceeds that which is typical or expected. Expenses related to such engagements may include certain incidental expenses, (e.g., transportation, lodging, etc.) that are necessary and appropriate, as agreed upon. Upon termination of any hourly fee contract, any unearned fees will be promptly returned to the client and any unpaid, earned fees will be due and payable to RMG. 

Variable sub-account management fees are charged based on the Variable Sub-Account Guidance Fees below. Variable accounts may be subject to exchange fees and surrender charges.  RMG does not share in these fees charged by your insurance company.  You should refer to the prospectus of their variable annuity and/or variable life contract for more details about the insurance company’s management expenses and any exchange or surrender fees. RMG does not sell variable annuities but can assist in their management as a part of our services.  

Your investment adviser representative has the capacity to serve you as a personal lines insurance agent. When acting in that separate capacity, the investment adviser representative can sell a variety of insurance products. As such, your investment adviser representative in his or her separate capacity as an insurance agent, may suggest that you implement recommendations of RMG by purchasing these insurance products. This receipt of commissions for these sales may create an incentive for the representative to recommend those products. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. These may be implemented elsewhere or not at all. RMG is a fiduciary RIA and puts your interests first.  As such, it is our responsibility to make you aware of this potential conflict. 

You or RMG may terminate this service for any reason by providing the other party with written notice, which will be effective within 30 days after receipt of termination notice. Financial planning and asset management services will continue until either party terminates the Agreement with 30-day written notice.  

Fee Schedules 

Financial Planning Fees:  

Assets under Management (AUM) and Variable Sub-Account Guidance Fees (blended, billed quarterly) : 

Divorce and Mediation Fees  

Item 6. Performance-Based Fees and Side-By-Side Management 

RMG does not charge performance-based fees, which are based on capital gains in your account. 

Item 7. Types of Clients  

Types of clients include, but are not limited to, individuals, families, trusts, estates, charitable organizations and business entities. 

Minimum Investment Amounts Required 

Hourly charges are often billed in advance with a minimum 10-hour retainer for divorce-related planning or consulting work. RMG generally has a $1 million investment minimum. RMG may, in its sole discretion, make an exception to this minimum. 

Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss 

By its nature, financial planning looks to the long-term. After your short-term cash needs and emergency fund are evaluated, investments, insurance and other strategies are designed to help you achieve your financial goals. Property and casualty insurance (e.g. homeowners’, auto, liability, etc.) is reviewed and such review may be provided by an outside casualty firm. Other outside professionals may be called upon for their expertise as well.  

While there is risk in all investments, some carry a greater degree of risk or higher costs. There is no guarantee that the investment strategy selected for you will result in your goals being met, nor is there any guarantee of profit or protection from loss. For those investments sold by prospectus, you should read the prospectus in full. Investing in securities involves risk of loss that you should be prepared to bear.  

Qualitative analysis including charting, fundamental, technical as well as cyclical analysis methods may be considered in establishing positions in securities and in monitoring their progress. RMG carefully considers individual investments, their relative quality, financial soundness, value and attractiveness as well as sector analysis in the selection of securities or funds. We are not “market timers”. We attempt to mitigate risk via the methods above, diversification, alternative investments and/or hedging strategies.  

Investments may include (but are not limited to) exchange-listed securities as well as securities traded over-the-counter, corporate debt securities (other than commercial paper), CD’s, municipal securities, investment company securities (including variable life insurance, variable annuities, mutual fund shares), and various other alternative investments.   

The fixed income process uses quantitative techniques to control risk including, but not limited to, duration management and break-even analysis (along with historical and fundamental data) in identifying the appropriate quality and sector spreads. In addition, return analysis is performed using various interest rate scenarios and time horizon studies along with other relevant considerations. Intermixed here are variable insurance products with various guarantees of return and/or income in hedged portfolios in order to mitigate risk. You understand that debt securities are subject to interest rate risk, time risk and, potentially, investment risk.  

Business Disruption 

Events that may cause business interruptions in markets may cause disruption to RMG, such as COVID-19, and may be impactful on RMG and its ability to serve you. In order to mitigate the risk of potential disruptions to business, RMG has revised and implemented its business continuity plan, pursuant to which personnel will work offsite. Our technology program is designed to make information available to offsite employees in a way that allows them to do so, safely and securely. RMG will continue to take all necessary actions to make available and consistently improve upon this program as technological advances allow. This includes monitoring all foreseeable potential issues in order to provide optimal business flow in conjunction with the highest regard for health and safety of its employees, clients, service providers and principals.  

Item 9. Disciplinary Information 

An investment advisor must disclose material facts about any legal or disciplinary event that is material to your evaluation of the advisory business or of the integrity of its management personnel. RMG has not had any disclosure items.  

Item 10. Other Financial Industry Activities and Affiliations 

RMG offers advice, which is not always directly investment related (tax, education, retirement, divorce, elder care, estate planning, etc.). RMG offers investment products to allow you not only to plan but also to implement your plan. Time is divided between planning and investment-related work.  

Insurance Agent 

Jamie Lapin is licensed in life and health insurance. When acting in that separate capacity as an insurance agent, she may sell a variety of insurance products to you and as such, may suggest that you implement recommendations of RMG by purchasing these insurance products. This may create an incentive for her to recommend those products for which she will receive a commission in her separate capacity as an insurance agent. Consequently, the advice rendered to you has the potential to be biased. You are under no obligation to implement any insurance or annuity transaction. RMG’s investment adviser representatives act as fiduciaries and as such, must put your interests first. Regardless, it is our responsibility to make you aware of this potential conflict.  

Item 11. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading 

Code of Ethics 

Ms. Lapin has been a CFP® professional for 40 years (1982 – present) and maintains strict adherence to the CFP Board's Code of Ethics noted below.  As a client, you will be made aware at the outset of activities that will generate commission or fee payment. You always maintain discretion over your accounts and therefore maintain final decision over any transaction.  You maintain the option of implementing your financial plan through RMG or elsewhere.  

A CFP® professional must: 

1. Act with honesty, integrity, competence, and diligence.
2. Act in the client’s best interests.
3. Exercise due care.
4. Avoid or disclose and manage conflicts of interest.
5. Maintain the confidentiality and protect the privacy of client information.
6. Act in a manner that reflects positively on the financial planning profession and CFP® certification. 

An investment adviser representative is considered a fiduciary and has a fiduciary duty to you. RMG has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflect its fiduciary obligations and those of its supervised persons. The RMG Code of Ethics also requires compliance with federal securities laws. It covers all individuals that are classified as “supervised persons”. All employees and investment advisor representatives are classified as supervised persons. RMG requires its supervised persons to consistently act in your best interest in all advisory activities. RMG imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business.    

This section is intended to provide a summary description of the RMG Code of Ethics. RMG will promptly provide the RMG Code of Ethics in its entirety upon receipt of your written request. 

Personal Trading 

RMG or supervised persons of the firm may buy and sell for their personal accounts investment products identical to those recommended to you, which creates a conflict of interest. It is the express policy of RMG that all persons associated in any manner with our firm must place your interests ahead of their own when implementing personal investments. As is required by our internal procedures manual, RMG and its supervised persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with our firm unless the information is also available to the investing public upon reasonable inquiry.   

We are now and will continue to be in compliance with applicable state and federal rules and regulations. To mitigate conflicts of interest that can occur when access persons manage their personal accounts at the same time RMG manages client accounts, we have developed written supervisory procedures that include personal investment and trading policies for our representatives, employees and their immediate family members (collectively, supervised persons):  

• Supervised persons cannot prefer their own interests to that of the client. 
• Supervised persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. 
• Supervised persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. 
• Supervised persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. 
• Supervised persons are discouraged from conducting frequent personal trading. 
• Supervised persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted by the Chief Compliance Officer of RMG.  

Any Supervised person not observing our policies is subject to sanctions up to and including termination. 

Item 12. Brokerage Practices 

We exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back-office services, technology and pricing of services offered. 

Clients are under no obligation to act on the financial planning recommendations of RMG.  If the firm assists in the implementation of any recommendations, we are responsible to ensure that the client receives the best execution possible.  Best execution does not necessarily mean that clients receive the lowest possible costs but that the qualitative execution is within the “best” definition.  In other words, all conditions considered, the transaction execution is in your best interest.  When considering best execution, we look at a number of factors of our execution partner besides prices and fees including, but not limited to: 

• Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with our existing systems, ease of monitoring investments) 
• Products and services offered (e.g., investment programs, back-office services, technology, regulatory compliance assistance, research and analytic services) 
• Financial strength, stability and responsibility 
• Reputation and integrity 
• Ability to maintain confidentiality 

Selection or Recommendation of Broker/Dealers 

When you sign an investment advisory agreement with RMG, you are required to establish a brokerage account with SEI Private Trust Company (SPTC). SEI is independent and not affiliated with RMG.   

SPTC provides RMG with access to their institutional trading and custody services.  The services from SPTC include brokerage, custody, research and access to mutual funds and other investments. SPTC is the custodian that supports the SEI Asset Management program.  A complete description of SEI’s advisory services, fee schedules and account minimums will be disclosed in their Firm Brochure which will be provided to you by RMG prior to or at the time an agreement for services is executed and the account is established.   

Clients should understand that not all investment advisors require the use of a particular broker/dealer or custodian.  Some investment advisors allow their clients to select whichever broker/dealer the client decides.  By requiring clients to use a particular broker/dealer, RMG may not achieve the most favorable execution of client transactions and the practice requiring the use of specific broker/dealers may cost clients more money than if the client used a different broker/dealer or custodian.  However, for compliance and operational efficiencies, RMG has decided to require our clients to use broker/dealers and other qualified custodians determined by RMG. 

Block Trading 

We accept such arrangements as long as they are advantageous to you. At certain account levels, advisory clients are offered advice as a benefit of our relationship and are charged fees based on Assets under Management and/or other agreed to services. Account aggregation is not relevant to our business model, though if it were relevant, appropriate and advantageous to you we would strive to do so.  

Soft Dollar Practices 

From time to time, RMG may receive “soft dollar” support in the form of research, client educational opportunities, industry conferences, services or branded promotional items. When soft dollars are obtained by production, we benefit from the education provided, as well as by not having to produce or pay for such items. This may create an incentive to select or recommend a product or service based on soft dollars received, rather than best execution for you. Ms. Lapin understands the fiduciary responsibility as a CFP® professional to put your welfare first in all investment decision-making as stipulated in the CFP® Code of Ethics. Soft dollar benefits do not directly accrue to any client or account. Rather they allow our firm to more economically service our clientele overall.  

Item 13. Review of Accounts and Reports on Accounts 

RMG reviews all accounts at least quarterly. Additional reviews are also triggered by changes in economic conditions, taxation or your personal or familial circumstances. In financial plans related to divorce or other specific events, the relationship is finite. RMG and you may subsequently choose to continue our working relationship with comprehensive financial planning and/or investment services.  

Due to the modularity of our services, reports vary.  

• In addition to statements issued by custodians and investment sponsors, RMG, as part of our comprehensive and consistent portfolio review, assesses your portfolio regularly. These assessments may yield a summary in the form of a personalized video emailed to you.  
• You may view account information any time through custodial logins and RMGConnect (accounts linked in eMoney). 

Reviews 

Reviews determine whether/when assets remain on track to satisfy your objectives and risk tolerance, taking taxes and other mitigating factors into consideration. RMG requests that you provide updated personal information so that this may be considered as well. All financial clients are expected to attend at least one annual portfolio review session. A financial plan is a snapshot in time. Reviews are part of an ongoing service for those clients who choose to engage RMG for goals-based planning services. 

Item 14. Client Referrals & Other Compensation 

RMG has no arrangement, oral or in writing, for which we are paid cash or receive any economic benefit from a non-client in connection with giving advice to clients nor do we directly or indirectly compensate any person for client referrals.  

Item 15. Custody 

Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. According to this definition, RMG does not have custody of client funds or securities.  

RMG is deemed to have custody of client funds and securities whenever RMG is given the authority to have advisory fees deducted directly from client accounts. However, this is the only form of custody RMG will ever maintain.  It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody. 

For accounts in which RMG is deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name.  Clients, or an independent representative of the client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained.  Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative.   

When fees are deducted from an account, SEI is responsible for calculating the fee and delivering instructions to the custodian. SEI instructs the custodian to deduct fees from your account and the fee itemization is included on the client’s statement from SEI.  Itemization will include the formula used to calculate the fee, the amount of assets under management the fee is based on, and the time period covered by the fee. 

RMG has the ability to instruct SEI’s custodian, SPTC, on certain transfers or withdrawals from your account(s) at SPTC. Specifically, RMG may instruct SPTC to distribute assets via check to your name and address of record on file with SPTC. With your written permission on file with SPTC, RMG may transfer assets to a bank account or account held at another custodian provided the account is in your name. All third-party distributions from SPTC must be signed by client. RMG does not have authority to instruct SPTC to distribute assets from client’s account at SPTC to a third-party. 

You will receive account statements at least quarterly from SEI or other qualified custodian. You are urged to compare custodial account statements against statements prepared by RMG for accuracy. Minor variations may occur because of reporting dates, accrual methods of interest and dividends, and other factors. The custodial statement is the official record of your account for tax purposes.  

Item 16. Investment Discretion 

Clients will grant RMG discretionary authority to establish and/or terminate a relationship with SEI for purposes of managing the account or a portion of the account determined by RMG. Client will also grant SEI with the discretionary authority (in the sole discretion of SEI without first consulting with Client) to make all decisions to buy, sell or hold securities, cash or other investments for such portion of the Account managed by SEI.   

Item 17. Voting Client Securities 

RMG does not vote proxies. It is your responsibility to vote proxies. You will receive proxy materials directly from the custodian. Questions about proxies may be made via the contact information on the proxy cover page. 

Item 18. Financial Information  

Registered investment advisors are required in this item to provide you with certain financial information or disclosures about their financial condition. Risk Management Group, LLC d/b/a RMG Advisors, has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to its clients and has not been the subject of a bankruptcy proceeding.  

Item 19. Requirements for State Registered Advisors 

Pertinent information regarding Jamie S. Lapin is as follows: 

Executive Officer and Management Personnel 

Jamie Lapin 

Educational Background: 

BA – University of Maryland – 1977 

CERTIFIED FINANCIAL PLANNER™️ – College of Financial Planning – 1982 

Certified Divorce Financial Analyst® – Institute for Divorce Financial Analysts – 1998 

Advanced Mediation Certificant – Harvard University – 2006 

Accredited Investment Fiduciary® – Fi360, Inc. – 2017 

Mediator – Mediation Matters – 2003 

Ms. Lapin takes continuing education classes in all areas of financial planning, investments, insurance and divorce, more than is sufficient to maintain current status as a CFP®, CDFA® and AIF® professional. She also takes industry-specific classes as well as meeting state standards for insurance and registered investment advisor. 

Ms. Lapin is associated with the following organizations: 

• Member, Financial Planning Association  
• Member, Financial Services Institute  
• Member, International Association of Collaborative Professionals 
• Member, Women Who Care 

Business Experience: 

Risk Management Group, LLC d/b/a RMG Advisors: Managing Member, CCO and Investment Adviser Representative, 1/85 – Present 

Insurance Agent, 1/86 - Present 

Grove Point Investments, LLC: Registered Representative, 9/03 – 1/23 

Family Law Software, Representative, 4/18 – 2/22 

Other Business Activities 

See Item 10 – Other Financial Industry Activities and Affiliations. 

No Performance-Based Fees 

As previously disclosed in Item 6, RMG does not charge or accept performance-based fees.  

No Arbitrations  

RMG or any of its associated persons have not been the subject of any client arbitrations or similar legal disputes. 

No Arrangement with Issuer of Securities 

RMG and its management do not have any relationship or arrangement with any issuer of securities. 

Date: March 29, 2023 

Risk Management Group LLC d/b/a RMG Advisors 

14 South Adams Street 

Rockville, MD 20850 

(301) 838-4111 

(301) 838-4211 (f) 

welcome@rmgadvisors.com 

Websites 

www.rmgadvisors.com 

www.thefedcorner.com 

This Brochure Supplement provides information about Jamie S. Lapin, CFP®, CDFA®, AIF® that supplements the Risk Management Group, LLC d/b/a RMG Advisors Form ADV Part 2 Brochure. Please contact Ms. Lapin using one of the methods above if you did not receive a Form ADV Part 2 Brochure or if you have any questions about the contents of this supplement. 

Additional information about Jamie Lapin is available on the SEC’s website at www.adviserinfo.sec.gov  (Investment Advisor Individual – CRD #855217).  

2. Educational Background and Business Experience

Education and Business Background 

Name: Jamie S. Lapin, CFP®, CDFA®, AIF® 

Year of Birth: 1955 

Education: University of Maryland, College Park, Maryland, Graduated BA in 1977 

Business: Risk Management Group, LLC d/b/a RMG Advisors: Managing Member, CCO and Investment Adviser Representative, 1/85  – present  

                   Insurance Agent, 1/86 - present  

                   Grove Point Investments, LLC: Registered Representative, 9/03 – 1/23 

                   Family Law Software, Representative, 4/18 – 2/22 

Professional Designations Qualifications 

Certified Financial Planner ^TM 

The Certified Financial Planner ^TM  certification is issued by the Certified Financial Planner Board of Standards, Inc. (CFP Board). CFP® certificants are individuals who have met the CFP Board's education, examination and experience requirements, have agreed to adhere to high ethical standards and complete continuing education requirements. Although many other respected financial certifications exist, a Certified Financial Plannertm is considered by many to be the best example of a professional qualified to give comprehensive financial advice to individuals and families. 

Candidates must meet the following requirements: 

• Complete the CFP Board educational program 
• Bachelor’s degree (or higher) from an accredited college or university 
• Pass CFP® certification Exam 
• 3 years of full time personal financial planning experience 
• Continuing education requirement of 30 hours every 2 years 

Certified Divorce Financial Analyst®   

The CDFA® designation is issued by the Institute of Divorce Financial Analysts.  Course work outlines several key areas important in divorce proceedings including the treatment of property during divorce, alimony, child support, and tax implications of property division.  The entire program generally takes six months to one year to complete. 

Candidates must meet the following requirements: 

• Complete each of four CDFA® modules 
• Pass certification exam on each module 
• Three years’ experience in the financial or legal field 
• 15 hours of divorce-related Continuing Education every two years 

Accredited Investment Fiduciary® 

Accredited Investment Fiduciary® (AIF®) Designees have been specially certified for their process of having their clients’ best interests at heart.  Accredited Investment Fiduciary (AIF®) designees have the ability to implement a prudent process into their own investment practices as well as being able to assist others in implementing proper policies and procedures. 

AIF® designees must accrue a minimum of six hours of continuing education annually.  The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. 

Qualifications: 

There are five requirements for attaining the AIF® designation:   

1. Enroll in and complete the AIF® Training 
2. Pass the AIF® Examination 
3. Meet the experience requirements 
4. Submit the application and attest to conduct standards and code of ethics
5. Pay dues 

Ms. Lapin is associated with the following organizations: 

• Member, Financial Planning Association  
• Member, Financial Services Institute  
• Member, International Association of Collaborative Professionals  
• Member, Women Who Care 
  

3. Disciplinary Information 

An investment advisor must disclose material facts about any legal or disciplinary event that is material to a client’s evaluation of the advisory business or of the integrity of its management personnel. Jamie S. Lapin does not have any disclosure items. 

4. Other Business Activities

Insurance Agent  

Ms. Lapin is licensed with several personal lines insurance companies. If clients purchase these products through Ms. Lapin, she will receive normal commissions.  Thus, a conflict exists between her interests and those of her advisory clients, and an incentive to recommend investment products based on the compensation received rather than on the clients’ needs. The CFP® Code of Ethics precludes Ms. Lapin from putting her interests before those of her clients (see Section 11 of the ADV Brochure).  The client is under no obligation to purchase products recommended, or to purchase products either through us or through these insurance companies. Ms. Lapin spends approximately 7 hours per month on this activity, 4 hours during normal trading hours. 

5. Additional Compensation 

From time to time, Ms. Lapin may recommend the services of other professionals to assist our clients in real estate transactions, estate planning, etc. Compensation is neither paid to nor received from these individuals. The client is under no obligation to utilize any professionals recommended by Ms. Lapin. 

6. Supervision

Ms. Lapin is the President and Chief Compliance Officer of Risk Management Group, LLC d/b/a RMG Advisors and is responsible for overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives. Ms. Lapin can be contacted at (301) 838-4111. 

 7. Requirements for State Registered Advisers 

Ms. Lapin has not been involved in an arbitration award and has not been found liable in an arbitration claim alleging damages in excess of $2,500.  She has not been involved in any award or found liable in any civil, self-regulatory organization, or administrative proceeding.  Additionally, she has not been the subject of a bankruptcy petition. 

Date: March 29, 2023

Risk Management Group LLC d/b/a RMG Advisors 

14 South Adams Street 

Rockville, MD 20850 

(301) 838-4111 

(301) 838-4211 (f) 

welcome@rmgadvisors.com 

Websites 

www.rmgadvisors.com

www.thefedcorner.com

This Brochure Supplement provides information about Thiago Glieger, AIF®, ChFEBC℠ that supplements the Risk Management Group, LLC d/b/a RMG Advisors Form ADV Part 2 Brochure. Please contact Jamie Lapin using one of the methods above if you did not receive a Form ADV Part 2 Brochure or if you have any questions about the contents of this supplement. 

Additional information about Mr. Glieger is available on the SEC’s website at www.adviserinfo.sec.gov  (Investment Advisor Individual – CRD #6326737). 

 2. Educational Background and Business Experience

Education and Business Background 

Name: Thiago Glieger, AIF®, ChFEBC℠ 

Year of Birth: 1990 

Education: University of Maryland, Graduated BS in 2012 

Montgomery College, Dates Attended 9/2008 to 4/2010 

Business: Risk Management Group, LLC d/b/a RMG Advisors: Private Wealth Advisor, 5/20 – present 

                   Risk Management Group, LLC, Operations Director, 10/17 – 5/20 

                   Grove Point Investments, LLC, Registered Representative, 10/17 – 1/23 

Beck, Inc., Registered Representative, 1/17 – 9/17

Beck, Inc., Investment Adviser Representative, 1/20 – 6/20

Beck, Inc., Asset Specialist, 04/14 – 1/17

                  HMS Host, Replenishment Analyst, 8/13 – 4/14 

                  PNC Bank, Financial Consultant, 2/13 – 7/13 

                  Unemployed, 12/12 – 1/13 

                  Target Corp., Investigative Specialist, 2/09 – 11/12 

Professional Designations Qualifications 

Accredited Investment Fiduciary® 

Accredited Investment Fiduciary® (AIF®) Designees have been specially certified for their process of having their clients’ best interests at heart.  Accredited Investment Fiduciary (AIF®) designees have the ability to implement a prudent process into their own investment practices as well as being able to assist others in implementing proper policies and procedures. 

AIF® designees must accrue a minimum of six hours of continuing education annually.  The CE requirement is effective immediately upon attainment of the AIF® designation, and CE hours may be accrued from a variety of sources. All CE is subject to audit by, and final approval from, Fi360. 

Qualifications: 

There are five requirements for attaining the AIF® designation:   

1. Enroll in and complete the AIF® Training 
2. Pass the AIF® Examination 
3. Meet the experience requirements 
4. Submit the application and attest to conduct standards and code of ethics
5. Pay dues   

Chartered Federal Employee Benefits Consultant℠  

ChFEBC℠ professionals are Financial Advisors, CPAs, Attorneys, and certain employees of the Federal Government, who have successfully completed a training course and passed an examination covering all federal employee benefits. 

ChFEBC℠ designees must accrue a minimum of ten hours of continuing education every two years. 

Qualifications: 

1. Three (3) years of financial services experience 

2. Hold one of the following:

• Series 6 
• Series 7 
• Series 24 
• Series 66 
• Registered Investment Advisor 
• Investment Advisor Representative 

3. Hold one of the following designations: 

• Chartered Financial Consultant (ChFC) 
• Chartered Life Underwriter (CLU) 
• Chartered Financial Analyst (CFA) 
• Certified Financial Planner (CFP)
• Master’s degree in business, Finance or Economics 
• Attorney’s License (JD)
• Certified Public Accountant (CPA) 

3. Disciplinary Information 

An investment advisor must disclose material facts about any legal or disciplinary event that is material to a client’s evaluation of the advisory business or of the integrity of its management personnel. Thiago Glieger does not have any disclosure items. 

4. Other Business Activities

Mr. Glieger is an author of FedSmith.com since June 2020. This is an investment related activity. Mr. Glieger is a contributing author to an online resource for federal employees. FedSmith.com is not affiliated with the U.S. government. Mr. Glieger spends approximately 4 hours per month on this activity, none during trading hours.  

5. Additional Compensation 

From time to time, Mr. Glieger may recommend the services of other professionals to assist our clients in real estate transactions, estate planning, etc. Compensation is neither paid to nor received from these individuals. The client is under no obligation to utilize any professionals recommended by Mr. Glieger. 

6. Supervision

Ms. Jamie Lapin is the President and Chief Compliance Officer of Risk Management Group, LLC d/b/a RMG Advisors and is responsible for overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives including Thiago Glieger.  Ms. Lapin can be contacted at (301) 838-4111. 

 7. Requirements for State Registered Advisers 

Mr. Glieger has not been involved in an arbitration award and has not been found liable in an arbitration claim alleging damages in excess of $2,500.  He has not been involved in any award or found liable in any civil, self-regulatory organization, or administrative proceeding.  Additionally, he has not been the subject of a bankruptcy petition. 

Commitment to Your Private Information. Risk Management Group, LLC d/b/a RMG Advisors has a policy of protecting the confidentiality and security of information we collect about you. We do not, and will not, share non-public personal information (“Information”) about you with outside third parties without your consent, except for the specific purposes described below. This notice has been provided to you to describe the Information we may gather and the situations under which we may need to share it.   

Why We Collect and How We Use Information. We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you. Such services include maintaining your accounts, processing transaction requests, and providing the advisory services described in our Form ADV. 

How We Gather Information. We get most Information directly from you when you provide us with information from any of the following sources: 

• Applications or forms (for example: name, address, social security number, birth date, assets, income, financial history, etc.) 
• Transactional activity in your account (for example: trading history and account balances) 
• Other sources with your consent (for example: your attorney, or accountant or other professional) 

How We Protect Information. We are required to protect the confidentiality of Information and to comply with our stated policies. We may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services. Any employee who violates our Privacy Policy is subject to disciplinary action, up to and including termination from employment with us. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with applicable SEC, state, and federal laws. We chose our managed services providers (MSPs) based on their leadership and experience in cybersecurity. 

Sharing Information with Other Companies Permitted Under Law. We do not disclose information obtained in our practice except as required or permitted under law or requested by you. Permitted disclosures include, for instance, providing Information to unrelated third parties who need to know such information to assist us with the provision of services to you. Unrelated third parties may include broker-dealers, mutual fund companies, insurance companies, and the custodian with which your assets are held. In such situations, we stress the confidential nature of information being shared.   

Former Clients.  In case our relationship with you is terminated, our Privacy Policy will continue to apply to you, and we will continue to treat your non-public information with strict confidentiality.