RobustWealth, Inc. Form ADV Part 2A Firm Brochure

1 Item 1 - Cover Page robustwealth , Inc. form ADV part 2A Firm Brochure 204 N. Union Street Lambertville, NJ 08530 March 30, 2020 This Brochure ( Brochure ) provides information about the qualifications and business practices of robustwealth , Inc. ( robustwealth or the Firm ), a registered investment adviser (CRD# 269919). The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Registration does not imply a certain level of skill or training. If you have any questions about the contents of this Brochure , please contact us at or Additional information about robustwealth , Inc.

2 Also is available on the United States Securities and Exchange Commission ( SEC ) s website at 2 Item 2 - Material Changes robustwealth s last annual update to part 2A of form ADV was filed March 28, 2019. Item 4 B. robustwealth no longer provides discretionary investment management services directly to individuals and high net worth individuals as their primary investment advisor. robustwealth continues to focus on its subadvisory business and provides discretionary investment management services to clients of third party SEC-registered investment advisers, financial institutions and dual registered broker-dealers ( Third Party Advisors or TPA ) pursuant to robustwealth s sub-advisory program (the TPA Program ).

3 Additional information about robustwealth s affiliated investment advisors is also available via the SEC s website 3 Item 3 - Table of Contents Item 1 Cover Item 2 Material Item 3 Table of Item 4 Advisory Item 5 Fees and Item 6 Performance-Based Fees and Side-By-Side Item 7 Types of Item 8 Methods of Analysis, Investment Strategies and Risk of Item 9 Disciplinary Item 10 Other Financial Industry Activities and Item 11 Code of Item 12 Brokerage Item 13 Review of Item 14 Client Referrals and Other Item 15 Item 16 Investment Item 17 Voting Client Item 18 Financial 4 Item 4 - Business A.

4 Ownership of the Firm robustwealth was formed as a limited liability company in the State of Delaware on May 8, 2015 and has been registered as an investment advisory firm with the SEC since May 18, 2017. Effective December 13, 2016 robustwealth changed from a limited liability company to a Delaware corporation. Michael Kerins is robustwealth s Founder and Chief Executive Officer. On July 2, 2018 robustwealth was acquired by Principal Innovations, Inc. ( PII ), a holding company that is majority owned by Principal Financial Services, Inc. ( PFSI ). PFSI is a wholly owned subsidiary of Principal Financial Group, Inc.

5 , a publicly traded company (NASDAQ Symbol: PFG). Both robustwealth and PFSI are under common control of PFG. B. Summary of robustwealth s Services robustwealth is an investment advisory firm that provides limited investment advice and portfolio management services on a continuing basis through digital technology solutions with the assistance of proprietary algorithms to clients, who are third party SEC-registered investment advisers, financial institutions and dual registered broker-dealers ( Third Party Advisors ) pursuant to robustwealth s sub-advisory program (the TPA Program ), described in the following section.

6 robustwealth s services are provided via robustwealth s proprietary platform located at (the Platform ). Additional information about robustwealth s products and services is provided on robustwealth encourages you to read its form ADV part 1 available at for additional information. Third Party Advisor Subadvisory Program robustwealth acts as a limited sub-advisor to Third Party Advisors participating in its TPA Program. Such Third Party Advisors, in turn, act as investment advisers to individual (natural person) investors and entities (the TPA End Users ) investing through such Third Party Advisors in the TPA Program.

7 Pursuant to the TPA Program, a Third Party Advisor delegates discretionary trading authority to the Firm with respect to a TPA End User s account in the TPA Program (the Program Account ). Program Accounts elect to participate on either a wrap fee basis or non-wrap fee basis. Third Party Advisors direct the Firm to deduct the Firm s fees and/or their fees directly from Program Accounts or Third Party Advisors pay robustwealth s fees directly to the Firm. The investment process as outlined in Item 8 is applicable to the TPA Program. Pursuant to the TPA Program, the Third Party Advisor contracts with robustwealth as a limited subadvisor to handle some or all of the following: 1) Trading: Buying, selling, exchanging, converting, and effecting spread, hold, and transactions for and with respect to securities.

8 5 2) Strategic Asset Allocation: Using long-term return and risk expectations in an optimization to determine the long-term asset allocation consistent with the TPA End User s stated investment objective(s). 3) Portfolio Construction: The process of investing across a range of assets that work together based on individual risk and return characteristics of the assets. 4) Implementation: Using securities such as stocks, ETFs, and mutual funds to gain exposure to desired asset classes or factors, which can include margin (leverage). 5) Strategy Selection: Selecting one or more investment strategies comprising the rules, behaviors and procedures, designed to guide the construction of a portfolio.

9 6) Risk Tolerance: Assessing and balancing of a TPA End User s portfolio based on individual needs such as growth and tolerance for risk. 7) Intelligent Rebalancing: Considering potential tax consequences, trading costs and rebalancing costs when rebalancing a portfolio. To commence participation in the TPA Program, an investment advisor representative of the Third Party Advisor identifies each TPA End User s investment objective based on the TPA End User s self-identified information. This is typically accomplished when the TPA End User completes an automated risk tolerance questionnaire. Thereafter, investment assets are allocated to investment model(s) created or selected by the Third Party Advisor consistent with the TPA End User s designated investment objective(s).

10 Once allocated, robustwealth provides ongoing monitoring, trading and review of the asset allocation as compared to the TPA End User s investment objective(s) and the investment model created or selected for the TPA End User by the Third Party Advisor. Third Party Advisors may select from a variety of investment models available in the TPA Program, including (a) models created and maintained by the Third Party Advisor, (b) models created and maintained by robustwealth or an affiliate of robustwealth , and (c) third party model portfolios created by other financial intermediaries. It is important for Third Party Advisors and TPA End Users to be aware that the Firm s or a third party s model portfolio can include funds sponsored by the model creator or an affiliate thereof resulting in a potential conflict of interest.