Part 2A of Form ADV: Firm Brochure Item 1 Cover Page ROCHDALE ...
Part 2A of Form ADV: Firm Brochure Item 1 Cover Page ROCHDALE ...
Part 2A of Form ADV: Firm Brochure Item 1 Cover Page ROCHDALE ...
You also want an ePaper? Increase the reach of your titles
YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.
<strong>Part</strong> <strong>2A</strong> <strong>of</strong> <strong>Form</strong> <strong>ADV</strong>: <strong>Firm</strong> <strong>Brochure</strong><br />
<strong>Item</strong> 1<br />
<strong>Cover</strong> <strong>Page</strong><br />
<strong>ROCHDALE</strong> INVESTMENT MANAGEMENT, LLC<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
Telephone: (212) 702-3500<br />
Facsimile: (212) 702-3535<br />
Internet: www.rochdale.com<br />
March 31, 2012<br />
This <strong>Brochure</strong> provides information about the qualifications and business practices <strong>of</strong> Rochdale<br />
Investment Management, LLC (“Adviser” or “Rochdale”). If you have any questions about the contents<br />
<strong>of</strong> this <strong>Brochure</strong>, please contact us at by telephone at (212) 702-3500 or by email at bam@rochdale.com.<br />
The information in this <strong>Brochure</strong> has not been approved or verified by the United States Securities and<br />
Exchange Commission (the “SEC”) or by any state securities authority.<br />
Additional information about Rochdale is also available on the SEC’s website at<br />
www.adviserinfo.sec.gov.<br />
Rochdale is a registered investment adviser with the SEC. Registration <strong>of</strong> an investment adviser with the<br />
SEC or with any state securities authority does not imply any level <strong>of</strong> skill or training.<br />
- i -<br />
US_ACTIVE-105561780.1
<strong>Item</strong> 2<br />
Material Changes<br />
MATERIAL CHANGES<br />
Rochdale continues to conduct its business activities and to provide investment advisory services in<br />
substantially the same manner as described in the <strong>Firm</strong>’s last update, which was made on March 28, 2012.<br />
This <strong>Brochure</strong>, however, has been prepared in accordance with rules adopted by the Securities and<br />
Exchange Commission. Accordingly, the content and presentation <strong>of</strong> our <strong>Brochure</strong> is not materially<br />
different from the brochure used by Rochdale last year.<br />
- ii -<br />
US_ACTIVE-105561780.1
<strong>Item</strong> 3<br />
Table <strong>of</strong> Contents<br />
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong> ..............................................................................................................................i<br />
<strong>Item</strong> 2 Material Changes ..................................................................................................................ii<br />
<strong>Item</strong> 3 Table <strong>of</strong> Contents .................................................................................................................iii<br />
<strong>Item</strong> 4 Advisory Business..................................................................................................................1<br />
A. General Description <strong>of</strong> Advisory <strong>Firm</strong> ....................................................................... 1<br />
B. Description <strong>of</strong> Advisory Services ............................................................................... 1<br />
C. Client Assets Under Management............................................................................... 3<br />
<strong>Item</strong> 5 Fees and Compensation ........................................................................................................4<br />
A. Advisory Fees and Compensation............................................................................... 4<br />
B. Payment <strong>of</strong> Fees.......................................................................................................... 5<br />
C. Prepayment <strong>of</strong> Fees..................................................................................................... 5<br />
<strong>Item</strong> 6 Performance-Based Fees and Side-By-Side Management.................................................6<br />
<strong>Item</strong> 7 Types <strong>of</strong> Clients .....................................................................................................................7<br />
<strong>Item</strong> 8 Methods <strong>of</strong> Analysis, Investment Strategies and Risk <strong>of</strong> Loss ..........................................8<br />
A. Methods <strong>of</strong> Analysis and Investment Strategies......................................................... 8<br />
B. Material Risks (Including Significant, or Unusual Risks) Relating to Investment<br />
Strategies..................................................................................................................... 8<br />
C. Risks Associated with Types <strong>of</strong> Securities that are Primarily Recommended ........... 9<br />
<strong>Item</strong> 9 Disciplinary Information ....................................................................................................11<br />
<strong>Item</strong> 10 Other Financial Industry Activities and Affiliations .......................................................12<br />
<strong>Item</strong> 11 Code <strong>of</strong> Ethics, <strong>Part</strong>icipation or Interest in Client Transactions and<br />
Personal Trading.................................................................................................................13<br />
A. Code <strong>of</strong> Ethics........................................................................................................... 13<br />
B. Client Transactions in Securities where Adviser has a Material Financial Interest.. 13<br />
C. Investing in Securities Recommended to Clients ..................................................... 14<br />
D. Conflicts <strong>of</strong> Interest Created by Contemporaneous Trading .................................... 14<br />
<strong>Item</strong> 12 Brokerage Practices ............................................................................................................15<br />
A. Factors Considered in Selecting or Recommending Broker-Dealers for Client<br />
Transactions .............................................................................................................. 15<br />
1. Research and Other S<strong>of</strong>t Dollar Benefits.................................................................. 15<br />
2. Brokerage for Client Referrals.................................................................................. 16<br />
3. Directed Brokerage ................................................................................................... 16<br />
B. Order Aggregation .................................................................................................... 16<br />
<strong>Item</strong> 13 Review <strong>of</strong> Accounts .............................................................................................................18<br />
A. Frequency and Nature <strong>of</strong> Review ............................................................................. 18<br />
B. Factors Prompting an Immediate Review <strong>of</strong> Accounts. ........................................... 18<br />
C. Content and Frequency <strong>of</strong> Regular Account Report................................................. 18<br />
<strong>Item</strong> 14 Client Referrals and Other Compensation........................................................................19<br />
A. Economic Benefits Received from Non-Clients for Providing Services to Clients . 19<br />
B. Compensation to Non-Supervised Persons for Client Referrals............................... 19<br />
<strong>Item</strong> 15 Custody.................................................................................................................................20<br />
<strong>Item</strong> 16 Investment Discretion .........................................................................................................21<br />
<strong>Item</strong> 17 Voting Client Securities.......................................................................................................23<br />
<strong>Item</strong> 18 Financial Information.........................................................................................................24<br />
<strong>Item</strong> 19 Requirements for State-Registered Advisers....................................................................25<br />
- iii -<br />
<strong>Page</strong><br />
US_ACTIVE-105561780.1
<strong>Item</strong> 4<br />
Advisory Business<br />
A. General Description <strong>of</strong> Advisory <strong>Firm</strong><br />
Rochdale Investment Management (the “Adviser” or “Rochdale”), a limited liability company organized<br />
under the laws <strong>of</strong> the State <strong>of</strong> Delaware, was formed on October 10, 2001. The Adviser’s principal place<br />
<strong>of</strong> business is in New York, New York.<br />
B. Description <strong>of</strong> Advisory Services<br />
Rochdale provides money management services to clients with portfolios <strong>of</strong> $1M and above, primarily on<br />
a discretionary basis. Rochdale works with each client to determine their portfolio needs and limitations<br />
and designs an asset allocation and investment objective plan to meet their goals. Thereafter, Rochdale<br />
portfolio managers implement each plan, working directly with the client and their financial advisor, on a<br />
one-on-one basis. A typical client relationship will also have a third party financial advisor to assist the<br />
client through the implementation process and work with Rochdale with on-going portfolio management<br />
<strong>of</strong> the clients assets. Rochdale intelligently personalizes and allows for customization <strong>of</strong> client portfolios.<br />
This includes working with a client’s already existing portfolio to build out an appropriate Rochdale<br />
portfolio (i.e. utilizing existing securities where appropriate), managing across multiple accounts (IRA’s,<br />
trust, personal, joint, etc.), allowing clients to place restrictions on securities (industry, sector, etc.), or<br />
types <strong>of</strong> securities (options, derivatives, etc.) or investment strategies (Large Cap, international,<br />
alternative, etc.), and managing a clients portfolio to meet a clients specific distribution needs and tax<br />
goals. To the extent the client elects to invest in pooled vehicles to implement an asset allocation<br />
program, such restrictions may not be appropriate. Except for the portion <strong>of</strong> each client’s account that is<br />
invested in pooled vehicles, each client’s account is managed separate from other clients <strong>of</strong> Rochdale<br />
(i.e., not commingled, securities are purchased in their personal accounts).<br />
Clients may chose from a variety <strong>of</strong> programs, depending on their investment objectives, financial<br />
position and level <strong>of</strong> assets to be placed with Rochdale. In working with clients to implement<br />
individualized investment programs, Rochdale may recommend the use <strong>of</strong> various investment funds<br />
managed by Rochdale or its affiliates to capture potential return from specified assets classes. These<br />
funds include the several investment portfolios <strong>of</strong> Rochdale Investment Trust, an open-end investment<br />
company registered under the Investment Company Act <strong>of</strong> 1940. As <strong>of</strong> the date <strong>of</strong> this update, these<br />
portfolios include: Rochdale Large Growth, Rochdale Large Value, Rochdale Dividend and Income,<br />
Rochdale Intermediate Fixed Income, Rochdale Emerging Markets and Rochdale Fixed Income<br />
Opportunities Portfolios (collectively "RIT Funds"). Rochdale also makes available to its clients<br />
interests in other registered investment vehicles who satisfy the suitability requirements specified in<br />
<strong>of</strong>fering documents relating to such vehicles. As <strong>of</strong> the date <strong>of</strong> this <strong>Brochure</strong>, these include Rochdale<br />
Core Alternative Strategies Master Fund, Rochdale Core Alternative Strategies Fund and Rochdale Core<br />
Alternative Strategies Fund TEI (collectively "RCAS"), Rochdale International Trade Fixed Income Fund<br />
("RITFI"), Rochdale Structured Claims Fixed Income Fund ("RSCFIF"), Rochdale Alternative Total<br />
Return Fund (“RATRF”) and Rochdale Royalty Rights Fund (“RRRF”). All <strong>of</strong> these vehicles are<br />
managed by Rochdale.<br />
Rochdale also makes available to its clients interests in other investment vehicles that are not registered<br />
under the Investment Company Act, who satisfy the suitability requirements specified in <strong>of</strong>fering<br />
documents relating to such vehicles. As <strong>of</strong> the date <strong>of</strong> this <strong>Brochure</strong>, these include Rochdale Offshore<br />
Global Opportunities Fund (“ROGOF), Rochdale Offshore Global Diversified Fund (“ROGDF”),<br />
Rochdale GML Trade Finance Income Fund, (“RGTFIF”) Rochdale Alternative Total Return Offshore<br />
Fund (RATROF), Rochdale Royalty Rights Offshore Fund (“RRROF”) and Long Point Investors. All <strong>of</strong><br />
the RIT Funds, together with RCAS, RITFI, RSCFIF, RATRF, RRRF, ROGOF, ROGDF, RGTFIF,<br />
1
RATROF and RRROF (“Alternative Funds”) are collectively referred to as the “Funds". Rochdale may<br />
organize other investment funds in the future. Rochdale receives fees for services to such vehicles.<br />
Advisory programs available through Rochdale are described below. Note that the fees and expenses<br />
associated with each program may differ (“See “Fees and Compensation” in this <strong>Brochure</strong>.)<br />
• Money Management Program. Intelligently personalized and customized portfolio<br />
implementation and management for clients that meet Rochdale’s minimum net worth<br />
requirements ($1M portfolio value and above across all accounts managed).<br />
• FCA Rochdale Customized Advisory Services. Through its division, FCA Rochdale, Rochdale<br />
provides customized investment management services and coordinated oversight <strong>of</strong> HNW client's<br />
estate, business and benefits planning. As with the Money Management Program, Clients who<br />
participants in this program generally have portfolios above $1M.<br />
• Rochdale “Wrap Fee” Programs. This Program bundles Money Management services with<br />
brokerage services for a single consolidated fee. Under this Program, which may be managed by<br />
Rochdale directly or, for clients through FCA Rochdale, Accounts are continuously managed on a<br />
fully discretionary basis and securities transactions are executed through RIM Securities, LLC<br />
(“RIM”), a broker deal registered with the Securities and Exchange Commission and affiliated<br />
with Rochdale. Clients participating in these Programs are required to direct the use <strong>of</strong> RIM as<br />
their broker-dealer. No commissions are charged for securities transactions. For a further<br />
discussion <strong>of</strong> Rochdale and/or FCA Rochdale's wrap fee program, including fees and expenses,<br />
please refer to Rochdale’s separate Wrap Fee <strong>Brochure</strong>.<br />
• Galaxy TM Asset Allocation Program (“GAAP”). Clients electing to participate in this program<br />
will have their accounts managed by way <strong>of</strong> Rochdale's proprietary Galaxy TM Asset Allocation<br />
Program ("GAAP"). These are clients that generally do not meet the dollar threshold <strong>of</strong> the<br />
programs above (with some exceptions). GAAP enables risk pr<strong>of</strong>iling, target asset class<br />
allocation, standard mutual fund implementation <strong>of</strong> target asset class allocation, customization <strong>of</strong><br />
mutual fund implementation, proposal generation, portfolio implementation based on<br />
implementation model, and portfolio management through periodic and/or event driven<br />
rebalancing. Some <strong>of</strong> the Funds are managed by Rochdale, which receives investment advisory<br />
fees for such services.<br />
Rochdale may utilize GAAP directly with its mid net worth clients for which it has entered into<br />
an investment advisory relationship with directly through Rochdale, an affiliated adviser or<br />
through access provided by another broker dealer or registered investment adviser that has<br />
entered into an agreement with Rochdale to <strong>of</strong>fer GAAP on their platform. Rochdale charges a<br />
flat platform fee <strong>of</strong> between 25 and 35 basis points, depending on the account value, for use <strong>of</strong><br />
this service.<br />
Other Rochdale Activities. The investment advisory programs described above are available to Accounts<br />
maintained <strong>of</strong>f-shore, although differing fee schedules may apply (see “Fees and Compensation” in this<br />
<strong>Brochure</strong>). Rochdale also provides investment advisory services to the RIT Funds and the Alternative<br />
Funds. A small percentage <strong>of</strong> Rochdale’s assets under management are represented by sub-advisory<br />
relationships. Where Rochdale acts as a sub-advisor, Rochdale is retained by an investment advisor who,<br />
in turn, has entered into a contract directly with the client. Under a sub-advisory arrangement, Rochdale<br />
may have limited contact with clients and will manage accounts according to the instructions <strong>of</strong> the<br />
investment adviser who has retained Rochdale to act in a sub-advisory capacity. Securities trades under a<br />
2
sub-advisory arrangement may be executed by RIM, or alternatively, broker/dealers that are not affiliated<br />
with Rochdale. Typically, the investment advisor that has retained Rochdale to act in a sub-advisory<br />
capacity directs the broker/dealer through whom Rochdale must execute trades. If this is the case,<br />
Rochdale does not have the authority to select brokers. When Rochdale acts in a sub-advisory capacity<br />
the fee it receives is determined by the agreement entered into between Rochdale and the investment<br />
advisory firm that has retained Rochdale. Please refer to “Brokerage Practices” in this <strong>Brochure</strong>.<br />
Services provided by Rochdale are governed under the terms <strong>of</strong> an advisory agreement between Rochdale<br />
and each client. The agreement may be terminated at any time upon 30 days written notice by either<br />
party, without penalty. See “Fees and Compensation” in this <strong>Brochure</strong>.<br />
Rochdale acquires clients in a variety <strong>of</strong> ways. The majority <strong>of</strong> clients are introduced to Rochdale by third<br />
parties including independent financial planners, investment advisors, consultants, CPAs, attorneys, and<br />
representatives <strong>of</strong> broker-dealers (sometimes referred to as “Referring <strong>Part</strong>ners”), including organizations<br />
that may be afforded access to GAAP, as noted above. Please refer to <strong>Item</strong> 14 in this <strong>Brochure</strong> for a<br />
further discussion <strong>of</strong> Referring <strong>Part</strong>ners' activities and referral fee arrangements.<br />
C. Client Assets Under Management<br />
As <strong>of</strong> February 29, 2012, the Adviser had $4.7 billion in client assets under management. As <strong>of</strong> that date,<br />
the Adviser managed $4.7 billion on a discretionary basis and $0 on a non-discretionary basis.<br />
3
<strong>Item</strong> 5<br />
Fees and Compensation<br />
A. Advisory Fees and Compensation<br />
Money Management Program.<br />
The table below sets forth Rochdale’s basic fee schedule. Rochdale provides investment advisory<br />
services and charges an investment management fee <strong>of</strong> up to 1.00% per annum, depending on the type<br />
and market value <strong>of</strong> the account, as noted in the table below.<br />
Value <strong>of</strong> Account<br />
Rochdale Fee<br />
First $2 Million 1.00%<br />
Next $3 Million 0.80%<br />
Next $5 Million 0.60%<br />
Amount Over $10 Million 0.50%<br />
Rochdale’s fees may be negotiable, at Rochdale’s sole discretion, and thus may vary from the above<br />
schedule, depending on the size <strong>of</strong> the account, referral fee arrangements affecting individual client<br />
accounts and other factors. For the most part, fees are payable quarterly, in advance. However, few<br />
clients do pay fees in arrears, based usually on the broker dealer custodian for their account.<br />
FCA Rochdale Customized Advisory Services<br />
Advisory Services for Clients through FCA Rochdale The table below sets forth FCA Rochdale’s basic<br />
fee for High Net Worth Accounts.<br />
Value <strong>of</strong> Account<br />
Fee<br />
$1,000,000 to $2,000,000 1.95%<br />
$2,000,001 to $ 3,000,000 1.80%<br />
$3,000,001 to $ 4,000,000 1.75%<br />
$4,000,001 to $ 5,000,000 1.70%<br />
$5,000,001 to $7,000,000 1.40%<br />
$7,000,001 to $10,000,000 1.20%<br />
$10,000,001 to $15,000,000 1.10%<br />
$15,000,001 to $20,000,000 .90%<br />
Above $20,000,000 .80%<br />
Fees set forth in the above schedule may be negotiable, at Rochdale’s sole discretion, and thus may vary<br />
from the above schedule, depending on the size <strong>of</strong> the account, referral fee arrangements affecting<br />
individual client accounts and other factors. For FCA Rochdale accounts the fee for each quarter is paid<br />
in arrears. The initial fee shall be due in full on the date the Account is opened with FCA Rochdale, shall<br />
be based on the market value <strong>of</strong> the Account on that date and shall be withdrawn from the assets in the<br />
Account automatically. The initial fee payment will cover the period from the opening date through the<br />
last day <strong>of</strong> the then current calendar quarter and shall be pro-rated on a daily basis accordingly.<br />
Galaxy Asset Allocation Program Fee Schedule<br />
Clients that elect to participate in this program will have their accounts managed by way <strong>of</strong> Rochdale's<br />
proprietary Galaxy TM Asset Allocation Program ("GAAP"). GAAP enables risk pr<strong>of</strong>iling, target asset<br />
class allocation, standard mutual fund implementation <strong>of</strong> target asset class allocation, customization <strong>of</strong><br />
mutual fund implementation, proposal generation, portfolio implementation based on implementation<br />
4
model, and portfolio management through periodic and/or event driven rebalancing.<br />
For GAAP accounts, Rochdale will charge a platform fee according to the following schedule:<br />
Value <strong>of</strong> Account<br />
Fee<br />
On the first $100,000 0.35%<br />
On the next $250,000 0.30%<br />
On assets over $350,000 0.25%<br />
Additionally, and in connection with GAAP accounts, Referring <strong>Part</strong>ners generally charge a fee, which<br />
ranges from 0.25%-1.25%, and is based on services provided. The services Referring <strong>Part</strong>ners may<br />
provide include: risk pr<strong>of</strong>iling, asset allocation, portfolio analysis, insurance services, retirement and<br />
estate planning. RIT Funds and Alternative Funds may be used in the implementation <strong>of</strong> the client's<br />
portfolio. Please refer to <strong>Item</strong> 14 in this <strong>Brochure</strong> to learn more about Rochdale’s Referring <strong>Part</strong>ners.<br />
Offshore Fees<br />
Rochdale has a separate fee, a portion <strong>of</strong> which is remitted to the custodian to cover custodial fees. Fees<br />
on these accounts are paid each quarter primarily in arrears and will be calculated at one fourth (1/4) <strong>of</strong><br />
the rates set forth below:<br />
Account Assets Value Income Only Accounts Equity or Balanced Accounts Fixed Income<br />
First $1,000,000 to $2,500,000 1.250% 0.750%<br />
On the next $2,500,000 1.000% 0.600%<br />
On the next $2,500,000 0.850% 0.500%<br />
On the next $2,500,000 0.700% 0.400%<br />
On the next $5,000,000 0.550% 0.325%<br />
On assets over $15,000,000 0.500% 0.300%<br />
Rochdale collects a commission (retrocession) for clients that use RBS Coutts to custody their assets.<br />
Such retrocession includes a portion <strong>of</strong> the custodial, trading, and other fees charged.<br />
B. Payment <strong>of</strong> Fees<br />
The Client agrees in its agreement with the Adviser to authorize the Advisor to deduct Management Fee<br />
the from client accounts by instructing the client’s custodian. In general, the Adviser deducts client<br />
accounts for Management Fees quarterly.<br />
C. Prepayment <strong>of</strong> Fees<br />
For the most part, clients pay Management Fees to the Adviser quarterly in advance (this may vary with<br />
<strong>of</strong>fshore clients and some domestic clients). Upon the termination <strong>of</strong> a client account during a calendar<br />
quarter, the Management Fee will be prorated for the days remaining in that calendar quarter and any<br />
prepaid, unearned fees will be refunded to the relevant client.<br />
5
<strong>Item</strong> 6 Performance-Based Fees and Side-By-Side Management<br />
As indicated above, Rochdale’s fees are calculated based on the level <strong>of</strong> assets under<br />
management in an Account. Performance fees are not charged at the account level. However<br />
some <strong>of</strong> the Alternative Funds are subject to the payment <strong>of</strong> performance fee once certain minimum<br />
performance benchmarks are met; all such arrangements are described in the <strong>of</strong>fering documents<br />
associated with such vehicles. These arrangements do not, however result in the receipt by any<br />
Rochdale employee <strong>of</strong> performance or incentive compensation and, accordingly, Rochdale does<br />
not believe that these arrangements give rise to any conflict <strong>of</strong> interest or <strong>of</strong>fer any incentive for any <strong>of</strong><br />
the firm’s investment personnel to favor any vehicle over any other Account.<br />
Rochdale may recommend to clients that they purchase shares <strong>of</strong> the Funds. Rochdale serves as the<br />
investment adviser for the Funds and receives a management fee for its services. If Rochdale invests a<br />
client into RIT Funds, Rochdale may not charge an advisory fee at the portfolio level for the assets <strong>of</strong> a<br />
client’s portfolio that are invested in RIT Funds, in addition to the management fees it receives from the<br />
mutual funds. In some cases Rochdale may credit back to the client the management fees that would have<br />
otherwise been earned through the mutual fund.<br />
Rochdale may also recommend to clients that they purchase shares <strong>of</strong> products other than the RIT Funds,<br />
for which Rochdale may collect a fee at the account level as well as at the product level. Such products<br />
include but are not limited to LPI, RCAS, ROGOF, ROGDF, RITFI, Rochdale GML Trade Finance<br />
Income Fund, RSCFI, RATRF, RRRF and the Federated Intercontinental Fund. Rochdale does not collect<br />
a fee from RATROF or RRROF, as they are feeders into their onshore counterparts, RATRF and RRRF,<br />
where Rochdale collects a fee.<br />
RIM acts as the broker for a majority <strong>of</strong> the client accounts that purchase shares <strong>of</strong> the Funds. Therefore,<br />
RIM receives additional compensation in the form <strong>of</strong> 12b-1 fees, service fees or other trails, which are<br />
fees that are charged to clients that maintain shares <strong>of</strong> the Funds.<br />
Members <strong>of</strong> Rochdale's management, its financial advisers, and members <strong>of</strong> management and advisers <strong>of</strong><br />
their affiliates may receive additional compensation for assets invested into the Funds.<br />
Allocation <strong>of</strong> IPO's: Rochdale may from time to time participate in IPO's. Rochdale's policy and practice<br />
is to allocate IPO shares fairly and equitably among our advisory clients according to a specific and<br />
consistent basis so as not to advantage any firm personnel or related account and so as not to favor or<br />
disfavor any client or group <strong>of</strong> clients over any other. To ensure fair and equitable treatment, Rochdale<br />
will allocate the amount <strong>of</strong> IPO received among all accounts in which it falls within that accounts asset<br />
class allocation. The percentage an account will receive will vary and depend upon the accounts' specific<br />
investment objectives.<br />
6
<strong>Item</strong> 7<br />
Types <strong>of</strong> Clients<br />
Rochdale’s clients consist primarily <strong>of</strong> individuals and pooled investment vehicles, such as the RIT Fund<br />
and the Alternative Funds. Other clients include institutional clients, such as pensions and pr<strong>of</strong>it sharing<br />
plans, charitable organizations and a limited number <strong>of</strong> municipalities. Rochdale generally requires a<br />
minimum <strong>of</strong> $1,000,000 <strong>of</strong> assets under management for a separately managed relationship, but may<br />
waive this minimum in its sole and absolute discretion. If the account size falls below the minimum<br />
requirement due to market fluctuations only, a client will not be required to invest additional funds with<br />
the Adviser to meet the minimum account size. With respect to investments in the RIT Funds or<br />
Alternative Funds, initial and additional subscription minimums are disclosed in the <strong>of</strong>fering documents<br />
relating to such funds.<br />
The Adviser may request clients to provide pro<strong>of</strong> <strong>of</strong> authority, directed trading letters, qualified client or<br />
qualified purchaser status, accredited investor certifications, and/or other information to allow the Adviser<br />
to manage client assets.<br />
7
<strong>Item</strong> 8<br />
Methods <strong>of</strong> Analysis, Investment Strategies and Risk <strong>of</strong> Loss<br />
A. Methods <strong>of</strong> Analysis and Investment Strategies<br />
The Adviser utilizes a variety <strong>of</strong> methods and strategies to make investment decisions and<br />
recommendations. These methods entail an evaluation <strong>of</strong> investment opportunities using fundamental,<br />
technical, quantitative and qualitative analyses to determine the intrinsic value <strong>of</strong> securities and other<br />
types <strong>of</strong> instruments.<br />
The Adviser employs the following investment strategies:<br />
Dynamic Equity Risk Management. The Adviser engages in a Dynamic Equity Risk Management<br />
investment strategy wherein the Adviser is allowed to manage excessive and extreme risk as it relates to<br />
individual client risk pr<strong>of</strong>iles. The Adviser manages portfolio risks proactively to avoid historical Buy &<br />
Hold traps. As well as relating client specific Investment Policy Statement goals to Rochdale’s portfolio<br />
strategy, recession monitor and fundamental outlook<br />
Equity. The Adviser’s equity strategy focuses on a broad range <strong>of</strong> equity investment styles, including<br />
growth, core, and value, as well as portfolios designed to be “style-neutral”. Some client accounts focus<br />
on specific ranges on the capitalization scale, from micro-cap, through small-cap, mid-cap and large-cap,<br />
to mega-cap. Other client accounts will focus on investment opportunities in more than one capitalization<br />
category or across all capitalization levels.<br />
Fundamental Value. The Adviser engages in a fundamental value investment strategy wherein the<br />
Adviser attempts to invest in asset-oriented securities the Adviser believes are undervalued by the market.<br />
Growth. The Adviser engages in a growth investment strategy wherein the Adviser attempts to select<br />
securities <strong>of</strong> a company whose earnings the Adviser expects to grow at an above-average rate compared<br />
to the company’s specific industry or the overall market.<br />
Hedging. The Adviser utilizes a variety <strong>of</strong> financial instruments such as derivatives and options for risk<br />
management purposes.<br />
Relative Value. The Adviser pursues relative value strategies by taking long positions in securities<br />
believed to be undervalued.<br />
High Dividend and Income. The Adviser pursues high dividend and income strategies by taking long<br />
positions in company with high dividend growth potential.<br />
Galaxy TM . The Adviser using a proprietary modeling system to design asset allocation models specific to<br />
clients risk return requirements. Please refer to <strong>Item</strong> 4 in this <strong>Brochure</strong> for a discussion <strong>of</strong> Galaxy. TM<br />
These methods, strategies and investments involve risk <strong>of</strong> loss to clients and clients must be prepared to<br />
bear the loss <strong>of</strong> their entire contribution/investment.<br />
B. Material Risks (Including Significant, or Unusual Risks) Relating to Investment Strategies<br />
Issuer-Specific Changes. Changes in the financial condition <strong>of</strong> an issuer or counterparty, changes in<br />
specific economic or political conditions that affect a particular type <strong>of</strong> security or issuer, and changes in<br />
general economic or political conditions can increase the risk <strong>of</strong> default by an issuer or counterparty,<br />
which can affect a security’s or instrument’s value. The value <strong>of</strong> securities <strong>of</strong> smaller, less well-known<br />
issuers can be more volatile than that <strong>of</strong> larger issuers. Smaller issuers can have more limited product<br />
lines, markets, or financial resources.<br />
Relative Value Risk. In the event that the perceived mispricings underlying the Adviser’s relative value<br />
trading positions were to fail to converge toward, or were to diverge further from, relationships expected<br />
8
y the Adviser, client accounts may incur a loss.<br />
Leverage. Performance may be more volatile if a client’s account employs leverage.<br />
Hedging. There can be no assurances that a particular hedge is appropriate, or that certain risk is<br />
measured properly. Further, while the Adviser may enter into hedging transactions to seek to reduce risk,<br />
such transactions may result in poorer overall performance and increased (rather than reduced) risk for the<br />
Adviser’s investment portfolios than if the Adviser did not engage in any such hedging transactions.<br />
Frequent Trading. The Adviser’s primary strategy uses frequent trading which results in significantly<br />
higher commissions and charges to client accounts due to increased brokerage, which will <strong>of</strong>fset client<br />
pr<strong>of</strong>its.<br />
C. Risks Associated with Types <strong>of</strong> Securities that are Primarily Recommended<br />
Equity Securities. The value <strong>of</strong> equity securities fluctuates in response to issuer, political, market, and<br />
economic developments. Fluctuations can be dramatic over the short as well as long term, and different<br />
parts <strong>of</strong> the market and different types <strong>of</strong> equity securities can react differently to these developments. For<br />
example, large cap stocks can react differently from small cap stocks, and “growth” stocks can react<br />
differently from “value” stocks. Issuer, political, or economic developments can affect a single issuer,<br />
issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in<br />
the financial condition <strong>of</strong> a single issuer can impact the market as a whole. Terrorism and related geopolitical<br />
risks have led, and may in the future lead, to increased short-term market volatility and may have<br />
adverse long-term effects on world economies and markets generally.<br />
Fixed-Income and Debt Securities. Investment in fixed-income and debt securities such as bonds, notes<br />
and asset-backed securities, subject a client’s portfolios to the risk that the value <strong>of</strong> these securities overall<br />
will decline because <strong>of</strong> rising interest rates. Similarly, portfolios that hold such securities are subject to<br />
the risk that the portfolio’s income will decline because <strong>of</strong> falling interest rates. Investments in these<br />
types <strong>of</strong> securities will also be subject to the credit risk created when a debt issuer fails to pay interest and<br />
principal in a timely manner, or that negative perceptions <strong>of</strong> the issuer’s ability to make such payments<br />
will cause the price <strong>of</strong> that debt to decline. Lastly, investments in debt securities will also subject the<br />
investments to the risk that the securities may fluctuate more in price, and are less liquid than higher-rated<br />
securities because issuers <strong>of</strong> such lower-rated debt securities are not as strong financially, and are more<br />
likely to encounter financial difficulties and be more vulnerable to adverse changes in the economy.<br />
Security Futures and Options. In connection with the use <strong>of</strong> futures contracts and options, there may be<br />
an imperfect correlation between the change in market value <strong>of</strong> a security and the prices <strong>of</strong> the futures<br />
contracts and options in the client’s account. In addition, the Adviser’s investments in security futures<br />
and options may encounter a lack <strong>of</strong> a liquid secondary market for a futures contract and the resulting<br />
inability to close a futures position prior to its maturity date.<br />
Offshore. As with all investment strategies, there are risks associated with its implementation. Applicable<br />
risks include, but are not limited to, market risk, unexpected volatility <strong>of</strong> stock prices, inflation risk, credit<br />
risk, and government policy risk. While these risks are monitored regularly by Rochdale Offshore<br />
Investment Management, they are still inherent in most investment strategies, including the one being<br />
implemented. Additionally, holding monies <strong>of</strong>fshore in custody adds a risk factor in dealing with and<br />
being subject to a foreign jurisdiction. These rules and regulations may provide more or less protection<br />
that what is afforded an investor who funds remain in the United States. Please consult with your<br />
investment or financial advisor to get a complete understanding <strong>of</strong> the risks that may affect your<br />
investment.<br />
Alternative Investments and Hedge Funds. Hedge funds and alternative investments are speculative and<br />
may entail substantial risks. Investing in small and medium-size companies and REITs may carry<br />
9
additional risks such as limited liquidity and increased volatility. Investing in international companies<br />
carries risks such as currency fluctuation, interest rate fluctuation, and economic and political instability.<br />
Investing in a non-diversified fund involves greater risk than investing in a diversified fund. Short sales<br />
may increase volatility and potential for loss. As with all investments, there is no guarantee that<br />
investment objectives will be met. For Alternative Funds, these risks include the fact that it may be<br />
difficult to correctly value all <strong>of</strong> the investments held and the fact that investments in the Fund may be<br />
illiquid. With respect to RIT Fund, the risk relates to the underlying investment objectives and strategies<br />
<strong>of</strong> the specific portfolio in which an investment is made and is described in the prospectus relating to each<br />
such portfolio.<br />
As indicated above, Rochdale may recommend the use <strong>of</strong> the Fund in implementing its asset allocation<br />
strategies. As is the case with respect to any investment in securities, Accounts managed by Rochdale<br />
using any or all <strong>of</strong> the strategies described above involve the risk that investment losses may be<br />
experienced by the Account. Investment in the Funds can involve certain risks.<br />
10
<strong>Item</strong> 9<br />
Disciplinary Information<br />
Neither Rochdale nor any <strong>of</strong> its employees have been involved in any legal or disciplinary events in the<br />
past 10 years that would be material to a client’s evaluation <strong>of</strong> the company or its personnel.<br />
11
<strong>Item</strong> 10<br />
Other Financial Industry Activities and Affiliations<br />
Certain <strong>of</strong>ficers and/or directors associated with Rochdale serve as <strong>of</strong>ficers, directors, analysts and/or<br />
portfolio managers <strong>of</strong> one or more the following entities: Symphonic Financial Advisors LLC, an SEC<br />
registered investment adviser, Symphonic Securities LLC, a FINRA registered broker/dealer, Symphonic<br />
Insurance LLC, a state registered insurance agency, RIM Securities LLC, a FINRA registered<br />
broker/dealer, Rochdale Capital Management LLC, an SEC registered investment adviser, and Rochdale<br />
Securities LLC, a FINRA registered broker/dealer. Please take note, Rochdale’s only affiliation with<br />
Rochdale Capital Management LLC and Rochdale Securities LLC is through the common ownership<br />
<strong>of</strong> Carl Acebes, Founder. Rochdale does not, follow or endorse the decisions, positions, analyses,<br />
opinions, research or recommendations made by Rochdale Capital Management LLC or Rochdale<br />
Securities LLC. Rochdale is a clear and distinct entity from both Rochdale Capital Management LLC<br />
and Rochdale Securities LLC. There is no overlap <strong>of</strong> personnel, systems, services, etc., nor is there any<br />
business arrangement or dealings between the entities. Rochdale’s relationship as an investment advisor<br />
to the several Alternative Funds and to RIT Funds is material to Rochdale’s advisory business. As<br />
described above, clients may invest in RIT Funds and/or Alternative Funds. Rochdale and/or its <strong>of</strong>ficers,<br />
employees and directors may also be investors in these vehicles. Although there is some potential for<br />
conflict <strong>of</strong> interest, Rochdale believes these are not material in light <strong>of</strong> the requirements <strong>of</strong> the Code <strong>of</strong><br />
Ethics adopted by Rochdale and in light <strong>of</strong> the fact that, to the extent that Rochdale or any employee,<br />
director or <strong>of</strong>ficer is an investor in RIT Funds or Alternative fund, each shares in any gains or losses<br />
proportionally with all other investors.<br />
12
<strong>Item</strong> 11<br />
Code <strong>of</strong> Ethics, <strong>Part</strong>icipation or Interest in Client Transactions and Personal<br />
Trading<br />
A. Code <strong>of</strong> Ethics<br />
Rochdale has adopted a Code <strong>of</strong> Ethics (the "Code") expressing the firm's commitment to ethical conduct.<br />
Rochdale's Code <strong>of</strong> Ethics describes the firm's fiduciary duties and responsibilities to clients (which<br />
includes Rochdale Investment Trust, Rochdale Core Alternative Strategies Fund, Rochdale International<br />
Trade Fixed Income Fund, Rochdale Structured Claims Fixed Income Fund, RIM, Symphonic Financial<br />
Advisors LLC, Symphonic Securities LLC and Symphonic Insurance LLC), and sets forth the practice <strong>of</strong><br />
supervising personal securities transactions <strong>of</strong> employees. Individuals associated with Rochdale may buy<br />
or sell securities for their personal accounts identical to or different than those recommended to clients. It<br />
is the expressed policy <strong>of</strong> Rochdale that no person employed by Rochdale shall prefer his or her own<br />
interest to that <strong>of</strong> an advisory client or make personal investment decisions based on the investment<br />
decisions <strong>of</strong> advisory clients.<br />
To supervise compliance with the Code, Rochdale requires that employees with access to advisory<br />
recommendations, or other inside information provide quarterly securities holdings reports and quarterly<br />
transactions reports to the Compliance Department. Rochdale also requires all such employees receive<br />
prior approval from the Compliance Department prior to effecting transactions meeting certain criteria.<br />
All individuals employed by or affiliated with Rochdale must sign, no less than annually, an attestation<br />
confirming their receipt and comprehension <strong>of</strong> the Code.<br />
Rochdale requires that all individuals must act in accordance with all applicable federal and state<br />
regulations governing registered investment advisory, broker dealer or other pr<strong>of</strong>essional designation<br />
practices. Rochdale's Code further includes the firm's policy prohibiting the use <strong>of</strong> material non-public<br />
information. Any individual not in observance <strong>of</strong> the Code may be subject to discipline.<br />
Rochdale will provide a complete copy <strong>of</strong> its Code <strong>of</strong> Ethics to any client upon request.<br />
B. Client Transactions in Securities where Adviser has a Material Financial Interest<br />
Rochdale has discretionary authority over its clients' investment accounts and initiates the transactions in<br />
such accounts. RIM receives commissions for executing transactions for most <strong>of</strong> Rochdale's clients.<br />
These commissions are assessed at rates which are believed to be competitive with those representative<br />
assisted rates charged by the major national discount brokerage firms. Rochdale follows specific<br />
procedures to assure that its fiduciary responsibilities are carried out with the highest degree <strong>of</strong> care and<br />
pr<strong>of</strong>essionalism.<br />
Rochdale and RIM may, from time to time, facilitate the purchase and sale <strong>of</strong> a security between two or<br />
more clients without either Rochdale or RIM being the seller or the buyer. This is known as an "internal<br />
cross" transaction and is only performed under client authorization. Prior to engaging in an internal cross<br />
transaction, Rochdale and RIM will ensure that the transaction is in the best interest <strong>of</strong> all client parties<br />
involved by ensuring the price is fair and properly disclosing all known potential conflicts. Neither<br />
Rochdale nor its affiliates will receive compensation for effecting internal cross transactions.<br />
Rochdale and RIM may, from time to time, enter into transactions where client securities are purchased<br />
from or sold to brokerage customers <strong>of</strong> RIM in what is known as an "agency cross" transaction. Rochdale<br />
or RIM will engage in these cross transactions when it is determined that doing so may provide a better<br />
execution opportunity though such a result is not guaranteed. If an agency cross transaction occurs, RIM<br />
may receive commissions from both sides <strong>of</strong> the transaction. Due to the method <strong>of</strong> trade execution for an<br />
13
agency cross transaction, there is a potential conflicting division <strong>of</strong> loyalties and responsibilities. In no<br />
event will Rochdale or RIM act as a principal in such transactions.<br />
C. Investing in Securities Recommended to Clients<br />
Rochdale and/or related persons may purchase, sell or hold positions in certain investments that are<br />
recommended to, or implemented for, any <strong>of</strong> its clients. If Rochdale holds securities for itself that it also<br />
recommends to or implements for clients, the following restrictions and disclosure procedures are<br />
maintained for the protection <strong>of</strong> clients.<br />
1) Rochdale will recommend to or implement for its clients the purchase or sale <strong>of</strong> the same securities<br />
held, purchased or sold by Rochdale or any associated person only if such transaction is consistent with<br />
the objectives <strong>of</strong> the client.<br />
2) The clients' interest will be placed before Rochdale in such purchases and sales to assure that, on any<br />
given day, (a) the timing <strong>of</strong> the transaction will not put the client at a disadvantage, and (b) the price<br />
obtained for the client will be the same or more advantageous than that obtained for Rochdale or any<br />
associated person.<br />
3) Employees deemed to have knowledge <strong>of</strong> client trading activities will be regarded as “Trust Access”<br />
persons and will be required to gain approval for all securities transactions.<br />
D. Conflicts <strong>of</strong> Interest Created by Contemporaneous Trading<br />
See C(1) <strong>of</strong> this <strong>Item</strong> 11 above and <strong>Item</strong> 10, in this <strong>Brochure</strong>.<br />
14
<strong>Item</strong> 12<br />
Brokerage Practices<br />
A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions<br />
Rochdale considers a number <strong>of</strong> factors in selecting a broker-dealer to execute transactions (or series <strong>of</strong><br />
transactions) and determining the reasonableness <strong>of</strong> the broker-dealer’s compensation. Such factors<br />
include net price, reputation, financial strength and stability, efficiency <strong>of</strong> execution and error resolution,<br />
<strong>of</strong>fering to Rochdale on-line access to computerized data regarding a client’s accounts. In selecting a<br />
broker-dealer to execute transactions (or series <strong>of</strong> transactions) and determining the reasonableness <strong>of</strong> the<br />
broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an<br />
obligation to seek the lowest available commission cost. It is not Rochdale’s practice to negotiate<br />
“execution only” commission rates, thus a client may be deemed to be paying for research, brokerage or<br />
other services provided by a broker-dealer which are included in the commission rate.<br />
1. Research and Other S<strong>of</strong>t Dollar Benefits<br />
Rochdale receives research or other products or services other than execution from a broker-dealer and/or<br />
a third party in connection with client securities transactions. This is known as a “s<strong>of</strong>t dollar” relationship.<br />
Rochdale will limit the use <strong>of</strong> “s<strong>of</strong>t dollars” to obtain research and brokerage services to services that<br />
constitute research and brokerage within the meaning <strong>of</strong> Section 28(e) <strong>of</strong> the Securities Exchange Act <strong>of</strong><br />
1934, as amended (“Section 28(e)”). Research services within Section 28(e) may include, but are not<br />
limited to, research reports (including market research); certain financial newsletters and trade journals;<br />
s<strong>of</strong>tware providing analysis <strong>of</strong> securities portfolios; corporate governance research and rating services;<br />
attendance at certain seminars and conferences; discussions with research analysts; meetings with<br />
corporate executives; consultants’ advice on portfolio strategy; data services (including services providing<br />
market data, company financial data and economic data); advice from broker-dealers on order execution;<br />
and certain proxy services. Brokerage services within Section 28(e) may include, but not limited to,<br />
services related to the execution, clearing and settlement <strong>of</strong> securities transactions and functions<br />
incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant<br />
parties such as custodians); trading s<strong>of</strong>tware operated by a broker-dealer to route orders; s<strong>of</strong>tware that<br />
provides trade analytics and trading strategies; s<strong>of</strong>tware used to transmit orders; clearance and settlement<br />
in connection with a trade; electronic communication <strong>of</strong> allocation instructions; routing settlement<br />
instructions; post trade matching <strong>of</strong> trade information; and services required by the SEC or a self<br />
regulatory organization such as comparison services, electronic confirms or trade affirmations.<br />
The Chief Compliance Officer will periodically review and evaluate Rochdale’s s<strong>of</strong>t dollar practices and<br />
to determine in good faith whether, with respect to any research or other products or services received<br />
from a broker-dealer, the commissions used to obtain those products and services were reasonable in<br />
relation to the value <strong>of</strong> the brokerage, research or other products or services provided by the brokerdealer.<br />
This determination will be viewed in terms <strong>of</strong> either the specific transaction or the Adviser’s<br />
overall responsibilities to the accounts or portfolios over which the Adviser exercises investment<br />
discretion.<br />
The use <strong>of</strong> client commissions (or markups or markdowns) to obtain research and brokerage products and<br />
services raises conflicts <strong>of</strong> interest. For example, the Adviser will not have to pay for the products and<br />
services itself. This creates an incentive for Rochdale to select or recommend a broker-dealer based on its<br />
interest in receiving those products and services.<br />
Rochdale may cause clients to pay commissions (or markups or markdowns) higher than those charged by<br />
other broker-dealers in return for s<strong>of</strong>t dollar benefits (known as paying-up), resulting in higher transaction<br />
costs for clients.<br />
Research and brokerage services obtained by the use <strong>of</strong> commissions arising from a client’s portfolio<br />
transactions may be used by Rochdale in its other investment activities, including, for the benefit <strong>of</strong> other<br />
15
client accounts. Rochdale does not seek to allocate s<strong>of</strong>t dollar benefits to client accounts proportionately<br />
to the s<strong>of</strong>t dollar credits the accounts generate.<br />
Rochdale may participate in “client commission arrangements” pursuant to which Rochdale may execute<br />
transactions through a broker-dealer and request that the broker-dealer allocate a portion <strong>of</strong> the<br />
commissions or commission credits to another firm that provides research and other products to<br />
Rochdale. Rochdale excludes from use under these arrangements those products and services that are not<br />
eligible under Section 28(e) and applicable regulatory interpretations.<br />
2. Brokerage for Client Referrals<br />
In selecting or recommending broker-dealers, Rochdale may consider whether Rochdale or a related<br />
person receives client referrals from a broker-dealer or third party. Rochdale may have an incentive to<br />
select or recommend a broker-dealer based on its interests to receive client referrals rather than on the<br />
client’s interests to receive most favorable execution. To address this conflict <strong>of</strong> interest, Rochdale will<br />
execute client trades through broker-dealers that refer clients to Rochdale only if it is determined by the<br />
Chief Compliance Officer that client trades with such broker-dealers are otherwise consistent with<br />
seeking best execution.<br />
3. Directed Brokerage<br />
Under certain circumstances, clients may direct Rochdale to execute the client’s trades with a specified<br />
broker-dealer. When a client directs Rochdale to use a specified broker-dealer to execute all or a portion<br />
<strong>of</strong> the client’s securities transactions, Rochdale treats the client direction as a decision by the client to<br />
retain, to the extent <strong>of</strong> the direction, the discretion Rochdale would otherwise have in selecting brokerdealers<br />
to effect transactions and in negotiating commissions for the client’s account. Although Rochdale<br />
attempts to effect such transactions in a manner consistent with its policy <strong>of</strong> seeking best execution, there<br />
may be occasions where it is unable to do so, in which case Rochdale will continue to comply with the<br />
client’s instructions. Transactions in the same security for accounts that have directed the use <strong>of</strong> the same<br />
broker will be aggregated. When the directed broker-dealer is unable to execute a trade, Rochdale will<br />
select broker-dealers other than the directed broker-dealer to effect client securities transactions. A client<br />
who directs Rochdale to use a particular broker-dealer to effect transactions should consider whether such<br />
direction may result in certain costs or disadvantages to the client. Such costs may include higher<br />
brokerage commissions (because Rochdale may not be able to aggregate orders to reduce transaction<br />
costs), less favorable execution <strong>of</strong> transactions, and the potential <strong>of</strong> exclusion from the client's portfolio <strong>of</strong><br />
certain foreign ordinary shares and/or small capitalization or illiquid securities due to the inability <strong>of</strong> the<br />
particular broker-dealer in question to provide adequate price and execution <strong>of</strong> all types <strong>of</strong> securities<br />
transactions. By permitting a client to direct Rochdale to execute the client’s trades through a specified<br />
broker-dealer, Rochdale will make no attempt to negotiate commissions on behalf <strong>of</strong> the client and, as a<br />
result, in some transactions such clients may pay materially disparate commissions depending on their<br />
commission arrangement with the specified broker-dealer and upon other factors such as number <strong>of</strong><br />
shares, round and odd lots and the market for the security. The commissions charged to clients that direct<br />
Rochdale to execute the client’s trades through a specified broker-dealer may in some transactions be<br />
materially different than those <strong>of</strong> clients who do not direct the execution <strong>of</strong> their trades. Client’s that<br />
direct Rochdale to execute the client’s trades through a specified broker-dealer may also lose the ability to<br />
negotiate volume commission discounts on batched transactions that may otherwise be available to other<br />
clients <strong>of</strong> Rochdale.<br />
B. Order Aggregation<br />
Rochdale <strong>of</strong>ten purchases or sells the same security for many clients contemporaneously (or near the<br />
same time) and using the same executing broker. It is Rochdale’s practice, where possible, to aggregate<br />
client orders for the purchase or sale <strong>of</strong> the same security submitted contemporaneously (or near the same<br />
16
time) for execution using the same executing broker. Rochdale will also aggregate in the same<br />
transaction, the same securities for accounts where Rochdale has brokerage discretion. Such aggregation<br />
may enable Rochdale to obtain for clients a more favorable price or a better commission rate based upon<br />
the volume <strong>of</strong> a particular transaction. However, in cases where the client has negotiated the commission<br />
rate directly with the broker, Rochdale will not be able to obtain more favorable commission rates based<br />
on an aggregated trade. In such cases, the client will be precluded from receiving the benefit <strong>of</strong> any<br />
possible commission discounts that might otherwise be available as a result <strong>of</strong> the aggregated trade. In<br />
cases where trading or investment restrictions are placed on a client’s account, Rochdale may be<br />
precluded from aggregating that client’s transaction with others. In such a case, the client may pay a<br />
higher commission rate and/or receive less favorable prices than clients who are able to participate in an<br />
aggregated order. When an aggregated order is completely filled, Rochdale allocates the securities<br />
purchased or proceeds <strong>of</strong> sale pro rata among the participating accounts, based on the purchase or sale<br />
order. Adjustments or changes may be made under certain circumstances, such as to avoid odd lots or<br />
excessively small allocations. If the order at a particular broker is filled at several different prices,<br />
through multiple trades, generally all such participating accounts will receive the average price and pay<br />
the average commission, subject to odd lots, rounding, and market practice. If an aggregated order is only<br />
partially filled, Rochdale’s procedures provide that the securities or proceeds are to be allocated in a<br />
manner deemed fair and equitable to clients. Depending on the investment strategy pursued and the type<br />
<strong>of</strong> security, this may result in a pro rata allocation to all participating clients. Rochdale or its related<br />
persons may also participate in an aggregate order.<br />
17
<strong>Item</strong> 13<br />
Review <strong>of</strong> Accounts<br />
A. Frequency and Nature <strong>of</strong> Review<br />
Each client account is reviewed by their portfolio manager or his designee on an ongoing and regular<br />
basis to determine whether securities positions should be maintained in view <strong>of</strong> current market conditions.<br />
Matters reviewed include specific securities held, adherence to investment guidelines and the<br />
performance <strong>of</strong> each client account.<br />
B. Factors Prompting an Immediate Review <strong>of</strong> Accounts.<br />
Significant market events affecting the prices <strong>of</strong> one or more securities in client accounts, changes in the<br />
investment objectives or guidelines <strong>of</strong> a particular client, or specific arrangements with particular clients<br />
may trigger reviews <strong>of</strong> client accounts on an immediate basis.<br />
C. Content and Frequency <strong>of</strong> Regular Account Report<br />
Each client that is a separate account will receive monthly statements and trade confirmations from the<br />
client’s broker-dealer and will receive quarterly reports from the Adviser. The reports will include a<br />
summary <strong>of</strong> assets, realized and unrealized capital gains and losses, and anticipated and actual income<br />
generated by the portfolio. Such reports may be delivered electronically to the client in accordance with<br />
the client’s agreement with the Adviser.<br />
18
<strong>Item</strong> 14<br />
Client Referrals and Other Compensation<br />
A. Economic Benefits Received from Non-Clients for Providing Services to Clients<br />
Rochdale receives certain research or other products or services from broker-dealers through “s<strong>of</strong>t-dollar”<br />
arrangements. These “s<strong>of</strong>t-dollar” arrangements create an incentive for Rochdale to select or recommend<br />
broker-dealers based on Rochdale’s interest in receiving the research or other products or services and<br />
may result in the selection <strong>of</strong> a broker-dealer on the basis <strong>of</strong> considerations that are not limited to the<br />
lowest commission rates and may result in higher transaction costs than would otherwise be obtainable by<br />
Rochdale on behalf <strong>of</strong> its clients. Please see <strong>Item</strong> 12 for further information on Rochdale’s “s<strong>of</strong>t-dollar”<br />
practices, including Rochdale’s procedures for addressing conflicts <strong>of</strong> interest that arise from such<br />
practices.<br />
B. Compensation to Non-Supervised Persons for Client Referrals<br />
Rochdale may make cash payments to third-party solicitors for client referrals, provided that, to the extent<br />
required, each such solicitor has entered into a written agreement with the Adviser pursuant to which the<br />
solicitor will provide each prospective client with a copy <strong>of</strong> Rochdale’s <strong>Form</strong> <strong>ADV</strong> <strong>Part</strong> 2, and a<br />
disclosure document setting forth the terms <strong>of</strong> the solicitation arrangement, including the nature <strong>of</strong> the<br />
relationship between the solicitor and Rochdale and any fees to be paid to the solicitor. Where applicable,<br />
cash payments for client solicitations will be structured to comply fully with the requirements <strong>of</strong> Rule<br />
206(4)-3 under the Investment Advisers Act <strong>of</strong> 1940, as amended, and related SEC staff interpretations. \<br />
The majority <strong>of</strong> clients are introduced to Rochdale by third parties including independent financial<br />
planners, investment advisors, consultants, CPAs, attorneys, and representatives <strong>of</strong> broker-dealers<br />
(“Referring <strong>Part</strong>ners”). Clients referred to Rochdale by a Referring <strong>Part</strong>ner, enter into an investment<br />
advisory contract directly with Rochdale. Referring <strong>Part</strong>ners may provide to client (but are not required<br />
by Rochdale to do so) other services (hereinafter “Additional Services”), such as researching money<br />
management services, assisting clients with financial planning and investment objective-setting,<br />
coordinating communications between the client and the manager, and monitoring performance and<br />
services to insure that clients’ needs are being met. Referring <strong>Part</strong>ners may or may not provide these<br />
services and clients should review with Referring <strong>Part</strong>ners those Additional Services that are being<br />
provided by Referring <strong>Part</strong>ners and the fee assessed for those Additional Services, which may be<br />
deducted by Rochdale for remittance to Referring <strong>Part</strong>ners. Any such Additional Services are provided<br />
solely by Referring <strong>Part</strong>ners and not by, or on behalf <strong>of</strong>, Rochdale. Referring <strong>Part</strong>ners charge a fee in<br />
addition to Rochdale fees.<br />
19
<strong>Item</strong> 15<br />
Custody<br />
Custody <strong>of</strong> all Accounts is maintained by Pershing LLC, a qualified custodian. Pershing LLC has agreed<br />
to provide account statements directly to clients at their address <strong>of</strong> record on a monthly basis. This<br />
quarterly statement also lists information relating to advisory fees paid to Rochdale, which fees are<br />
generally paid directly from the Account. Client should carefully review these statements and should<br />
compare these statements, including fees and expenses charged to the client’s Account, to the monthly<br />
summary provided to each client by Rochdale.<br />
Rochdale does not maintain physical custody <strong>of</strong> any client assets. Because Rochdale or related persons <strong>of</strong><br />
Rochdale serves as the general partner and/or investment manager for ROGOF and ROGDF, we are<br />
deemed to have custody <strong>of</strong> such assets pursuant to the Investment Advisers Act <strong>of</strong> 1940 and certain<br />
reporting obligations to investors apply. These requirements are satisfied by having each such fund<br />
undergo an annual audit by a PCAOB qualified independent audit firm and providing the audited<br />
financial statements to each investor in the fund within 180 days <strong>of</strong> its fiscal year end. [Transactions in<br />
each such fund are also listed on the quarterly statement sent directly to each investor during such<br />
quarter.]<br />
20
<strong>Item</strong> 16<br />
Investment Discretion<br />
Pursuant to the terms <strong>of</strong> the Investment Advisory Agreement, Rochdale is not required to obtain specific<br />
client consent regarding securities to be bought or sold or its amounts there<strong>of</strong>. However, Rochdale buys<br />
securities for a client's account in accordance with the client's stated investment objectives. Rochdale<br />
assumes all investment duties with respect to assets held in the investment management account and has<br />
all investment powers including sole investment authority, except that Rochdale is not authorized to<br />
withdraw any money or securities from the account without specific authority from the client. If assets<br />
are to be withdrawn in any name other than that <strong>of</strong> the account, the client must provide written<br />
instructions and authority.<br />
For client accounts that Rochdale has not been granted discretion, Rochdale's ability to provide the best<br />
possible services may be impaired and as such, client's account may be at a detriment.<br />
Rochdale suggests that most clients direct RIM, in its capacity as a Financial Industry Regulatory<br />
Authority (FINRA) registered broker-dealer, to act as broker for the account. RIM is an affiliate <strong>of</strong><br />
Rochdale. In these cases, custody services are provided by Pershing LLC under a fully disclosed clearing<br />
agreement with RIM. If client assets are custodied through RIM, at Pershing LLC, the client does not<br />
have the option <strong>of</strong> having outside broker dealers effecting securities transactions. Commission rates are<br />
set by RIM. Certain clients elect to custody their assets <strong>of</strong>fshore, in these instances, executions are<br />
primarily done through the <strong>of</strong>fshore bank's broker dealer arm. The commission rates are normally not<br />
negotiable but may be depending upon the size <strong>of</strong> the account, the client's relationship with the firm's<br />
representative, and other factors.<br />
Commission schedules are available upon request. Generally Rochdale requires that transactions be<br />
executed through RIM because <strong>of</strong> its belief that this achieves greater operational efficiencies. Clients<br />
may instruct Rochdale to use brokers other than RIM.<br />
Some <strong>of</strong> Rochdale's clients are referred by independent investment advisors or representatives <strong>of</strong> nonaffiliated<br />
brokerage firms. In these cases, the client may designate the non-affiliated brokerage firm to<br />
effect transactions directed by Rochdale and to provide custodial and other brokerage services. Rochdale<br />
will follow the client's instructions as contained in the Investment Advisory Agreement. For these clients,<br />
Rochdale does not negotiate commission rates with the designated brokerage firm or any representative <strong>of</strong><br />
the firm. If they wish to do so, clients may negotiate these rates independently. The factors involved in<br />
such negotiation may include the size <strong>of</strong> the account, the brokerage firm's policy with respect to<br />
discounts, the client's relationship with the firm's representative, and other factors. Unless a lower rate is<br />
negotiated, the client should expect that the designated brokerage firm will charge on the basis <strong>of</strong> its nondiscounted<br />
commission schedule.<br />
In those situations where the client has directed Rochdale to place trades with a non-affiliated<br />
broker/dealer, Rochdale may not be free to seek the best price, volume discounts or best execution by<br />
placing transactions with other broker-dealers. Additionally, as a result <strong>of</strong> directing Rochdale to place<br />
trades with a particular broker/dealer, a disparity in commission charges and services provided may exist<br />
between the commissions charged to clients who direct Rochdale to use a particular broker/dealer and<br />
those clients who may not direct Rochdale to use a particular broker/dealer as well as a disparity among<br />
the brokers to which different clients have directed trades.<br />
Typically, under a sub-advisory arrangement the investment advisor that has retained Rochdale to act in a<br />
sub-advisory capacity directs the broker/dealer through whom Rochdale must execute trades. If this is the<br />
case, Rochdale does not have the authority to select brokers.<br />
21
RIM executes transactions for the majority <strong>of</strong> Rochdale's advisory clients. Clients who have not entered<br />
into an investment advisory agreement with Rochdale and who do not pay an investment advisory fee<br />
may incur a higher rate <strong>of</strong> commissions on transactions according to a separate commission schedule for<br />
non-fee accounts. With respect to OTC transactions effected on behalf <strong>of</strong> clients, RIM does not act as a<br />
market-maker or principal. These transactions are effected on an agency basis only.<br />
RIM may route its orders to other broker/dealers for execution at its discretion. In those situations where<br />
Rochdale has not been directed by a client to execute trades with a particular broker/dealer, Rochdale is<br />
free to determine the broker/dealer utilized. Factors taken into consideration by RIM in choosing<br />
broker/dealers for execution, and the reasonableness <strong>of</strong> their commissions, include execution quality,<br />
quality <strong>of</strong> service, payments which may be received by RIM for directing order flow, clearing<br />
relationships and products or research services provided. RIM presently receives research services for<br />
directing its trades to a particular broker. These research services are usually in the form <strong>of</strong> written<br />
research reports and market analysis. Research services may be used in servicing all <strong>of</strong> Rochdale's clients,<br />
not just those clients whose commissions enabled Rochdale to obtain the research. While RIM may pay a<br />
higher commission rate to brokers in exchange for research services, those increased commissions do not<br />
affect the commissions charged by RIM to Rochdale's clients and are absorbed by RIM, except for RIT<br />
Funds. If RIT Funds trade their underlying securities through RIM and RIM provides research services or<br />
routes orders to another broker dealer for research services, the RIT Funds may pay a higher commission,<br />
which is directly assessed to the RIT Fund. Please see Rochdale Investment Trust's prospectus for more<br />
information.<br />
Rochdale may aggregate orders in a given security for a number <strong>of</strong> clients if it believes doing so may<br />
result in a better execution, however there is no guarantee that this will be achieved. When orders for<br />
different clients are forwarded to Rochdale’s traders within the same general time period during the<br />
trading day, the trader will endeavor to combine those orders. Orders in the same security for different<br />
clients forwarded to Rochdale’s trader that are separated by large periods <strong>of</strong> time will most likely not be<br />
aggregated. The time an order is forwarded to Rochdale’s trader is dependent on a number <strong>of</strong> factors<br />
including, but not limited to, portfolio adjustments required by Rochdale’s proprietary s<strong>of</strong>tware, decisions<br />
by individual portfolio managers, the type <strong>of</strong> client and the individual needs or circumstances surrounding<br />
a particular clients' account.<br />
When an aggregate order is executed at more than one price, each client receives the weighted average price<br />
at which the completed order was filled. Commissions are not reduced by such grouping <strong>of</strong> orders. Each<br />
client incurs its regular commission pursuant to the designated broker's commission schedule.<br />
Trades executed for clients with assets custodied at unaffiliated broker/dealers will not, because <strong>of</strong><br />
operational limitations, be aggregated, but may be aggregated with other Rochdale clients utilizing the same<br />
custodian.<br />
In deciding the execution priority for client accounts who have directed Rochdale to place trades with RIM or<br />
those clients who have directed Rochdale to place trades with unaffiliated brokers, Rochdale shall seek to<br />
take a fair an equitable approach and rotate the time priority given to these accounts so that no one group <strong>of</strong><br />
clients consistently receives executions prior to any other. The rotation sequence shall alternate daily<br />
between trades executed with RIM, and all other unaffiliated brokers so that RIM is never given priority in<br />
any two consecutive days. Additionally, trades will be rotated among outside brokers in a uniform sequence.<br />
This procedure may be altered during extreme market conditions if it is determined that following such<br />
procedures is likely to be detrimental to a large number <strong>of</strong> clients.<br />
22
<strong>Item</strong> 17<br />
Voting Client Securities<br />
As a registered investment adviser with the SEC, Rochdale owes its clients a duty <strong>of</strong> care and a duty <strong>of</strong><br />
loyalty at all times. This means that if granted the authority to vote proxies we must always vote in your best<br />
interest. We must maintain copies <strong>of</strong> all proxy votes we cast on your behalf and will provide this information<br />
upon request.<br />
Upon opening an account with Rochdale, clients are given the option to delegate proxy-voting discretion to<br />
Rochdale by completing the appropriate documents. Rochdale will only exercise proxy-voting discretion over<br />
the client shares in the instances where clients give Rochdale discretionary authority to vote on their behalf.<br />
When voting on behalf <strong>of</strong> clients, we currently utilize the services <strong>of</strong> a neutral third party proxy voting<br />
service. This service provides Rochdale with a neutral recommendation on how a client's proxy should be<br />
voted. In most instances, we will cast clients votes in accordance with their recommendation. However, in the<br />
event we feel that the suggestion provided by the proxy voting services is not in not in the clients best interest<br />
we may vote against such recommendation. In the instances we decide not to go with the recommendation<br />
provided, we keep an internal memorandum detailing our reasons for doing so.<br />
Rochdale also has authorization to vote the underlying shares <strong>of</strong> Rochdale Investment Trust.<br />
Clients may obtain a copy <strong>of</strong> the Adviser’s proxy voting policies and procedures and information about how<br />
the Adviser voted a client’s proxies by contacting Barbara Hawkesworth (Chief Compliance Officer) by<br />
email at bam@rochdale.com or by telephone at (212) 702-3500.<br />
23
<strong>Item</strong> 18<br />
Financial Information<br />
This <strong>Item</strong> is not applicable as Rochdale uses Pershing LLC as its Qualified Custodian.<br />
24
<strong>Item</strong> 19<br />
Requirements for State-Registered Advisers<br />
This <strong>Item</strong> is not applicable.<br />
25
<strong>Part</strong> <strong>2A</strong> Appendix 1 <strong>of</strong> <strong>Form</strong> <strong>ADV</strong>: Wrap Fee Program <strong>Brochure</strong><br />
<strong>Item</strong> 1<br />
<strong>Cover</strong> <strong>Page</strong><br />
Rochdale Investment Mangement LLC<br />
570 Lexington Avenue, Floor 9<br />
New York, NY 10009<br />
Telephone: 212-702-3500<br />
Facsimile: 212-702-3535<br />
Internet: www.rochdale.com<br />
March 31, 2012<br />
This <strong>Brochure</strong> provides information about certain Comprehensive Investment Advisory Programs (“Wrap<br />
Programs”) available through Rochdale Investment Management, LLC (“Rochdale” or “Adviser”) and<br />
Rochdale’s qualifications and business practices. If you have any questions about the contents <strong>of</strong> this<br />
<strong>Brochure</strong>, please contact us by telephone at (212) 702-3500 or by email at bam@rochdale.com. The<br />
information in this <strong>Brochure</strong> has not been approved or verified by the United States Securities and<br />
Exchange Commission (the “SEC”) or by any state securities authority.<br />
Additional information about Rochdale also is available on the SEC’s website at<br />
www.adviserinfo.sec.gov.<br />
Rochdale is a registered investment adviser with the SEC. Registration <strong>of</strong> an investment adviser with the<br />
SEC or with any state securities authority does not imply any level <strong>of</strong> skill or training.<br />
i
<strong>Item</strong> 2 Material Changes<br />
Material Changes -- Rochdale continues to conduct its business activities and to provide investment<br />
advisory services in substantially the same manner as described in the <strong>Firm</strong>’s last update, which was<br />
made on March 28, 2012. This Wrap Fee <strong>Brochure</strong>, however, has been prepared in accordance with<br />
rules newly adopted by the Securities and Exchange Commission. Accordingly, the content and<br />
presentation <strong>of</strong> our <strong>Brochure</strong> is materially different from brochures used by Rochdale in prior years.<br />
ii
<strong>Item</strong> 3 Table <strong>of</strong> Contents<br />
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong>……………………………………………………………………….....i<br />
<strong>Item</strong> 2 Material Changes………………………………………………………………….ii<br />
<strong>Item</strong> 3 Table <strong>of</strong> Contents…………………………………………………………………iii<br />
<strong>Item</strong> 4 Services and Compensation………………………………………………………1<br />
<strong>Item</strong> 5 Account Requirements and Types <strong>of</strong> Clients…………………………………….5<br />
<strong>Item</strong> 6 Portfolio Manager Selection and Evaluation…………………………………….6<br />
<strong>Item</strong> 7 Client Information Provided to Portfolio Managers…………………………...10<br />
<strong>Item</strong> 8 Client Contact with Portfolio Managers………………………………………...11<br />
<strong>Item</strong> 9 Additional Information....………………………………………………………...12<br />
<strong>Item</strong> 10 Requirements for State Registered Investment Advisers………………………15<br />
iii
<strong>Item</strong> 4 Services, Fees and Compensation<br />
The Advisor’s Comprehensive Investment Advisory Programs (“Wrap Programs”) are advisory programs that<br />
bundle high net worth investment advisory services with brokerage services for a consolidated fee.<br />
Wrap Fee Services.<br />
Both the Wrap Program <strong>of</strong>fered directly through Rochdale (“Rochdale Wrap Program”) and the Wrap Fee<br />
Program provided through FCA Rochdale (“FCA Rochdale Wrap Program”), <strong>of</strong>fer continuous management <strong>of</strong><br />
client accounts (“Account(s)”) on a fully discretionary basis making all security purchase and sale decisions.<br />
Securities transactions are executed through Advisor’s brokerage affiliate, RIM Securities LLC (“RIM”), a<br />
member <strong>of</strong> the Financial Industry Regulatory Authority (“FINRA”). Clients participating in the Wrap Programs<br />
are required to direct the use <strong>of</strong> RIM as their broker/dealer. RIM clears all <strong>of</strong> its transactions on a fully<br />
disclosed basis through Pershing LLC (“Pershing”), but separate commissions are not charged for securities<br />
transactions under the Wrap Fee Programs. Pershing also serves as the custodian for all client Accounts that<br />
participate in the Wrap Fee Programs. Pershing provides account insurance coverage through the Securities<br />
Insurance Protection Corporation (“SIPC”) <strong>of</strong> up to $500,000 including up to $100,000 in cash. Additionally,<br />
Pershing has obtained excess account protection <strong>of</strong> up to an overall aggregate level <strong>of</strong> $1 billion, including up to<br />
$1.9 million in cash through Lloyd's <strong>of</strong> London<br />
In addition to actively managing client accounts, the Wrap Fee Programs <strong>of</strong>fer assistance to clients in setting<br />
investment objectives, as well as determining appropriate asset allocations. A variety <strong>of</strong> investment styles may<br />
be employed, with client consultation, with a view to establishing the investment style most appropriate for the<br />
client’s investment objectives. Nevertheless, there can be no guarantee that a client’s objectives will be<br />
achieved. FCA Rochdale Wrap Fee Program makes available to participating Accounts assistance in connection<br />
with specialized areas such as risk pr<strong>of</strong>iling, asset allocation, portfolio analysis, and insurance services.<br />
The Wrap Fee Programs also <strong>of</strong>fer the following services and reports:<br />
a) Meetings with Advisor’s Portfolio Managers;<br />
b) Confirmations provided by RIM through Pershing <strong>of</strong> all purchases and sales in the Account;<br />
c) Monthly statements provided by RIM through Pershing showing activity in the Account, securities held<br />
and month-end valuations;<br />
d) Detailed quarterly reports provided by Advisor/FCA Rochdale showing securities held and Account<br />
performance;<br />
e) A comprehensive year-end tax information statement (1099B, Div, Int.) provided by Pershing; and such<br />
other reports or information that Clients may reasonably request.<br />
Fee Schedules for Wrap Fee Programs.<br />
Advisor’s fee for its services under the Wrap Programs is based upon the market value <strong>of</strong> the assets in the<br />
Account determined as <strong>of</strong> the close <strong>of</strong> business on the last business day <strong>of</strong> the previous calendar quarter. Fee<br />
arrangements relating to the Rochdale Wrap Fee Program, including the applicable fee schedule, are set forth<br />
below.<br />
Annual Asset Value<br />
*Advisor Fee<br />
Portion <strong>of</strong><br />
Wrap<br />
Annual Asset Value<br />
**Transaction Fee<br />
Portion <strong>of</strong> Wrap<br />
First $750,000 to $1,000,000 1.00% $750,000 to $1,000,000 0.19%<br />
1
Next $1,000,000 to<br />
1.00% $1,000,000 to $2,000,000 0.14%<br />
$2,000,000<br />
Next $2,000,000 to<br />
0.80% $2,000,000 to $3,000,000 0.14%<br />
$3,000,000<br />
Next $3,000,000 to<br />
0.80% $3,000,000 to $5,000,000 0.09%<br />
$5,000,000<br />
Next $5,000,000 to<br />
0.60% $5,000,000 to $10,000,000 0.07%<br />
$10,000,000<br />
Next $10,000,000 and above 0.50% $10,000,000 and above 0.05%<br />
*The Investment Management Fee here<strong>of</strong> is based on a tiered schedule (cumulative). Therefore, at each level you<br />
will be charged the respective fee listed (e.g. on your first $2 million you will be charged 1.00%, on the next $3<br />
million you will be charged 0.80% etc.).<br />
**The Transaction Fee, although based on assets, is not based on a tiered schedule but fixed with respect to the<br />
aggregate assets in the Account. Therefore, if your account value is under $1 million, you will be charged 0.19%, if<br />
your account value is $1 million to $2 million, you will be charged 0.14% on the entire account and so forth.<br />
Under certain circumstances, the fees shown may be negotiated on a case-by-case basis and may be different<br />
from, but not higher than, the above schedule.<br />
Clients who participate in this program will not be charged commissions on a transaction by transaction basis in<br />
connection with purchases and sales for their Account(s). Securities transactions are effected “net,” i.e., without<br />
transaction based commissions, and a portion <strong>of</strong> the Wrap Fee is generally considered as being in lieu <strong>of</strong><br />
commissions. This program may cost the client more or less than if management fees and commissions were<br />
charged separately. Custody fees payable to Pershing are not separately charged to client Accounts under the<br />
Rochdale Wrap Fee Program. Client are responsible, however, for miscellaneous administrative fees that may<br />
charged by Pershing (e.g. retirement account custodial fees, safekeeping fees, wire transfer fees and any other<br />
administrative fees, a list <strong>of</strong> which is available upon request). Additionally, clients who are invested in any<br />
pooled investment vehicle or mutual fund will bear the expenses <strong>of</strong> that fund. Fund expenses vary depending<br />
upon the fund selected. (See, “Types <strong>of</strong> Investments” below.)<br />
FCA Rochdale Wrap Fee Program.<br />
The FCA Rochdale Wrap Fee Program provides a separate fee option, as set forth below:<br />
Account Asset Value<br />
Annual Fee to Client<br />
$1,000,000 to $2,000,000 2.10%<br />
$2,000,001 to $3,000,000 1.95%<br />
$3,000,001 to $4,000,000 1.90%<br />
$4,000,001 to $5,000,000 1.85%<br />
$5,000,001 to $7,000,000 1.50%<br />
$7,000,001 to $10,000,000 1.25%<br />
$10,000,001 to $15,000,000 1.15%<br />
$15,000,001 to $20,000,000 0.95%<br />
2
$20,000,000 and above 0.85%<br />
Under certain circumstances, the fees shown may be negotiated on a case-by-case basis and may be different<br />
from, but not higher than, the above schedule.<br />
Clients who participate in this program will be charged a single asset based fee; commissions on a transaction by<br />
transaction basis in connection with purchases and sales for their Account(s) will not be charged. Securities<br />
transactions are effected “net,” i.e., without transaction based commissions, and a portion <strong>of</strong> the Wrap Fee is<br />
generally considered as being in lieu <strong>of</strong> commissions. This program may cost the client more or less than if<br />
management fees and commissions were charged separately. Custody fees payable to Pershing are not<br />
separately charged to client Accounts. Client are responsible, however, for miscellaneous administrative fees<br />
that may charged by Pershing (e.g. retirement account custodial fees, safekeeping fees, wire transfer fees and any<br />
other administrative fees a list <strong>of</strong> which is available upon request). Additionally, clients who are invested in any<br />
pooled investment vehicle or mutual fund will bear the expenses <strong>of</strong> that fund. Fund expenses vary depending<br />
upon the fund selected. (See, “Types <strong>of</strong> Investments” below.)<br />
Types <strong>of</strong> Investments<br />
In providing services under the Wrap Fee Programs, Rochdale may invest in a variety <strong>of</strong> asset classes including<br />
large company, mid/small company, international and fixed income. Depending on the objectives <strong>of</strong> a particular<br />
client, Rochdale may recommend the use <strong>of</strong> various investment funds managed by Rochdale or its affiliates to<br />
capture potential return from specified assets classes. These funds include the several investment portfolios <strong>of</strong><br />
Rochdale Investment Trust, an open-end investment company registered under the Investment Company Act <strong>of</strong><br />
1940. As <strong>of</strong> the date <strong>of</strong> this update, these portfolios include: Rochdale Large Growth, Rochdale Large Value,<br />
Rochdale Dividend and Income, Rochdale Intermediate Fixed Income, Rochdale Emerging Markets and<br />
Rochdale Fixed Income Opportunities Portfolios (collectively "RIT Funds"). Rochdale also makes available to<br />
its clients, interests in other registered investment vehicles who satisfy the suitability requirements specified in<br />
<strong>of</strong>fering documents relating to such vehicles. As <strong>of</strong> the date <strong>of</strong> this <strong>Brochure</strong>, these include Rochdale Core<br />
Alternative Strategies Master Fund, Rochdale Core Alternative Strategies Fund and Rochdale Core Alternative<br />
Strategies Fund TEI (collectively "RCAS"), Rochdale International Trade Fixed Income Fund ("RITFI"),<br />
Rochdale Structured Claims Fixed Income Fund ("RSCFIF"), Rochdale Alternative Total Return Fund<br />
(“RATRF”) and Rochdale Royalty Rights Fund (“RRRF”). All <strong>of</strong> these vehicles are managed by Rochdale.<br />
Rochdale also makes available to its clients interests in other investment vehicles that are not registered under<br />
the Investment Company Act, who satisfy the suitability requirements specified in <strong>of</strong>fering documents relating to<br />
such vehicles. As <strong>of</strong> the date <strong>of</strong> this <strong>Brochure</strong>, these include Rochdale Offshore Global Opportunities Fund<br />
(“ROGOF), Rochdale Offshore Global Diversified Fund (“ROGDF”), Rochdale GML Trade Finance Income<br />
Fund, (“RGTFIF”) Rochdale Alternative Total Return Offshore Fund (RATROF) Rochdale Royalty Rights<br />
Offshore Fund (“RRROF”) and Long Point Investors. All <strong>of</strong> the RIT Funds, together with RCAS, RITFI,<br />
RSCFIF, RATRF, RRRF, ROGOF, ROGDF, RGTFIF, RRROF and RATROF (“Alternative Funds”) are<br />
collectively referred to as the “Funds". Rochdale may organize other investment funds in the future. Rochdale<br />
receives fees for services to such vehicles.<br />
General Information Regarding “Wrap fees” or “all-inclusive fees”<br />
In establishing the Wrap Fee schedules set forth above, Rochdale has taken into consideration a variety <strong>of</strong> factors<br />
including costs associated with investment management services, direct communication with the Portfolio<br />
Managers, detailed client reporting, custody <strong>of</strong> client assets through Pershing, as well as trading and clearing<br />
costs for trades executed through RIM. Depending, however, upon the level <strong>of</strong> the fee charged by Rochdale, the<br />
amount <strong>of</strong> portfolio activity in the client’s account, the value <strong>of</strong> custodial and other services which are provided<br />
under the arrangement, and other factors, the cost <strong>of</strong> participating in the Wrap Fee Program may exceed the<br />
aggregate cost <strong>of</strong> such services if they were to be separately purchased. Under the Wrap Fee Programs described<br />
3
above, securities transactions will be executed through RIM without commission. This may result in the receipt<br />
by the Advisor <strong>of</strong> investment advisory fees that are different than those received in connection with other<br />
investment advisory services provided by the Adviser and, in some cases, will be higher than fees paid by clients<br />
who bear their own commission costs. Similarly, fees retained by RIM may also be higher than those received<br />
under traditional commission based arrangements. This is so because RIM will receive a fee as described above<br />
regardless <strong>of</strong> the number <strong>of</strong> transactions performed during the quarter. In evaluating any wrap fee arrangement,<br />
a client should recognize that brokerage commissions or the execution terms <strong>of</strong> transactions in the client’s<br />
accounts are not negotiated by Advisor or FCA Rochdale. Although generally the best price can be <strong>of</strong>fered for<br />
listed transactions, no assurance can be given that such will continue to be the case.<br />
Rochdale acquires clients in a variety <strong>of</strong> ways. The majority <strong>of</strong> clients, including clients that participate in the<br />
Wrap Fee Programs, are introduced to Rochdale by affiliated and unaffiliated third parties, including<br />
independent financial planners, investment advisors, consultants, CPAs, attorneys, and representatives <strong>of</strong> brokerdealers<br />
(sometimes referred to as “Referring <strong>Part</strong>ners”). Referring <strong>Part</strong>ners may or may not provide services<br />
directly to clients and clients may be responsible for fees relating to any such services. Any such services are<br />
provided solely by Referring <strong>Part</strong>ners and not by, or on behalf <strong>of</strong>, Advisor. Additionally, Referring <strong>Part</strong>ners may<br />
be compensated for introductions to Rochdale. (See, <strong>Item</strong> 9 in this Wrap Fee <strong>Brochure</strong> for further information<br />
about the activities <strong>of</strong> Referring <strong>Part</strong>ners.)<br />
4
<strong>Item</strong> 5 Account Requirements and Types <strong>of</strong> Clients<br />
Rochdale’s clients consist primarily <strong>of</strong> individuals and pooled investment vehicles, such as the RIT Fund<br />
and the Alternative Funds. Other clients include institutional clients, such as pensions and pr<strong>of</strong>it sharing<br />
plans, charitable organizations and a limited number <strong>of</strong> municipalities. Rochdale generally requires a<br />
minimum <strong>of</strong> $1,000,000 <strong>of</strong> assets under management for a separately managed relationship, but may<br />
waive this minimum in its sole and absolute discretion. If the account size falls below the minimum<br />
requirement due to market fluctuations only, a client will not be required to invest additional funds with<br />
the Adviser to meet the minimum account size. With respect to investments in the RIT Funds or<br />
Alternative Funds, initial and additional subscription minimums are disclosed in the <strong>of</strong>fering documents<br />
relating to such funds.<br />
The Adviser may request clients to provide pro<strong>of</strong> <strong>of</strong> authority, directed trading letters, qualified client or<br />
qualified purchaser status, accredited investor certifications, and/or other information to allow the Adviser<br />
to manage client assets.<br />
5
<strong>Item</strong> 6 Portfolio Manager Selection and Evaluation<br />
All <strong>of</strong> the portfolio managers responsible for client Accounts that participate in the Wrap Fee Programs<br />
are Rochdale pr<strong>of</strong>essionals. Portfolio Managers are selected to handle Accounts based on Rochdale’s<br />
assessment <strong>of</strong> the client’s individual circumstances, taking into consideration such factors as the type <strong>of</strong><br />
client, age <strong>of</strong> the client, time horizon for investments, investment goals, cash flow needs, tax concerns and<br />
sensitivity to risk.<br />
Clients receive regular and continuous communications concerning the activity and status <strong>of</strong> their<br />
Accounts. Clients receive trade confirmations for every security transaction that occurs as well as a<br />
monthly summary account statement showing all activity in the account during the previous month as<br />
well as the month-end market value, in each case distributed by RIM Securities. In addition to this<br />
brokerage information, Rochdale provides a quarterly evaluation report that details the cost basis and<br />
current market value for each security in the portfolio and each asset class. This quarterly report also<br />
summarize gains, losses, income and expenses, and provides the time-weighted net return <strong>of</strong> the portfolio.<br />
Clients also have the ability to view their Accounts at Rochdale’s Web site, www.rochdale.com. Various<br />
other reports may also be made available through the Web site from time to time. In appropriate cases,<br />
and as directed by clients, Referring <strong>Part</strong>ners may receive copies <strong>of</strong> confirms, statements, and quarterly<br />
performance reports and may also be afforded access to portfolio managers assigned to specific client<br />
Accounts.<br />
In-person or telephonic conferences with clients are generally conducted at least annually. Clients are<br />
strongly encouraged to contact their portfolio manager directly; Rochdale also maintains a knowledgeable<br />
client service department with the capacity to answer a wide range <strong>of</strong> inquiries relating to the clients<br />
Accounts. Clients are also encouraged to notify Rochdale immediately, either through the client service<br />
department or by contact their portfolio manager, if there is any change in their investment objectives or<br />
financial condition.<br />
In general, Rochdale hires pr<strong>of</strong>essionals internally as portfolio managers on client accounts. Rochdale<br />
generally requires that portfolio managers hold an MBA (or equivalent advanced degree) and/or CFA (in<br />
most cases both) and have substantial industry experience. Portfolio managers are trained in all areas <strong>of</strong><br />
a client’s portfolio (stocks, bonds, alternatives). Therefore, a critical part <strong>of</strong> the Portfolio Manager<br />
selection process is based on individual style and compatibility with the client and, as a result. The<br />
performance <strong>of</strong> client portfolios is evaluated against appropriate benchmarks and Lipper averages for<br />
their specific securities class (Large Cap, Mid Small Cap, Fixed Income, Dividend & Income).<br />
Additionally, adherence to client established risk parameters are factors in performance expectations. An<br />
annual GIPS verification is conducted with respect to all equity portfolios and used in establishing the<br />
Adviser’s overall performance models.<br />
Securities positions are subject to constant re-evaluation and accounts are reviewed frequently on a not<br />
less than monthly basis. Review <strong>of</strong> portfolio management assignments and the handling <strong>of</strong> a client<br />
Account may be triggered by any one <strong>of</strong> a number <strong>of</strong> events including, but not limited to: 1) changes in<br />
general economic or investment market conditions; 2) a change in Rochdale’s portfolio strategy or its<br />
outlook regarding the prospects <strong>of</strong> a particular portfolio holding or the consideration <strong>of</strong> the purchase <strong>of</strong> a<br />
new portfolio holding; 3) changes in the client’s investment objectives or financial condition; and/or 4)<br />
the deposit or withdrawal <strong>of</strong> funds from a client’s Account. Consideration will be given to replacing a<br />
portfolio manager if it is determined that the client is not satisfied with the performance <strong>of</strong> the Account or<br />
level <strong>of</strong> service provided by the existing portfolio manager.<br />
6
Other Aspects <strong>of</strong> Rochdale’s Investment Advisory Business.<br />
Rochdale provides investment management programs other than the Wrap Fee Programs. Portfolio<br />
Managers responsible for Wrap Fee Accounts are also involved in providing investment management<br />
services to Accounts that are outside <strong>of</strong> the Wrap Fee Program. Advisory programs available through<br />
Rochdale are described below. In managing Accounts in the Wrap Fee Programs and in providing<br />
services in connection with the Advisory programs noted below, Rochdale seeks to intelligently<br />
personalize and customize client portfolios, based upon the individual circumstances and requirements <strong>of</strong><br />
the client and taking into consideration such factors as the type <strong>of</strong> client, age <strong>of</strong> the client, time horizon<br />
for investments, investment goals, cash flow needs, tax concerns and sensitivity to risk. Each is described<br />
in more detail in the Adviser’s “<strong>Firm</strong> <strong>Brochure</strong>.”<br />
Rochdale provides money management services to clients with portfolios <strong>of</strong> $1 million and above,<br />
primarily on a discretionary basis. Rochdale works with each client to determine their portfolio needs and<br />
limitations and designs an asset allocation and investment objective plan to meet their goals. Thereafter,<br />
Rochdale portfolio managers implement each plan, working directly with the client and their financial<br />
advisor, on a one-on-one basis. A typical client relationship will also have a third party financial advisor<br />
to assist the client through the implementation process and work with Rochdale with on-going portfolio<br />
management <strong>of</strong> the client’s assets. Rochdale intelligently personalizes and allows for customization <strong>of</strong><br />
client portfolios, based upon the individual circumstances and requirements <strong>of</strong> the client and taking into<br />
consideration such factors as the type <strong>of</strong> client, age <strong>of</strong> the client, time horizon for investments, investment<br />
goals, cash flow needs, tax concerns and sensitivity to risk. This includes working with a client’s already<br />
existing portfolio to build out an appropriate Rochdale portfolio (i.e. utilizing existing securities where<br />
appropriate), managing across multiple accounts (IRAs, trust, personal, joint, etc.), allowing clients to<br />
place restrictions on securities (industry, sector, etc.), or types <strong>of</strong> securities (options, derivatives, etc.) or<br />
investment strategies (Large Cap, international, alternative, etc.), and managing a client’s portfolio to<br />
meet a client’s specific distribution needs and tax goals. To the extent the client elects to invest in pooled<br />
vehicles to implement an asset allocation program, such restrictions may not be appropriate. Except for<br />
the portion <strong>of</strong> each client’s account that is invested in pooled vehicles, the account is managed separate<br />
from other clients <strong>of</strong> Rochdale (i.e., not commingled, securities are purchased in their personal accounts).<br />
• Money Management Program. Intelligently personalized and customized portfolio<br />
implementation and management for clients that meet Rochdale’s minimum net worth<br />
requirements ($1M portfolio value and above across all accounts managed).<br />
• FCA Rochdale Customized Advisory Services. Through its division, FCA Rochdale, Rochdale<br />
provides customized investment management services and coordinated oversight <strong>of</strong> HNW client's<br />
estate, business and benefits planning. As with the Money Management Program, clients who<br />
participate in this program generally have portfolios above $1M.<br />
• Galaxy TM Asset Allocation Program (“GAAP”). Clients electing to participate in this program<br />
will have their accounts managed by way <strong>of</strong> Rochdale's proprietary Galaxy TM Asset Allocation<br />
Program ("GAAP"). These are clients that generally do not meet the dollar threshold <strong>of</strong> the<br />
programs above (with some exceptions). GAAP enables risk pr<strong>of</strong>iling, target asset class<br />
allocation, standard mutual fund implementation <strong>of</strong> target asset class allocation, customization <strong>of</strong><br />
mutual fund implementation, proposal generation, portfolio implementation based on<br />
implementation model, and portfolio management through periodic and/or event driven<br />
rebalancing. Some <strong>of</strong> the Funds are managed by Rochdale, which receives investment advisory<br />
7
fees for such services. Rochdale may utilize GAAP directly with its mid net worth clients for<br />
which it has entered into an investment advisory relationship directly through Rochdale, an<br />
affiliated adviser, or through access provided by another broker dealer or registered investment<br />
adviser that has entered into an agreement with Rochdale to <strong>of</strong>fer GAAP on their platform.<br />
Rochdale charges a flat platform fee <strong>of</strong> between 25 and 35 basis points, depending on the account<br />
value, for use <strong>of</strong> this service.<br />
• Sub-advisory Services. Rochdale also provides investment advisory services to the RIT Funds<br />
and the Alternative Funds. A small percentage <strong>of</strong> Rochdale’s assets under management are<br />
represented by sub-advisory relationships. Where Rochdale acts as a sub-advisor, Rochdale is<br />
retained by an investment advisor who, in turn, has entered into a contract directly with the client.<br />
Under a sub-advisory arrangement, Rochdale may have limited contact with clients and will<br />
manage accounts according to the instructions <strong>of</strong> the investment adviser who has retained<br />
Rochdale to act in a sub-advisory capacity.<br />
None <strong>of</strong> the investment advisory programs <strong>of</strong>fered by Rochdale involve receipt <strong>of</strong> performance fees or<br />
other incentive compensation. Rochdale does provide investment advisory services to certain pooled<br />
investment vehicles and, in connection with such services, may receive performance compensation if<br />
certain minimum performance benchmarks are met. These arrangements do not, however result in the<br />
receipt by any Rochdale employee <strong>of</strong> performance or incentive compensation and, accordingly, Rochdale<br />
does not believe that these arrangements give rise to any conflict <strong>of</strong> interest or <strong>of</strong>fer any incentive for any<br />
<strong>of</strong> the firm’s investment personnel, including the portfolio manager responsible for managing client<br />
Accounts in the Wrap Fee Program to favor any vehicle over any other Account.<br />
Methods <strong>of</strong> Analysis, Investment Strategies and Risk <strong>of</strong> Loss<br />
The Adviser utilizes a variety <strong>of</strong> methods and strategies to make investment decisions and<br />
recommendations in connection with client Accounts in the Wrap Fee Program, as well as in connection<br />
with other investment advisory programs. These methods entail an evaluation <strong>of</strong> investment<br />
opportunities using fundamental, technical, quantitative and qualitative analyses to determine the intrinsic<br />
value <strong>of</strong> securities and other types <strong>of</strong> instruments. These methods, strategies and investments involve risk<br />
<strong>of</strong> loss to clients and clients must be prepared to bear the loss <strong>of</strong> their entire contribution/investment. The<br />
Adviser employs the following investment strategies:<br />
Dynamic Equity Risk Management. The Adviser engages in a Dynamic Equity Risk Management<br />
investment strategy wherein the Adviser is allowed to manage excessive and extreme risk as it relates to<br />
individual client risk pr<strong>of</strong>iles. The Adviser manages portfolio risks proactively to avoid historical Buy &<br />
Hold traps. As well as relating client specific Investment Policy Statement goals to Rochdale’s portfolio<br />
strategy, recession monitor and fundamental outlook.<br />
Equity. The Adviser’s equity strategy focuses on a broad range <strong>of</strong> equity investment styles, including<br />
growth, core, and value, as well as portfolios designed to be “style-neutral”. Some client accounts focus<br />
on specific ranges on the capitalization scale, from micro-cap, through small-cap, mid-cap and large-cap,<br />
to mega-cap. Other client accounts will focus on investment opportunities in more than one capitalization<br />
category or across all capitalization levels.<br />
Fundamental Value. The Adviser engages in a fundamental value investment strategy wherein the<br />
Adviser attempts to invest in asset-oriented securities the Adviser believes are undervalued by the market.<br />
Growth. The Adviser engages in a growth investment strategy wherein the Adviser attempts to select<br />
8
securities <strong>of</strong> a company whose earnings the Adviser expects to grow at an above-average rate compared<br />
to the company’s specific industry or the overall market.<br />
Hedging. The Adviser utilizes a variety <strong>of</strong> financial instruments such as derivatives and options for risk<br />
management purposes.<br />
Relative Value. The Adviser pursues relative value strategies by taking long positions in securities<br />
believed to be undervalued.<br />
High Dividend and Income. The Adviser pursues high dividend and income strategies by taking long<br />
positions in company with high dividend growth potential.<br />
Galaxy TM . The Adviser using a proprietary modeling system to design asset allocation models specific to<br />
a client’s risk return requirements. Please refer to the description <strong>of</strong> Galaxy. TM above.<br />
Voting Client Securities<br />
As a registered investment adviser with the SEC, Rochdale owes its clients a duty <strong>of</strong> care and a duty <strong>of</strong><br />
loyalty at all times. This means that if granted the authority to vote proxies, Rochdale must always vote in its<br />
clients’ best interest. Rochdale must maintain copies <strong>of</strong> all proxy votes cast on client’s behalf and will<br />
provide this information upon request. Upon opening an account with Rochdale, clients are given the option<br />
to delegate proxy-voting discretion to Rochdale by completing the appropriate documents. Rochdale will<br />
only exercise proxy-voting discretion over the client shares in the instances where clients give Rochdale<br />
discretionary authority to vote on their behalf. When voting on behalf <strong>of</strong> clients, Rochdale currently utilizes<br />
the services <strong>of</strong> a neutral third party proxy voting service. This service provides Rochdale with a neutral<br />
recommendation on how a client's proxy should be voted. In most instances, Rochdale will cast client’s votes<br />
in accordance with their recommendation. However, in the event Rochdale feels that the suggestion provided<br />
by the proxy voting service is not in the clients’ best interest, Rochdale may vote against such<br />
recommendation. In the instance Rochdale decides not to go with the recommendation provided, Rochdale<br />
shall keep an internal memorandum detailing its reasons for doing so. Rochdale also has authorization to<br />
vote the underlying shares <strong>of</strong> Rochdale Investment Trust. Clients may obtain a copy <strong>of</strong> the Adviser’s proxy<br />
voting policies and procedures and information about how the Adviser voted a client’s proxies by contacting<br />
Barbara Hawkesworth (Chief Compliance Officer) by email at bam@rochdale.com or by telephone at (212)<br />
702-3500.<br />
9
<strong>Item</strong> 7 Client Information Provided to Portfolio Managers<br />
Each client fills out a comprehensive questionnaire and provides pro<strong>of</strong> <strong>of</strong> financial means. Information<br />
regarding each client’s risk tolerance and financial well being is documented and followed closely. As<br />
well each client is contacted on a regular basis to determine how to proceed in the future. As indicated<br />
above, In-person or telephonic conferences with clients are generally conducted at least annually. Clients<br />
are strongly encouraged to contact their portfolio manager directly; Rochdale also maintains a<br />
knowledgeable client service department with the capacity to answer a wide range <strong>of</strong> inquiries relating to<br />
the client’s Accounts. Clients are also encouraged to notify Rochdale immediately, either through the<br />
client service department or by contacting their portfolio manager, if there is any change in their<br />
investment objectives or financial condition.<br />
10
<strong>Item</strong> 8 Client Contact with Portfolio Managers<br />
Clients are strongly encouraged to contact their portfolio managers directly and portfolio managers are<br />
available during business hours: Rochdale imposes no additional restriction or limitation on a client’s<br />
access to their portfolio mangers. Rochdale also maintains a knowledgeable client service department<br />
with the capacity to answer a wide range <strong>of</strong> inquiries relating to the client’s Accounts, current investments<br />
or Rochdale’s overall investment philosophy. Clients are also encouraged to notify Rochdale<br />
immediately, either through the client service department or by contacting their portfolio manager, if there<br />
is any change in their investment objectives or financial condition.<br />
11
<strong>Item</strong> 9 Additional Information<br />
Disciplinary Information -- Neither Rochdale nor any <strong>of</strong> its employees have been involved in any legal<br />
or disciplinary events in the past 10 years that would be material to a client’s evaluation <strong>of</strong> the company<br />
or its personnel.<br />
Other Financial Industry Activities and Affiliations -- Certain <strong>of</strong>ficers and/or directors associated with<br />
Rochdale serve as <strong>of</strong>ficers, directors, analysts and/or portfolio managers <strong>of</strong> one or more the following<br />
entities: Rochdale Investment Management, an SEC registered investment advisor, Symphonic Financial<br />
Advisors LLC, an SEC registered investment adviser, Symphonic Securities LLC, a FINRA registered<br />
broker/dealer, Symphonic Insurance LLC, a state registered insurance agency and/or RIM Securities<br />
LLC, a FINRA registered broker/dealer. Rochdale’s relationship as an investment advisor to the several<br />
Alternative Funds and to RIT Funds are material to Rochdale’s advisory business. As described above,<br />
clients may invest in RIT Funds and/or Alternative Funds. Rochdale and/or its <strong>of</strong>ficers, employees and<br />
directors may also be investors in these vehicles. Although there is some potential for conflict <strong>of</strong> interest,<br />
Rochdale believes these are not material in light <strong>of</strong> the requirements <strong>of</strong> the Code <strong>of</strong> Ethics adopted by<br />
Rochdale and in light <strong>of</strong> the fact that, to the extent that Rochdale or any employee, director or <strong>of</strong>ficer is an<br />
investor in RIT Funds or Alternative fund, each shares in any gains or losses proportionally with all other<br />
investors.<br />
Code <strong>of</strong> Ethics, <strong>Part</strong>icipation or Interest in Client Transaction and Personal Trading -- Rochdale has<br />
adopted a Code <strong>of</strong> Ethics (the "Code") expressing the firm's commitment to ethical conduct. Rochdale's<br />
Code <strong>of</strong> Ethics describes the firm's fiduciary duties and responsibilities to clients (which includes<br />
Rochdale Investment Trust, Rochdale Core Alternative Strategies Fund, Rochdale International Trade<br />
Fixed Income Fund, Rochdale Structured Claims Fixed Income Fund, RIM Securities LLC, Symphonic<br />
Financial Advisors LLC, Symphonic Securities LLC and Symphonic Insurance LLC), and sets forth the<br />
practice <strong>of</strong> supervising personal securities transactions <strong>of</strong> employees. Individuals associated with<br />
Rochdale may buy or sell securities for their personal accounts identical to or different than those<br />
recommended to clients. It is the expressed policy <strong>of</strong> Rochdale that no person employed by Rochdale<br />
shall prefer his or her own interest to that <strong>of</strong> an advisory client or make personal investment decisions<br />
based on the investment decisions <strong>of</strong> advisory clients.<br />
To supervise compliance with the Code, Rochdale requires that employees with access to advisory<br />
recommendations, or other inside information provide quarterly securities holdings reports and quarterly<br />
transactions reports to the Compliance Department. Rochdale also requires all such employees receive<br />
prior approval from the Compliance Department prior to effecting transactions meeting certain criteria.<br />
All individuals employed by or affiliated with Rochdale must sign, no less than annually, an attestation<br />
confirming their receipt and comprehension <strong>of</strong> the Code.<br />
Rochdale requires that all individuals must act in accordance with all applicable federal and state<br />
regulations governing registered investment advisory, broker dealer or other pr<strong>of</strong>essional designation<br />
practices. Rochdale's Code further includes the firm's policy prohibiting the use <strong>of</strong> material non-public<br />
information. Any individual not in observance <strong>of</strong> the Code may be subject to discipline. Rochdale will<br />
provide a complete copy <strong>of</strong> its Code <strong>of</strong> Ethics to any client upon request.<br />
Client Transactions in Securities where Adviser has a Material Financial Interest -- Rochdale has<br />
discretionary authority over its clients' investment accounts and initiates the transactions in such accounts.<br />
12
RIM receives commissions for executing transactions for most <strong>of</strong> Rochdale’s clients. These commissions<br />
are assessed at rates which are believed to be competitive with those charged by the major national<br />
discount brokerage firms. Rochdale follows specific procedures to assure that its fiduciary<br />
responsibilities are carried out with the highest degree <strong>of</strong> care and pr<strong>of</strong>essionalism.<br />
Rochdale and RIM may, from time to time, facilitate the purchase and sale <strong>of</strong> a security between two or<br />
more clients without either Rochdale or RIM being the seller or the buyer. This is known as an "internal<br />
cross" transaction and is only performed under client authorization. Prior to engaging in an internal cross<br />
transaction, Rochdale and RIM will ensure that the transaction is in the best interest <strong>of</strong> all client parties<br />
involved by ensuring the price is fair, and properly disclosing all known potential conflicts. Neither<br />
Rochdale nor its affiliates will receive compensation for effecting internal cross transactions.<br />
Rochdale and RIM may, from time to time, enter into transactions where client securities are purchased<br />
from or sold to brokerage customers <strong>of</strong> RIM in what is known as an "agency cross" transaction.<br />
Rochdale or RIM will engage in these cross transactions when it is determined that doing so may provide<br />
a better execution opportunity though such a result is not guaranteed. If an agency cross transaction<br />
occurs, RIM may receive commissions from both sides <strong>of</strong> the transaction. Due to the method <strong>of</strong> trade<br />
execution for an agency cross transaction, there is a potential conflicting division <strong>of</strong> loyalties and<br />
responsibilities. In no event will Rochdale or RIM act as a principal in such transactions.<br />
Investing in Securities Recommended to Clients -- Rochdale and/or related persons may purchase, sell<br />
or hold positions in certain investments that are recommended to, or implemented for, any <strong>of</strong> its clients.<br />
If Rochdale holds securities for itself that it also recommends to or implements for clients, the following<br />
restrictions and disclosure procedures are maintained for the protection <strong>of</strong> clients:<br />
• Rochdale will recommend to or implement for its clients the purchase or sale <strong>of</strong> the same<br />
securities held, purchased or sold by Rochdale or any associated person only if such transaction<br />
is consistent with the objectives <strong>of</strong> the client.<br />
• The clients' interest will be placed before Rochdale in such purchases and sales to assure<br />
that, on any given day, (a) the timing <strong>of</strong> the transaction will not put the client at a disadvantage,<br />
and (b) the price obtained for the client will be the same or more advantageous than that<br />
obtained for Rochdale or any associated person.<br />
• Employees deemed to have knowledge <strong>of</strong> client trading activities will be regarded as<br />
“Trust Access” persons and will be required to gain approval for all securities transactions.<br />
Review <strong>of</strong> Accounts -- Each client account is reviewed by their portfolio manager or his designee on an<br />
ongoing and regular basis to determine whether securities positions should be maintained in view <strong>of</strong><br />
current market conditions. Matters reviewed include specific securities held, adherence to investment<br />
guidelines and the performance <strong>of</strong> each client account. Factors prompting an immediate review <strong>of</strong><br />
Accounts include significant market events affecting the prices <strong>of</strong> one or more securities in clients<br />
accounts, changes in the investment objectives or guidelines <strong>of</strong> a particular client, or specific<br />
arrangements with particular clients may trigger reviews <strong>of</strong> a client’s Accounts on an immediate basis.<br />
Clients receive regular and continuous communications concerning the activity and status <strong>of</strong> their<br />
Accounts. Clients receive trade confirmations for every security transaction that occurs, as well as a<br />
monthly summary account statement, showing all activity in the account during the previous month as<br />
13
well as the month-end market value, in each case distributed by RIM. In addition to this brokerage<br />
information, Rochdale provides a quarterly evaluation report that details the cost basis and current market<br />
value for each security in the portfolio and each asset class. This quarterly report also summarize gains,<br />
losses, income and expenses, and provides the time-weighted net return <strong>of</strong> the portfolio. Clients also have<br />
the ability to view their Accounts at Rochdale’s Web site, www.rochdale.com. Various other reports may<br />
also be made available through the Web site from time to time. In appropriate cases, and as directed by<br />
clients, Referring <strong>Part</strong>ners may receive copies <strong>of</strong> confirms, statements, and quarterly performance reports<br />
and may also be afforded access to portfolio managers assigned to specific client Accounts.<br />
Client Referrals and Other Compensation -- Rochdale may make cash payments to third-party<br />
solicitors for client referrals, provided that, to the extent required, each such solicitor has entered into a<br />
written agreement with the Adviser pursuant to which the solicitor will provide each prospective client<br />
with a copy <strong>of</strong> Rochdale’s <strong>Form</strong> <strong>ADV</strong> <strong>Part</strong> 2, and a disclosure document setting forth the terms <strong>of</strong> the<br />
solicitation arrangement, including the nature <strong>of</strong> the relationship between the solicitor and Rochdale and<br />
any fees to be paid to the solicitor. Where applicable, cash payments for client solicitations will be<br />
structured to comply fully with the requirements <strong>of</strong> Rule 206(4)-3 under the Investment Advisers Act <strong>of</strong><br />
1940, as amended, and related SEC staff interpretations.<br />
The majority <strong>of</strong> clients are introduced to Rochdale by affiliated and unaffiliated third parties including<br />
independent financial planners, investment advisors, consultants, CPAs, attorneys, and representatives <strong>of</strong><br />
broker-dealers (previously referred to in this Wrap Fee <strong>Brochure</strong> as “Referring <strong>Part</strong>ners”). Clients<br />
referred to Rochdale by a Referring <strong>Part</strong>ner, enter into an investment advisory contract directly with<br />
Rochdale. Referring <strong>Part</strong>ners may provide to client (but are not required by Rochdale to do so) other<br />
services such as researching money management services, assisting clients with financial planning and<br />
investment objective-setting, coordinating communications between the client and the manager, and<br />
monitoring performance and other such services to insure that clients’ needs are being met. Referring<br />
<strong>Part</strong>ners may or may not provide these services and clients should review with Referring <strong>Part</strong>ners those<br />
Additional Services that are being provided by Referring <strong>Part</strong>ners and the fee assessed for those<br />
Additional Services, which may be deducted by Rochdale for remittance to Referring <strong>Part</strong>ners. Any such<br />
services are provided solely by Referring <strong>Part</strong>ners and not by, or on behalf <strong>of</strong>, Rochdale. Referring<br />
<strong>Part</strong>ners charge a fee in addition to Rochdale fees.<br />
Financial Information – Not Applicable.<br />
14
<strong>Item</strong> 10 Requirements for State-Registered Advisers<br />
Not applicable<br />
15
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
<strong>Part</strong> 2B <strong>of</strong> <strong>Form</strong> <strong>ADV</strong>: <strong>Brochure</strong> Supplement<br />
Carl Acebes<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Carl Acebes that supplements Rochdale Investment<br />
Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that brochure. Please<br />
contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not receive Rochdale’s<br />
disclosure brochure or if you have any questions about the contents <strong>of</strong> this supplement.<br />
Additional information about Carl Acebes is available on the SEC’s website at www.adviserinfo.sec.gov
Carl Acebes (Year <strong>of</strong> birth – 1946)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Acebes studied engineering at Cornell University and economics at Columbia University.<br />
Mr. Acebes is the Chairman and Co-Chief Investment Officer <strong>of</strong> Rochdale and its affiliated entities, RIM Securities,<br />
Symphonic Financial Advisors LLC and Symphonic Securities LLC. Mr. Acebes also serves as Chairman and as<br />
Portfolio Manager to the majority <strong>of</strong> the funds <strong>of</strong> Rochdale Investment Trust.<br />
On or about July 1986, Mr. Acebes became a member <strong>of</strong> the Board <strong>of</strong> Directors <strong>of</strong> Rochdale Investment<br />
Management Inc. and the Director <strong>of</strong> Research for Rochdale. He was also the President and Chief Executive Officer,<br />
Chief Financial Officer and Director <strong>of</strong> Rochdale Securities Corporation. Mr. Acebes also serves as Chairman <strong>of</strong> the<br />
Board <strong>of</strong> Rochdale Corporation, Rochdale Alternative Strategies Fund, Rochdale International Trade Fixed Income<br />
Fund, Rochdale Structured Claims Fixed Income Fund and Rochdale Alternative Total Return Fund.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Acebes.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Acebes is a controlling owner <strong>of</strong> a holding company Rochdale Corporation that is a part owner <strong>of</strong> an<br />
institutional trading firm where the holding company receives earnings as well as a consultant fee.<br />
Mr. Acebes is also an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong><br />
Rochdale and affiliates, thus Mr. Acebes receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
As an owner, Mr. Acebes also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale Investment Trust’s Board <strong>of</strong> Directors, Chief Executive Officer Garrett D’ Alessandro and Chief<br />
Compliance Officer, Barbara Hawkesworth, Esq. supervise and monitor the activities <strong>of</strong> Mr. Acebes as it relates to<br />
the <strong>Firm</strong> and its clients. Such is done through various channels including the review <strong>of</strong> documents related to his<br />
clients and monitoring <strong>of</strong> accounts through automated reports generated directly to the Compliance Department.<br />
The <strong>Firm</strong>’s Chief Compliance Officer, Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Garrett R. D’Alessandro, CFA, CAIA, AIF®<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Garrett R. D’Alessandro that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Garrett R. D’Alessandro is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Garrett R. D’Alessandro, CFA, CAIA, AIF® (Year <strong>of</strong> birth – 1957)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. D'Alessandro received his Bachelor <strong>of</strong> Science degree from Montclair State University and his Master’s <strong>of</strong><br />
Business Administration in finance from New York University’s Stern School <strong>of</strong> Business.<br />
Mr. D’Alessandro is the President, Chief Executive Officer (“CEO”) and Co-Chief Investment Officer <strong>of</strong> Rochdale.<br />
He is also the CEO and President <strong>of</strong> Rochdale’s affiliated entities, Rim Securities LLC, Symphonic Financial<br />
Advisors LLC and Symphonic Securities LLC. Mr. D'Alessandro also serves on the Board <strong>of</strong> Directors <strong>of</strong> these<br />
organizations.<br />
Mr. D'Alessandro also serves as the President <strong>of</strong> Rochdale Core Alternative Strategies Fund, Rochdale International<br />
Trade Fixed Income Fund, Rochdale Structured Claims Fixed Income Fund and Rochdale Alternative Total Return<br />
Fund.<br />
Mr. D'Alessandro joined these organizations in 1986. Since 1998 he also serves as President <strong>of</strong> Rochdale Investment<br />
Trust (the “Trust”), and as Portfolio Manager to all funds <strong>of</strong> the Trust.<br />
Prior to joining Rochdale Mr. D'Alessandro was a Vice President and Controller <strong>of</strong> Yipkon Corporation, a New<br />
Jersey based computer company and an audit manager and Certified Public Accountant with Peat Marwick Mitchell<br />
& Co., a public accounting firm.<br />
Mr. D'Alessandro holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the<br />
CFA Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional<br />
experience involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work<br />
experience. It is a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All<br />
three levels are then achieved through a course exam. There are no continuing education requirements.<br />
Mr. D’Alessandro holds the Chartered Alternative Investment Analyst (“CAIA”) designation. This designation is<br />
issued by the CAIA Association. The prerequisites or experience required is over one year <strong>of</strong> pr<strong>of</strong>essional<br />
experience and a U.S. bachelor’s degree (or equivalent) or four years <strong>of</strong> pr<strong>of</strong>essional experience. CAIA candidates<br />
must pass both Level I and Level II <strong>of</strong> the CAIA exam to qualify for the designation. Qualifying candidates must<br />
complete the online Member Agreement, provide two pr<strong>of</strong>essional references, and submit annual membership dues.<br />
Mr. D’Alessandro holds the Accredited Investment Fiduciary® (“AIF®”) designation. AIF® designees have<br />
successfully completed a specialized program on investment fiduciary standards <strong>of</strong> care. After the training program<br />
they must successfully pass an examination, conform to a code <strong>of</strong> ethics and complete 6 hours <strong>of</strong> continuing<br />
education requirements on a yearly basis.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. D’Alessandro.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. D’Alessandro is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong><br />
Rochdale and affiliates, thus Mr. D’Alessandro receives a portion <strong>of</strong> ADA’s earnings.
<strong>Item</strong> 5 Additional Compensation<br />
As an owner, Mr. D’Alessandro also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale Investment Trust’s Board <strong>of</strong> Directors, including Chairman Carl Acebes, and Chief Compliance Officer<br />
Barbara Hawkesworth, Esq. supervise and monitor the activities <strong>of</strong> Mr. D’Alessandro relative to the <strong>Firm</strong> and its<br />
clients. Such is done through various channels including the review <strong>of</strong> documents related to his clients and<br />
monitoring <strong>of</strong> accounts through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s<br />
Chief Compliance Officer, Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
John T. Buckley, CFA<br />
Rochdale Investment Management<br />
455 Market Street, Suite 970<br />
San Francisco, CA 94105<br />
(415) 477-2544<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about John T. Buckley that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about John T. Buckley is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
John T. Buckley, CFA (Year <strong>of</strong> birth – 1961)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Buckley received his Bachelor <strong>of</strong> Science degree from the University <strong>of</strong> California at Davis and his Master’s <strong>of</strong><br />
Business Administration from the University <strong>of</strong> California at Berkeley.<br />
Mr. Buckley joined Rochdale in 1994 as Regional Marketing Director for the western region <strong>of</strong> the country, and was<br />
subsequently promoted to Vice President in 1995 and Senior Vice President in January 2000. In his current role as<br />
Executive Vice President and Western Regional Director, Mr. Buckley is responsible for all business development<br />
activities for Rochdale in the western half <strong>of</strong> the United States.<br />
For the five years prior to joining Rochdale, Mr. Buckley was Vice President and Senior Vice President for<br />
Liquidity Fund Investment Corp., an investment manager specializing in real estate securities and a pioneer in the<br />
secondary market for partnership units. Mr. Buckley is also a member <strong>of</strong> The Security Analysts <strong>of</strong> San Francisco.<br />
Mr. Buckley holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Buckley.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Buckley is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale<br />
and affiliates, thus Mr. Buckley receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Buckley may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Mr. Buckley may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Mr. Buckley also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Buckley as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
David M. Coiro<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about David M. Coiro that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about David M. Coiro is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
David M. Coiro (Year <strong>of</strong> birth – 1946)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Coiro received his Bachelor <strong>of</strong> Science degree from Boston College and studied developmental economics at<br />
Georgetown University's graduate school.<br />
In July 1986, Mr. Coiro became Vice President and Senior Portfolio Manager at Rochdale. Mr. Coiro joined<br />
Rochdale in 1983. He has thirty-six years <strong>of</strong> diversified investment management experience.<br />
Mr. Coiro began his career in 1973 in Washington, D.C., with the New York Stock Exchange member firm Folger,<br />
Nolan Fleming, Douglas, where he gained valuable experience trading municipal bonds and working with<br />
substantial institutional investors. In 1979, he joined R.W. Corby & Co., a prominent Washington investment<br />
banking and institutional municipal bond firm, where he expanded his interests and experience in private and limited<br />
partnership investments. He led and participated in the organization and financing <strong>of</strong> several private investments.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Coiro.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Coiro is a part owner <strong>of</strong> a holding company Rochdale Corporation that is a part owner <strong>of</strong> an institutional trading<br />
firm where the holding company receives earnings as well as a consultant fee.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Coiro may receive additional compensation from the firm based on the assets he brings to<br />
the firm and the fees collected by the firm on those assets. Mr. Coiro may also receive compensation from fees<br />
collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Coiro as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Neal Rubin<br />
Rochdale Offshore Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Neal Rubin that supplements Rochdale Investment<br />
Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that brochure. Please<br />
contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not receive Rochdale’s<br />
disclosure brochure or if you have any questions about the contents <strong>of</strong> this supplement.<br />
Additional information about Neal Rubin is available on the SEC’s website at www.adviserinfo.sec.gov
Neal Rubin (Year <strong>of</strong> birth – 1956)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Rubin received his Bachelor <strong>of</strong> Arts degree in Economics from Brandeis University and his Master’s <strong>of</strong><br />
Business Administration from Harvard Business School.<br />
Mr. Rubin is a Managing Director <strong>of</strong> Rochdale Offshore Investment Management ("ROIM"), a division <strong>of</strong><br />
Rochdale. Mr. Rubin joined Rochdale in 2004.<br />
Prior to joining Rochdale, Mr. Rubin was employed by Credit Suisse Private Advisors as Director National Sales<br />
Manager North America.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Rubin.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Rubin is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale and<br />
affiliates, thus Mr. Rubin receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Rubin may receive compensation based on the total assets he manages or generates and the management fees<br />
generated by those accounts. In addition, Mr. Rubin may also receive compensation from fees collected from<br />
Rochdale products.<br />
As an owner, Mr. Ruben also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Rubin as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Jeffrey L. Gage, AIF®<br />
FCA Rochdale<br />
10220 River Road, Suite 105<br />
Potomac, MD 20854<br />
(301) 983-8898<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Jeffrey L. Gage that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Jeffrey L. Gage is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Jeffrey L. Gage, AIF® (Year <strong>of</strong> birth – 1960)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Gage received his Artium Baccalaureus degree in engineering from Lafayette College.<br />
Mr. Gage is the President <strong>of</strong> FCA Rochdale and a Senior Vice President <strong>of</strong> Rochdale. He brings to Rochdale over 25<br />
years <strong>of</strong> expertise managing sophisticated clients using a comprehensive HNW service.<br />
Mr. Gage began his career with Peat Marwick Mitchell & Company and Cigna Financial Services before founding<br />
his own firm, FCA, in 1992. Mr. Gage has been president and owner <strong>of</strong> FCA since its founding. He is also a<br />
designated FINRA expert witness.<br />
Mr. Gage holds the Accredited Investment Fiduciary® (“AIF®”) designation. AIF® designees have successfully<br />
completed a specialized program on investment fiduciary standards <strong>of</strong> care. After the training program they must<br />
successfully pass an examination, conform to a code <strong>of</strong> ethics and complete 6 hours <strong>of</strong> continuing education<br />
requirements on a yearly basis.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Gage.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Gage is also the sole owner <strong>of</strong> FCA Associates LLC where he provides insurance and financial planning<br />
services to which he collects fees.<br />
Mr. Gage is also an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale<br />
and affiliates, thus Mr. Gage receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Gage may receive compensation based on the total assets he manages or generates and the management fees<br />
generated by those accounts.<br />
As an owner, Mr. Gage also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Gage as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including compliance meetings and reviews <strong>of</strong> documents related to his clients and monitoring <strong>of</strong><br />
accounts through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief<br />
Compliance Officer, Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Ted Cox, CFA<br />
Rochdale Investment Management<br />
7275 Glen forest Drive, Suite 205<br />
Richmond, VA 23226<br />
(804) 282-3022<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Ted Cox that supplements Rochdale Investment<br />
Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that brochure. Please<br />
contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not receive Rochdale’s<br />
disclosure brochure or if you have any questions about the contents <strong>of</strong> this supplement.<br />
Additional information about Ted Cox is available on the SEC’s website at www.adviserinfo.sec.gov
Ted Cox, CFA (Year <strong>of</strong> birth – 1966)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Cox received his Bachelor <strong>of</strong> Arts degree from Cornell University and his Master’s <strong>of</strong> Business Administration<br />
from Columbia University.<br />
Mr. Cox, currently a Senior Vice President – Investment Consulting, joined Rochdale in 2001 and has 20 years <strong>of</strong><br />
diversified financial industry experience. Located in Richmond, VA, he is responsible for business development<br />
throughout the Southeast.<br />
Prior to Rochdale, Mr. Cox spent twelve years at Marsh & McLennan as a managing account executive in the<br />
reinsurance division. In this role, Mr. Cox was an advisor to senior executives <strong>of</strong> client insurance companies on<br />
financial management strategies.<br />
Mr. Cox holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Cox.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Cox is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale and<br />
affiliates, thus Mr. Cox receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Cox may receive additional compensation from the firm based on the assets he brings to<br />
the firm and the fees collected by the firm on those assets. Mr. Cox may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Mr. Cox also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Cox as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
John T. Fulgham, AIF®<br />
Rochdale Investment Management<br />
605 Crescent Executive Drive, Suite 320<br />
Lake Mary, FL 32746<br />
(407) 333-1677<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about John T. Fulgham that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about John T. Fulgham is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
John T. Fulgham, AIF® (Year <strong>of</strong> birth – 1956)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Fulgham received both a Bachelor <strong>of</strong> Science and a Master’s <strong>of</strong> Business Administration from California Coast<br />
University.<br />
Mr. Fulgham joined Rochdale in 2004 and has seventeen years <strong>of</strong> experience in financial planning and personal<br />
asset management. He currently serves as the Regional Vice President, Florida/Midwest Regions.<br />
Mr. Fulgham’s previous positions include Financial Consultant with Merrill Lynch and senior level positions in the<br />
Private Banking and Wealth Management Groups <strong>of</strong> First Union National Bank, SunTrust Bank, and Bank <strong>of</strong><br />
America. Prior to embarking on a career in wealth management, Mr. Fulgham was a pr<strong>of</strong>essional athlete with the<br />
St. Louis Cardinals baseball team.<br />
Mr. Fulgham holds the Accredited Investment Fiduciary® (“AIF®”) designation. AIF® designees have successfully<br />
completed a specialized program on investment fiduciary standards <strong>of</strong> care. After the training program they must<br />
successfully pass an examination, conform to a code <strong>of</strong> ethics and complete 6 hours <strong>of</strong> continuing education<br />
requirements on a yearly basis.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Fulgham.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Fulgham is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale<br />
and affiliates, thus Mr. Fulgham receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Additionally, Mr. Fulgham receives compensation from the assets brought to the firm by sales persons that work<br />
directly under his supervision. Mr. Fulgham may also receive compensation from fees collected from Rochdale<br />
products. Mr. Fulgham may also receive compensation based on the sales efforts <strong>of</strong> the sales employees he manages.<br />
As an owner, Mr. Fulgham also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Fulgham as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Kashif S. Ahmad, CFA<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Kashif S. Ahmad that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Kashif S. Ahmad is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Kashif S. Ahmad, CFA (Year <strong>of</strong> birth – 1972)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Ahmad received a Bachelor <strong>of</strong> Science in finance from the Wharton School <strong>of</strong> the University <strong>of</strong> Pennsylvania<br />
and his Master’s <strong>of</strong> Business Administration with concentrations in finance and strategy from the Yale School <strong>of</strong><br />
Management.<br />
Mr. Ahmad joined Rochdale in 1999. He currently serves as Vice President – Investment Consulting.<br />
Previously, Mr. Ahmad worked at PricewaterhouseCoopers in its Corporate Finance Group, where he was<br />
responsible for company valuations and due diligence regarding acquisitions by private equity investment firms.<br />
Prior to that, while at M. Sagheer & Co., Mr. Ahmad was involved in investment analyses and recommended<br />
investment strategies to high net worth individuals.<br />
Mr. Ahmad holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Ahmad.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Ahmad is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale and<br />
affiliates, thus Mr. Ahmad receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Ahmad receives compensation on the total assets he manages on the account level and for management fees<br />
generated by those accounts. Mr. Ahmad may also receive compensation from fees collected from Rochdale<br />
products.<br />
As an owner, Mr. Ahmad also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s, Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Ahmad as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Harry Martin, AIF®<br />
Rochdale Investment Management<br />
100 Crescent Court, Suite 700<br />
Dallas, TX 75201<br />
(212)702-3523<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Harry Martin that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Harry Martin is available on the SEC’s website at www.adviserinfo.sec.gov
Harry Martin, AIF® (Year <strong>of</strong> birth – 1949)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Martin earned his Bachelor <strong>of</strong> Science with Highest Honors from the U.S. Merchant Marine Academy and his<br />
Master’s <strong>of</strong> Business Administration from Harvard Business School.<br />
Mr. Martin joined Rochdale in January <strong>of</strong> 2008. Based in Dallas, Texas, Mr. Martin fosters relationships with<br />
financial advisors, CPAs, attorneys, and their clients. He is responsible for business development throughout the<br />
Mid-America Southern region.<br />
Prior to joining Rochdale, Mr. Martin held several senior level positions at Brown Brothers Harriman. In his final<br />
role as a Managing Director, Mr. Martin led a team that provided portfolio management, client relations, and<br />
marketing to clients including high net worth individuals, endowments, and foundations. Early in his wealth<br />
management career, Mr. Martin was also a U.S. Naval Reserve Officer and ultimately obtained the rank <strong>of</strong><br />
Commander, USNR. He served as the Director and Treasurer <strong>of</strong> the U.S. Merchant Marine Academy Foundation<br />
and was meritoriously awarded for his outstanding service.<br />
Mr. Martin is also a member <strong>of</strong> the Foundation Board <strong>of</strong> the Dallas Symphony Orchestra.<br />
Mr. Martin holds the Accredited Investment Fiduciary® (“AIF®”) designation. AIF® designees have successfully<br />
completed a specialized program on investment fiduciary standards <strong>of</strong> care. After the training program they must<br />
successfully pass an examination, conform to a code <strong>of</strong> ethics and complete 6 hours <strong>of</strong> continuing education<br />
requirements on a yearly basis.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Martin.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Martin is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Martin receives compensation on the total assets he manages on the account level and for management fees<br />
generated by those accounts. Mr. Martin may also receive compensation from fees collected from Rochdale<br />
products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Martin as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Derek A. Roy, AIF®<br />
Rochdale Investment Management<br />
605 Crescent Executive Drive, Suite 320<br />
Lake Mary, FL 32746<br />
(407) 333-1677<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Derek A. Roy that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Derek A. Roy is available on the SEC’s website at www.adviserinfo.sec.gov
Derek A. Roy, AIF® (Year <strong>of</strong> birth – 1975)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Roy earned his Bachelor <strong>of</strong> Science in business management from North Carolina State University.<br />
Mr. Roy joined Rochdale in 2008 as Vice President – Investment Consulting.<br />
In previous positions at Jackson National Life and Kaufman Brothers, he gained extensive high net worth sales and<br />
business development experience. At Capital Strategies, Mr. Roy was a member <strong>of</strong> the Investment Policy<br />
Committee where he developed the firm’s separate account platform and was responsible for the management <strong>of</strong><br />
individual portfolios.<br />
Mr. Roy holds the Accredited Investment Fiduciary® (“AIF®”) designation. AIF® designees have successfully<br />
completed a specialized program on investment fiduciary standards <strong>of</strong> care. After the training program they must<br />
successfully pass an examination, conform to a code <strong>of</strong> ethics and complete 6 hours <strong>of</strong> continuing education<br />
requirements on a yearly basis.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Roy.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Roy is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Roy receives compensation on the total assets he manages on the account level and for management fees<br />
generated by those accounts. Mr. Roy may also receive compensation from fees collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro , Chief Compliance Officer, Barbara Hawkesworth, Esq.<br />
and Regional Director – Senior Vice President, John Fulgham supervise and monitor the activities <strong>of</strong> Mr. Roy as it<br />
relates to the <strong>Firm</strong> and its clients. Such is done through various channels including the review <strong>of</strong> documents related<br />
to his clients and monitoring <strong>of</strong> accounts through automated reports generated directly to the Compliance<br />
Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Jonathan Doyle, CIMA®<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Jonathan Doyle that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Jonathan Doyle is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Jonathan Doyle, CIMA® (Year <strong>of</strong> birth – 1973)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Doyle received his Bachelor <strong>of</strong> Arts in Psychology from the University <strong>of</strong> Arizona and his Master’s <strong>of</strong> Business<br />
Administration from the F.W. Olin Graduate School <strong>of</strong> Business at Babson College. Additionally, he has completed<br />
the Certificate in Advanced Financial Planning from the Wharton School <strong>of</strong> the University <strong>of</strong> Pennsylvania.<br />
Mr. Doyle joined Rochdale in 2010 with over ten years <strong>of</strong> experience in the financial services industry. As a Senior<br />
Sales Consultant Mr. Doyle fosters relationships with financial pr<strong>of</strong>essionals and their clients. He is responsible for<br />
business development in the Midwest Region.<br />
Prior to joining Rochdale, he worked at Placemark Investments as an Associate Regional Consultant where he<br />
worked with financial advisors analyzing client portfolios and creating tax efficient asset transition strategies.<br />
Previously, Mr. Doyle was a Relationship Manager at Bank <strong>of</strong> America where he worked directly with the bank’s<br />
clients to provide solutions for their complex credit and investment needs. Mr. Doyle began his career at Sun Life<br />
Financial as a Sales Consultant where he assisted financial advisors in providing financial planning solutions.<br />
Mr. Doyle holds the Certified Investment Management Analyst® (“CIMA®”) designation. The CIMA® credential<br />
is awarded by the Investment Management Consultants Association to pr<strong>of</strong>essionals who pass a pre-qualifying and a<br />
certifying exam, complete coursework at the Wharton School, University <strong>of</strong> Pennsylvania, have a minimum <strong>of</strong> three<br />
years experience in investment consulting and fulfill continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Doyle.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Doyle is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Doyle receives compensation on the total assets he manages on the account level and for management fees<br />
generated by those accounts. Mr. Doyle may also receive compensation from fees collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro, Chief Compliance Officer, Barbara Hawkesworth, Esq.<br />
and Regional Director – Senior Vice President, John Fulgham supervise and monitor the activities <strong>of</strong> Mr. Doyle as<br />
it relates to the <strong>Firm</strong> and its clients. Such is done through various channels including the review <strong>of</strong> documents<br />
related to his clients and monitoring <strong>of</strong> accounts through automated reports generated directly to the Compliance<br />
Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Kevin Barlow<br />
Rochdale Investment Management<br />
455 Market Street, Suite 970<br />
San Francisco, CA 94105<br />
(415) 477-2544<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Kevin Barlow that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Kevin Barlow is available on the SEC’s website at www.adviserinfo.sec.gov
Kevin Barlow (Year <strong>of</strong> birth – 1982)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Barlow received his Bachelor <strong>of</strong> Arts from the University <strong>of</strong> Michigan.<br />
Mr. Barlow joined Rochdale in 2011 as a Sales and Marketing Associate. In 2012 Mr. Barlow was promoted to<br />
Sales Investment Consultant. Prior to joining Rochdale Mr. Barlow was a solicitor for Forward Pro, LLC, a Senior<br />
Account Executive with Yammer Inc., a Group Sales Representative with Sun Life Financial, an Investment<br />
Counselor with Fisher Investments and the Director <strong>of</strong> Business Development with Leisure Intelligence.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Barlow.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Barlow is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
Mr. Barlow receives compensation on the total assets he manages on the account level and for management fees<br />
generated by those accounts. Mr. Barlow may also receive compensation from fees collected from Rochdale<br />
products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Barlow as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Paul Guerney, CFA<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Paul Guerney that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Paul Guerney is available on the SEC’s website at www.adviserinfo.sec.gov
Paul Guerney, CFA (Year <strong>of</strong> birth – 1973)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Guerney received his Bachelor <strong>of</strong> Arts in economics and psychology from Fairfield University and his Master’s<br />
<strong>of</strong> Business Administration in finance and management from New York University, Stern School <strong>of</strong> Business. He<br />
also completed a Certificate Program in the Digital Economy at New York University.<br />
Mr. Guerney is a Vice President and Senior Portfolio Manager for Rochdale Investment Management. Mr. Guerney<br />
joined Rochdale in 2001 and is responsible for the management <strong>of</strong> client portfolios.<br />
Prior to joining Rochdale, Mr. Guerney worked as an Investment Officer at Envest Net PMC Advisory, where he<br />
advised financial planners and private clients on portfolio structure and strategy. Other responsibilities included<br />
researching both hedge funds and traditional money managers and developing strategic new product initiatives.<br />
From 1996 to 1999, prior to business school, he worked as an analyst at Goldman Sachs & Co., where he was<br />
involved in both Corporate Treasury - Cash Management and Institutional Fixed Income - Sales and Trading. Mr.<br />
Guerney began his career in 1995 as a junior auditor for Price Waterhouse Coopers in the Entertainment/Media<br />
practice.<br />
Mr. Guerney holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Guerney.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Guerney is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale<br />
and affiliates, thus Mr. Guerney receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Guerney may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Mr. Guerney may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Mr. Guerney also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Guerney as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Poul Erik Olsen, CFA<br />
Rochdale Investment Management<br />
455 Market Street, Suite 970<br />
San Francisco, CA 94105<br />
(415) 477-2544<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Poul Erik Olsen that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Poul Erik Olsen is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Poul Erik Olsen, CFA (Year <strong>of</strong> birth – 1966)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Olsen received his Bachelor <strong>of</strong> Science in economics from the Aarhus Business School in Denmark and his<br />
Master’s <strong>of</strong> Business Administration in finance from the University <strong>of</strong> California at Berkeley, where he specialized<br />
in finance and international business.<br />
Mr. Olsen is a Vice President and Senior Portfolio Manager for Rochdale Investment Management. Mr. Olsen<br />
joined Rochdale Investment Management in 2003.<br />
Mr. Olsen’s career in finance began in his native Denmark, where he worked as a lending <strong>of</strong>ficer for Savings Bank<br />
Nordiylland. He has more than eighteen years <strong>of</strong> experience in international finance and client management<br />
including nine years with public and private U.S. equity investments in the brokerage and investment banking<br />
industry. While at Bank <strong>of</strong> America Securities and Robertson, Stephens & Co., Mr. Olsen was responsible for<br />
account management <strong>of</strong> the largest pension and mutual funds in Scandinavia and the Benelux.<br />
Mr. Olsen holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Olsen.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Olsen is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale and<br />
affiliates, thus Mr. Olsen receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Olsen may receive additional compensation from the firm based on the assets he brings to<br />
the firm and the fees collected by the firm on those assets. Mr. Olsen may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Mr. Olsen also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Olsen as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Charles P. Alberton, CFA, CAIA<br />
Rochdale Investment Management<br />
455 Market Street, Suite 970<br />
San Francisco, CA 94105<br />
(415) 477-2544<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Charles P. Alberton that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Charles P. Alberton is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Charles P. Alberton, CFA, CAIA (Year <strong>of</strong> birth – 1973)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Alberton earned his Bachelor <strong>of</strong> Science in business administration from California State University, Chico and<br />
his Master’s <strong>of</strong> Business Administration in finance from the University <strong>of</strong> Notre Dame.<br />
Mr. Alberton is a Vice President and Senior Portfolio Manager for Rochdale Investment Management. Mr. Alberton<br />
joined Rochdale Investment Management in 2000.<br />
Prior to Rochdale, Mr. Alberton was employed with Wells Fargo in their Private Client Services group, where he<br />
designed and implemented investment strategies for high net worth individuals. Mr. Alberton began his career at<br />
Lehman Brothers on the Institutional Fixed Income desk, where he gained valuable experience trading and<br />
analyzing various tiers <strong>of</strong> commercial paper, corporate bonds, municipal bonds, mortgages, asset-backed securities,<br />
and other fixed income instruments for institutional investors. He has over eleven years <strong>of</strong> institutional fixed income<br />
and private client investment management experience.<br />
Mr. Alberton holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
Mr. Alberton holds the Chartered Alternative Investment Analyst (“CAIA”) designation. This designation is issued<br />
by the CAIA Association. The prerequisites or experience required is over one year <strong>of</strong> pr<strong>of</strong>essional experience and a<br />
U.S. bachelor’s degree (or equivalent) or four years <strong>of</strong> pr<strong>of</strong>essional experience. CAIA candidates must pass both<br />
Level I and Level II <strong>of</strong> the CAIA exam to qualify for the designation. Qualifying candidates must complete the<br />
online Member Agreement, provide two pr<strong>of</strong>essional references, and submit annual membership dues.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Alberton.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Alberton is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale<br />
and affiliates, thus Mr. Alberton receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Alberton may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Mr. Alberton may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Mr. Alberton also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,
Esq. supervise and monitor the activities <strong>of</strong> Mr. Alberton as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Elizabeth T. Dooley, CFA<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Elizabeth T. Dooley that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Elizabeth T. Dooley is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Elizabeth T. Dooley, CFA (Year <strong>of</strong> birth – 1971)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Ms. Dooley received her Bachelor <strong>of</strong> Business Studies in Finance from Dublin City University in Dublin, Ireland.<br />
Ms. Dooley is a Portfolio Manager for Rochdale Investment Management. Ms. Dooley joined Rochdale in 2000 and<br />
is responsible for the management <strong>of</strong> client portfolios.<br />
Prior to joining Rochdale, Ms. Dooley was employed by Citibank as a trader where she traded various fixed income<br />
securities. From 1995 to 1996 Ms. Dooley was employed as a Junior Trader with Mitsubishi Trust & Banking Corp.<br />
in their finance/treasury and securities lending department. Ms. Dooley began her career in 1994 as a Trading<br />
Assistant with Fukuoka Citibank where she assisted traders in the trading and settlement Federal Funds.<br />
Ms. Dooley holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relevant to Ms. Dooley.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Ms. Dooley is an owner <strong>of</strong> Acebes, D’Alessandro and Associates (“ADA”), the controlling member <strong>of</strong> Rochdale and<br />
affiliates, thus Mr. Alberton receives a portion <strong>of</strong> ADA’s earnings.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Ms. Dooley may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Ms. Dooley may also receive compensation from fees<br />
collected from Rochdale products.<br />
As an owner, Ms. Dooley also receives a portion <strong>of</strong> pr<strong>of</strong>its earned by the firm.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities<strong>of</strong> Ms. Dooley as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to her clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Sheldon C. Brandau, CFA<br />
Rochdale Investment Management<br />
605 Crescent Executive Drive, Suite 320<br />
Lake Mary, FL 32746<br />
(407) 333-1677<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Sheldon C. Brandau that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Sheldon C. Brandau is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Sheldon C. Brandau, CFA (Year <strong>of</strong> birth – 1971)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Brandau received his Bachelor <strong>of</strong> Science in Management from Purdue University and his Master’s <strong>of</strong> Business<br />
Administration in Finance and Statistics from New York University, Stern School <strong>of</strong> Business.<br />
Mr. Brandau is a Portfolio Manager for Rochdale Investment Management. Mr. Brandau joined Rochdale in 2009<br />
and is responsible for the management <strong>of</strong> client portfolios.<br />
Previously he worked as a Financial Advisor and Portfolio Manager within Merrill Lynch's Private Banking and<br />
Investment Group, designing and implementing investment strategies for affluent clients. Prior to joining Merrill<br />
Lynch, Mr. Brandau worked at State Street Corporation where he was a Senior Officer, managing the investment<br />
analysis and performance reporting for the firm's Section 529 College Savings Plans. Mr. Brandau began his<br />
investment and financial career at Sanford C. Bernstein & Co. Inc., serving as the firm's Investment Planning<br />
Analyst for the Southeast region. Mr. Brandau is also a member <strong>of</strong> the CFA Institute and the CFA Society <strong>of</strong> South<br />
Florida.<br />
Mr. Brandau holds the Chartered Financial Analyst (“CFA”) designation. This designation is issued by the CFA<br />
Institute. The prerequisites or experience required is an undergraduate degree, 4 years <strong>of</strong> pr<strong>of</strong>essional experience<br />
involving investment decision making or 4 years <strong>of</strong> full-time qualified non-investment related work experience. It is<br />
a self-study program, approximately 250 recommended hours <strong>of</strong> study for each <strong>of</strong> the 3 levels. All three levels are<br />
then achieved through a course exam. There are no continuing education requirements.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Brandau.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Brandau is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Brandau may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Mr. Brandau may also receive compensation from fees<br />
collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Brandau as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
John Geraghty<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about John Geraghty that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about John Geraghty is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
John Geraghty (Year <strong>of</strong> birth – 1973)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Geraghty earned his Bachelor <strong>of</strong> Arts in finance from Fordham University and his Master’s <strong>of</strong> Business<br />
Administration in finance from the Stern School <strong>of</strong> Business at New York University.<br />
Mr. Geraghty joined Rochdale in 2005. As Portfolio Management Associate he is responsible for the<br />
implementation and monitoring <strong>of</strong> private client portfolios for Rochdale's Offshore Investment Management<br />
division.<br />
Prior to joining Rochdale, Mr. Geraghty worked in the Private Client Group at Citigroup Asset Management, where<br />
he managed equity and fixed income portfolios for individual clients. Additionally, he was employed with Deutsche<br />
Asset Management, where he implemented and monitored the investments <strong>of</strong> client portfolios.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Geraghty.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Geraghty is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
There are no arrangements where a non-client provides an economic benefit to Mr. Geraghty for providing advisory<br />
services.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro, the Managing Director <strong>of</strong> Rochdale Offshore Investment<br />
Management, Neal Rubin, and Chief Compliance Officer, Barbara Hawkesworth, Esq. supervise and monitor the<br />
activities <strong>of</strong> Mr. Geraghty as it relates to the <strong>Firm</strong> and its clients. Such is done through various channels including<br />
the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through automated reports generated<br />
directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara Hawkesworth may be<br />
contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Robert DeLong<br />
Rochdale Investment Management<br />
455 Market Street, Suite 970<br />
San Francisco, CA 94105<br />
(415) 477-2544<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Robert DeLong that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Robert DeLong is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Robert DeLong (Year <strong>of</strong> birth – 1965)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. DeLong received his Bachelor <strong>of</strong> Sciences degree from the University <strong>of</strong> Virginia’s McIntire School <strong>of</strong><br />
Commerce and earned his Master’s <strong>of</strong> Business Administration from the Kellogg Graduate School <strong>of</strong> Management<br />
at Northwestern University where he specialized in finance and management strategy.<br />
Mr. DeLong joined Rochdale in 2011 as a Portfolio Manager.<br />
Mr. DeLong’s financial career began over 20 years ago as an investment banker with Morgan Stanley where he<br />
worked for eight years in both Mergers and Acquisitions and Corporate Finance. He later worked with Banc <strong>of</strong><br />
America Securities where he specialized in debt and equity financing and provided strategic transaction advice to his<br />
clients. Additionally, Mr. DeLong spent five years working with high net worth clients as a Portfolio Manager &<br />
Research Analyst at Grand-Jean Capital Management where he was responsible for due diligence, security selection<br />
and portfolio performance analysis. Mr. DeLong did some proprietary trading and provided some consultant work<br />
for Vulcan Capital from 2006-2010.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. DeLong.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. DeLong is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. DeLong may receive additional compensation from the firm based on the assets he brings<br />
to the firm and the fees collected by the firm on those assets. Mr. DeLong may also receive compensation from fees<br />
collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. DeLong as it relates to the <strong>Firm</strong> and its clients. Such is done<br />
through various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts<br />
through automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer,<br />
Barbara Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Adam Elover<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Adam Elover that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Adam Elover is available on the SEC’s website at www.adviserinfo.sec.gov
Adam Elover (Year <strong>of</strong> birth – 1980)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Elover received his Bachelor <strong>of</strong> Science from the University <strong>of</strong> Maryland and his Master’s <strong>of</strong> Business<br />
Administration, emphasis in Finance, from the University <strong>of</strong> Baltimore.<br />
Mr. Elover joined Rochdale in 2006 as a Portfolio Management Associate. Currently a Junior Portfolio Manager he<br />
is responsible for the implementation and monitoring <strong>of</strong> private client portfolios for Rochdale.<br />
Prior to joining Rochdale Mr. Elover was a Portfolio Analyst for Mercantile Bank, from 2003 to 2006 and a<br />
Reconciliation Specialist with Legg Mason from 2002 to 2003.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Elover.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Elover is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
There are no arrangements where a non-client provides an economic benefit to Mr. Elover for providing advisory<br />
services.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Elover as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Thomas A. Galvin<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Thomas A. Galvin that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Thomas A. Galvin is available on the SEC’s website at<br />
www.adviserinfo.sec.gov
Thomas A. Galvin (Year <strong>of</strong> birth – 1955)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Mr. Galvin received his Bachelor <strong>of</strong> Arts from Queens College and his Master’s <strong>of</strong> Business Administration from<br />
Fordham University.<br />
Mr. Galvin joined Rochdale in 2012 as the Director <strong>of</strong> US Equity and Research. Mr. Galvin works directly with the<br />
CEO and President to guide the firm’s investment research and portfolio development functions. He is solely<br />
responsible for leading the equity research team and will focus primarily on the large and mid cap asset classes.<br />
Prior to joining Rochdale Mr. Galvin was the Managing <strong>Part</strong>ner for High Net Worth Clients at Galvin Asset<br />
Management from 2008 to 2012. From 2006 to 2007 Mr. Galvin was the Executive Director, Large Cap Growth<br />
with UBS Global Asset Management and from 1991 to 2006 Mr. Galvin moved within a number <strong>of</strong> roles with<br />
Forstmann Leff Associates, including Portfolio Manager, Chief Investment Officer and Senior Managing Director.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Mr. Galvin.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Mr. Galvin is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Mr. Galvin may receive additional compensation from the firm based on the assets she brings<br />
to the firm and the fees collected by the firm on those assets. Mr. Galvin may also receive compensation from fees<br />
collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Mr. Galvin as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.
<strong>Item</strong> 1 <strong>Cover</strong> <strong>Page</strong><br />
Lindsey Cook<br />
March 31, 2012<br />
Rochdale Investment Management<br />
570 Lexington Avenue, 9 th Floor<br />
New York, NY 10022<br />
(212) 702-3500<br />
www.rochdale.com<br />
This brochure supplement provides information about Lindsey Cook that supplements Rochdale<br />
Investment Management LLC’s (“Rochdale”) brochure. You should have received a copy <strong>of</strong> that<br />
brochure. Please contact Rochdale’s Compliance Department by calling (212) 702-3500 if you did not<br />
receive Rochdale’s disclosure brochure or if you have any questions about the contents <strong>of</strong> this<br />
supplement.<br />
Additional information about Lindsey Cook is available on the SEC’s website at www.adviserinfo.sec.gov
Lindsey Cook (Year <strong>of</strong> birth – 1984)<br />
<strong>Item</strong> 2 Educational Background and Business Experience<br />
Ms. Cook received her bachelors degree and her Master’s <strong>of</strong> Business Administration from Loyola Marymount<br />
University.<br />
Ms. Cook joined Rochdale in 2010 as a Portfolio Management Associate. Currently as a Junior Portfolio Manager<br />
she is responsible for the implementation and monitoring <strong>of</strong> private client portfolios for Rochdale.<br />
Prior to joining Rochdale Ms. Cook was an Investment Associate with AXA Advisors from 2007 to 2010 and a<br />
Junior Associate with Bank <strong>of</strong> America in 2006.<br />
<strong>Item</strong> 3 Disciplinary Information<br />
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events<br />
that would be material to your evaluation <strong>of</strong> each supervised person providing investment advice.<br />
There are no legal or disciplinary events to report relative to Ms. Cook.<br />
<strong>Item</strong> 4 Other Business Activities<br />
Ms. Cook is not actively engaged in any other investment-related business or occupation.<br />
<strong>Item</strong> 5 Additional Compensation<br />
In addition to salary, Ms. Cook may receive additional compensation from the firm based on the assets she brings to<br />
the firm and the fees collected by the firm on those assets. Ms. Cook may also receive compensation from fees<br />
collected from Rochdale products.<br />
<strong>Item</strong> 6 Supervision<br />
Rochdale’s Chief Executive Officer Garrett D’ Alessandro and Chief Compliance Officer, Barbara Hawkesworth,<br />
Esq. supervise and monitor the activities <strong>of</strong> Ms. Cook as it relates to the <strong>Firm</strong> and its clients. Such is done through<br />
various channels including the review <strong>of</strong> documents related to his clients and monitoring <strong>of</strong> accounts through<br />
automated reports generated directly to the Compliance Department. The <strong>Firm</strong>’s Chief Compliance Officer, Barbara<br />
Hawkesworth may be contacted at 212-702-3500.