De Rosa Asset Management, LLC

The Firm provides discretionary investment management to individuals, trusts, estates, corporations and other business entities, serving a small client base with approximately $50 million in assets under management. Advisory services emphasize ongoing portfolio management and client consultations to assess volatility tolerance, time horizon and liquidity needs.

The Firm implements a dynamic, model‑driven allocation strategy that primarily uses exchange‑traded funds — including Buffer ETFs — and relies on technical analysis, relative strength and momentum signals to shift allocations between equity exposure and cash. Portfolios are managed through similarly managed model accounts and are monitored continuously; the Firm may hold cash for extended periods and includes cash in account valuation for billing and investment decisions.

Uncommonly for a solo independent adviser, the Firm offers performance‑based fee arrangements to qualified clients, with performance fees calculated annually in arrears against an agreed benchmark and the first performance fee assessed on December 31 regardless of when management began. The Firm also provides portfolio management to institutional or business clients and discloses the attendant conflicts and risks from side‑by‑side management and use of buffered/derivative ETFs (including liquidity, counterparty and tax considerations), together with procedures intended to address those conflicts.