Roche Asset Management, LLC

Roche Asset Management, LLC provides discretionary portfolio management and related financial planning primarily to individual clients (both non‑high‑net‑worth and high‑net‑worth individuals) and to certain businesses. The firm charges percentage‑of‑assets advisory fees and offers advice across individual securities, mutual funds, exchange‑traded funds and certain alternative or non‑conventional investments.

The firm combines multiple analytical methods — including fundamental, technical, quantitative and qualitative analysis — and uses asset allocation together with long‑term, short‑term and trading strategies to construct and rebalance client portfolios. Accounts are reviewed at least quarterly and managed on a discretionary basis consistent with each client’s objectives, risk tolerance and liquidity needs.

Notable operational features include that certain firm personnel are dually registered as broker‑dealer representatives and are licensed insurance agents through the broker‑dealer’s insurance agency, and a principal of the firm has an ownership interest in a tax preparation and bookkeeping business; the firm discloses these affiliations and related transition payments and oversight arrangements as potential conflicts of interest. The firm also discloses a prior regulatory consent order that resulted in discontinuing investments in ETNs and inverse/leveraged ETPs, and it maintains limited custody arrangements for a small number of clients via standing letters of authorization.