Reagan Companies Asset Management is a investment adviser based in Syracuse, NY, that holds a 90.9/100 Fidelon TransparencyScore (86th percentile among SEC-registered advisers), with 5 registered advisors. Score based on public SEC and FINRA filings.
Reagan Companies Asset Management
Reagan Companies Asset Management, INC · CRD #161648
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Reagan Companies Asset Management, INC is an SEC-registered investment adviser in Syracuse, NY. It used to be called Reagan Investment Management. Its 5 registered advisors typically serve pension and profit-sharing plans. It manages $1.2 billion across 2,100 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it does not report earning commissions. Its services include financial planning, portfolio management, investment newsletters and market-timing advice. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
1,536th of 10,815
SEC-registered advisers
Top 14%
177th of 1,070
SEC-registered advisers in NY
Top 17%
5th of 9
SEC-registered advisers in Syracuse, NY
Bottom 44%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Does not earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $1 - $2,000,000.
This fee is negotiable
“These fees are negotiable depending upon the needs of the client and complexity of the situation and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Financial Planning Fees: Fixed fees at $1,500
- • Hourly fees between $150 and $500
- • Pension Consulting Fees: Individually priced based on complexity
- • Educational Seminar and Workshop Fees: No charge
- • Selection of Other Advisers Fees: Third-party fees as outlined, e.g., Vanguard Personalized Indexing Management, LLC fees from 0.20% to 0.15% based on assets
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $1 - $2,000,000 | 1.00% |
| $2,000,000 - $4,000,000 | 0.75% |
| $4,000,000 and above | 0.50% |
Billed quarterly
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Who They Typically Serve
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Things You Should Know
- Its brochure names research or services received from a custodian or broker (soft dollars) as a conflict, but it does not say what the firm is paid for it, explain what this arrangement tempts the firm to do, or say what it can cost you. Ask what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.Items 10, 11, 12.B and 14
Conflict Audit
Zero material conflicts identified in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“Therefore, the more assets you have in your advisory account, the more you will pay us since our fee is calculated on a percentage basis of the assets we are managing for you. Therefore, we have an incentive to increase those assets, while also trying to preserve them in a market downturn since our fee is directly related to the amount of assets we manage for you.”
Source: the firm’s own Form CRS — quoted directly
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
94/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
63/100
Fair
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
- Does it include everything the SEC requires?
- Required sections
- 71/100
- Does it explain how the firm's conflicts affect you?
- Conflicts of interest
What to askAsk the advisor to name every way the firm gets paid besides your fee, and how each one can affect their advice.
- 20/100
- Can you tell what you would pay?
- What you pay
- 69/100
- Is it written in plain English?
- Plain language
- 95/100
This firm's Form CRS averages 64 out of 100 and adds 0.94 points to the score above.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Total Assets Under Management Annual Fee First $1 - $2,000,000 1.00% Next $2,000,000 0.75% Everything Over $4,000,000 0.50%p. 6
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
These fees are negotiable depending upon the needs of the client and complexity of the situation and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract.p. 6
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Advisory fees are withdrawn directly from the client’s accounts with client written authorization.p. 6
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Fees are calculated using the value of the account on the last business day of the previous quarter and are calculated by dividing the annual fee percentage by 4(4 quarters) and are paid quarterly and initial fees for new accounts will be calculated on a pro-rata basis.p. 6
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.).p. 9
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination.p. 6
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity56/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
RCAM receives research, products, or services other from another third-party in connection with client securities transactions (“soft dollar benefits”).p. 15
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
RCAM receives a benefit because it does not have to pay for or produce the research, services, or products and therefore RCAM might have an incentive to recommend a custodian based on its interest rather than their clients.p. 16
- Does it describe what the arrangement actually is?Not found in the brochureStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
What to askAsk the advisor to explain this arrangement in plain terms, including who pays whom.
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Charles Schwab & Co., Inc. Advisor Services also makes available to RCAM other products and services that benefit RCAM but may not benefit its clients’ accounts.p. 17
- Does it explain what this arrangement tempts the firm to do?Not found in the brochureStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
What to askAsk what this arrangement gives the firm a reason to recommend, and how often that happens.
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
These benefits may include national, regional or RCAM specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services.p. 17
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?Not found in the brochureStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
What to askAsk what the firm gains from this arrangement beyond fees.
- Does it say what it can cost you?Not found in the brochureStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
What to askAsk what this arrangement can cost you, in fees, returns or choices you do not get.
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
- Hedged wording
RCAM receives a benefit because it does not have to pay for or produce the research, services, or products and therefore RCAM might have an incentive to recommend a custodian based on its interest rather than their clients.p. 16
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars82/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of RCAM’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting.p. 17
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
RCAM receives a benefit because it does not have to pay for or produce the research, services, or products and therefore RCAM might have an incentive to recommend a custodian based on its interest rather than their clients.p. 16
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
RCAM receives a benefit because it does not have to pay for or produce the research, services, or products and therefore RCAM might have an incentive to recommend a custodian based on its interest rather than their clients.p. 16
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
RCAM receives research, products, or services other from another third-party in connection with client securities transactions (“soft dollar benefits”).p. 15
- Does it say whether you pay more in trading costs because of those perks?Does not applyItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
- Does it say whether every client benefits or only some?Not found in the brochureItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
What to askAsk whether the research your trades help pay for is used for your account.
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
5 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Richard Paul Reagan | 2391015 | — | — |
| David Haahr | 4635464 | — | — |
| Christopher P. Riggi | 6277968 | — | — |
| Daniel Joseph Esford | 6455605 | — | — |
| Ethan Robert Ciota | 8157789 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #161648