Romano Wealth Management is a dual-registered firm based in Evanston, IL, that holds a 80.3/100 Fidelon TransparencyScore (23rd percentile among SEC-registered advisers), with 13 registered advisors. Score based on public SEC and FINRA filings.
Romano Wealth Management
Romano Brothers And · CRD #3215
A dual-registered firm offering both advisory and brokerage services.
Fidelon Fact Sheet
Romano Wealth Management is an investment adviser and broker-dealer in Evanston, IL. It used to be called Romano Brothers And COMPANY. Its 13 registered advisors typically serve individuals and families and high-net-worth individuals. It manages $1.5 billion across 2,078 client accounts. It charges a percentage of the money it manages for you. When it gives advice, it must put your interests first. When it sells products, it only has to pick ones that are suitable for you. Its services include financial planning and portfolio management. It reports that it can hold or access client money, which the SEC requires firms to disclose. It has regulatory actions and customer arbitrations on file, most recently in 2018.
Peer Context
8,284th of 10,815
SEC-registered advisers
Bottom 23%
305th of 419
SEC-registered advisers in IL
Bottom 27%
7th of 8
SEC-registered advisers in Evanston, IL
Bottom 13%
How This Firm Works
Registration & Standard of Care
Dual-Registered — this firm operates as both an investment adviser (fiduciary) and a broker-dealer. Some services come with fiduciary protection, while brokerage services may involve commissions.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Charges fixed fees for specific services
- Representatives can earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $500,000 and above.
This fee is negotiable
“Financial planning/consulting fees are negotiable in certain circumstances.”
From their Form ADV Part 2A. Most investors never ask.
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 |
|---|---|
| $0 - $500,000 | 1.00% |
| $500,000 and above | 0.75% |
Billed quarterly in arrears (active) or advance (passive)
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
- Registered as investment adviser with fiduciary obligation
Things You Should Know
- Also operates as a broker-dealer — may not always be required to put your interests first
- 2 regulatory complaints reported by FINRA
- $170K in regulatory fines
Conflict Audit
Multiple structural conflicts identified in regulatory filings. These are disclosed business arrangements — worth asking about, not disqualifying.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
What this firm says about how it gets paid
“The more assets in an account we handle on an advisory basis, the larger the management fee.”
“we receive additional revenues from principal trading (bond markups), mutual fund 12b-1 fees, money fund rebates, insurance commissions, and referral fees from lending products”
Source: the firm’s own Form CRS — quoted directly
Regulatory Track Record
2
Disclosures
$170K
Total Fines
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
87/100
Strong
Avg for dual-registered firms: 66.8 | Top 10%: 97.2
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
83/100
Strong
Avg for dual-registered firms: 70.4 | Top 10%: 80.7
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.
65/100
Fair
Avg for dual-registered firms: 62.2 | Top 10%: 79.3
Enforcement History
Past actions taken by the SEC, FINRA, or state regulators, and how well the firm supervised its people.
87/100
Strong
Avg for dual-registered firms: 59.6 | Top 10%: 86.5
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.
Accounts under $500,000 1.00% of assets Accounts over $500,000 $1,000 base fee plus 0.75% of assets up to $1 million plus 0.65% of assets over $1 million plus 0.60% of assets over $5 millionp. 9
- 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.
Financial planning/consulting fees are negotiable in certain circumstances.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.
Fees are paid quarterly in arrears (active management) or advance (passive management) and are generally deducted from the client portfolio.p. 9
- 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.
The fee will be computed and billed at the end of each calendar quarter by applying one quarter of the applicable annual rate to the market value of the portfolio, as defined above, on the last trading day of the preceding quarter.p. 9
- 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.
The Total Client Fee also excludes other related charges, including but not limited to, express postage and handling charges, returned check charges, short-term mutual fund trading fees, fees listed in a mutual fund prospectus, Advantage Checking account fees, legal transfer fees, safekeeping fees, valuation fees, wire or transfer fees, transfer taxes or exchange fees, or other fees mandated by lawp. 8
- Does it say how you get money back if you leave mid-period?Does not applyItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity53/100
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 its people earn commissions on securities, does it explain them?
Securities commissions
- 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.
Our policy is to mark up or mark down securities from the inter-dealer bid or offer price as specified in the investment management contract. This policy yields additional compensation to the firm and as such might provide a potential conflict of interest.p. 9
- 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.
Our policy is to mark up or mark down securities from the inter-dealer bid or offer price as specified in the investment management contract.p. 9
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
This policy yields additional compensation to the firmp. 9
- 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 whether anyone at the firm earns a commission on investments recommended to you, and whether it lowers your fee.
If its people can earn insurance commissions, does it explain them?
Insurance commissions
- 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.
This may result in a conflict of interest, as in most cases, RWM will receive a commission of approximately the first year’s premium plus a small ongoing annual feep. 10
- 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.
RWM may refer you to one or more insurance general agents or carriers for life, disability, long term care, or other insurance needsp. 10
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
RWM will receive a commission of approximately the first year’s premium plus a small ongoing annual feep. 10
- 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 whether anyone at the firm earns a commission on insurance recommended to you, and whether it lowers your fee.
If the firm collects 12b-1 fees from mutual funds, does it explain them?
12b-1 distribution fees from mutual funds
- 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.
A portion of these expenses may be paid to RWM (i.e., 12b-1 fees), which is in addition to the overall management fee assessed by us.p. 10
- 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.
A portion of these expenses may be paid to RWM (i.e., 12b-1 fees), which is in addition to the overall management fee assessed by us.p. 10
- Does it say what the firm is paid for it?CoveredStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
A portion of these expenses may be paid to RWM (i.e., 12b-1 fees)p. 10
- 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 whether any fund you own pays the firm a 12b-1 fee, and whether a cheaper share class exists.
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?Not found in the brochureItems 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.
What to askAsk the advisor to walk you through every way the firm gets paid besides your fee.
- 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?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.
Do they earn commissions on products, and do they say so?Brochure Sales Compensation60/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
Our policy is to mark up or mark down securities from the inter-dealer bid or offer price as specified in the investment management contract. This policy yields additional compensation to the firm and as such might provide a potential conflict of interest.p. 9
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
The receipt of such payments provides a financial incentive for RWM to recommend and approve non-purpose loans.p. 19
- Does it say you can buy the same products elsewhere?Not found in the brochureItem 5.E.2
You may be able to buy the same product for less somewhere else.
What to askAsk whether you could buy any recommended product through another broker or insurer.
- Does it say whether commissions lower your advisory fee?Not found in the brochureItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
What to askAsk whether any commission the firm earns is credited against your advisory fee.
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars0/100
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?Not found in the brochureItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
What to askAsk what research, tools or services the firm receives from brokers or custodians at no charge.
- Does it say the firm benefits by not paying for those things?Not found in the brochureItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
What to askAsk what the firm would have to pay for those services if it bought them itself.
- Does it say those perks can shape which broker it picks for you?Not found in the brochureItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
What to askAsk how the firm chooses the broker for your trades and whether perks play any part.
- Does it say whether those perks stay within what the law allows?Not found in the brochureItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
What to askAsk whether everything the firm receives from brokers is research the law lets it take in return for your trades.
- 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
13 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Joseph Richardviktory Romano | 2659164 | — | — |
| Scott M Miller | 3255946 | — | — |
| Brett Patrick Larson | 4620646 | — | — |
| Douglas Norman Geisser | 1137506 | — | — |
| Eric Arthur Bederman | 2074318 | — | — |
| Richard Constantino Romano | 403390 | — | — |
| Deborah Lewin Cross | 4659319 | — | — |
| Valerie Romano Larson | 6544905 | — | — |
| Peter Hemwall | 5972002 | — | — |
| Megan Naydenova | 6959353 | — | — |
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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.
What does dual registration mean for me?
It means your advisor can act as a fiduciary (putting your interests first) for some services and as a broker (suitability standard) for others. The key question to ask: 'For this specific recommendation, are you acting as my fiduciary?' Get the answer in writing.
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.
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Last scored: · Score version: 3.15 · CRD #3215