Reflection Asset Management LLC

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Reflection Asset Management LLC
CRD #306663
SEC #801-119521
CIK #0002108398
AUM 228.9 M (2026-03-31)
Employees 3 (67% Investors, 0% Brokers)
Fees
Minimum
Phone617-584-4042
Address
Source [IAPD] [EDGAR] [Website] [Twitter] [LinkedIn] [Facebook]
Total AUM ($M)
2502001501005002010201520212027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
Item 5 - Fees and Compensation

Separately Managed Accounts
RAM receives a management fee for separately managed accounts based on the market value of the
client’s account. Management fees are expected to range from 0.45% to 1.35% annually, are generally
payable quarterly in arrears, and deducted from the client’s account.
Management fees are waived for the assets in separately managed accounts that are invested in the
Democratic Large Cap Core ETF or Sphere 500 Climate Fund (the “Funds”). Management fees will be
calculated based on the specified percentage of assets under management not invested in the Funds at
the end of each calendar quarter and is payable quarterly in arrears. RAM reserves the right to amend
this calculation formula and will charge a prorated amount for significant additions or withdrawals in
a given quarter. See Item 15 of this Brochure regarding the deduction of management fees from
certain client accounts.

WMNomics and other model accounts
For model portfolios, such as WMNomics, offered to individual investors through accounts at
Interactive Brokers, RAM charges a management fee of 40-45 bps annually paid quarterly in arrears.

Consulting services
RAM charges for investment consulting services on an hourly basis at a rate agreed upon with the
client.

Other Fees or Expenses
In addition to management fees, client accounts will also be subject to other investment related
expenses such as custodial charges, brokerage fees, commissions and/or transactional costs, taxes or
transfer and registrations fees. Investments made in certain assets classes such as mutual funds or
exchange traded funds (“ETFs”) may also incur additional fees for the client.

Mutual Funds
RAM serves as the advisor to the Democratic Large Cap Core ETF and Sphere 500 Climate Fund (each,
a “Mutual Fund”, or, collectively, the “Mutual Funds”). This creates a conflict of interest in that RAM
has an incentive to invest clients in the Mutual Funds as we may receive a higher fee for advising the
Mutual Funds. RAM is compensated for the provision of services in accordance with investment
advisory agreements approved by the Board of Trustees of each Mutual Fund. Advisory fees are
calculated separately for each Mutual Fund at a specified annual percentage of the Mutual Fund’s
average daily net assets and are payable monthly.

The Adviser may recommend or allocate the Mutual Funds to certain advisory clients or within certain
investment models. In these instances, we waive the client’s account management fee for the portion
of assets invested in the Mutual Funds. The client pays the fees, expenses and charges associated with
the Mutual Funds, custodian or other third parties. Please refer to the prospectus and statement of
additional information (“SAI”) for information about the fees and expenses associated with the Mutual
Funds.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
Item 7 - Types of Clients

RAM offers investment advisory services to individuals and is the investment adviser to the Democratic
Large Cap Core ETF and Sphere 500 Climate Fund, each a registered investment company organized
under the Investment Company Act of 1940.

RAM reserves the right to impose a minimum account size requirement for each Managed Account.
While we intend to be flexible as to minimum account sizes, the relative higher costs and loss of
economies of scale for smaller account sizes typically requires us to charge higher management
and/or administration fees for smaller Managed Accounts. We may enter into agreements with new
clients that have different minimum account sizes and fees from those in effect for existing clients.
Clients may make cash additions to their Managed Account at any time and withdraw account assets
with written notice to RAM. We will not establish a Managed Account for a prospective client whose
investment objectives, strategies and/or restrictions are inconsistent with our philosophy and
disciplines.
Sector Form 13F Holdings Value ($M)
Nvidia Corp 8.0
Apple Inc 7.5
Microsoft Corp 7.0
Facebook Inc 4.2
Alphabet Inc 3.0
Amazon Com Inc 2.8
Alphabet Inc 2.5
Lam Research Corp 2.4
KLA Tencor Corp 2.1
Costco Wholesale Corp /NEW 2.1
View All
Holdings by Sector ($M)
15012090603002025202520262027
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 70 113.9
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 2 115.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 121 228.9
By Discretionary
Discretionary 121 228.9
Non-Discretionary 0 0.0
Total 121 228.9
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 228.9
Total 121 228.9
EDGAR Form CIK 2011 - 2026
13F-HR [0002108398]
Firm Profile (Form ADV)
Discretionary AUM$0.0B
ServesInstitutional, Retail, Research
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