R&GWM offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to R&GWM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with R&GWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). R&GWM has been registered as an investment adviser since April 2016 and is owned by Jeffrey Rhame. As of March 21, 2024, R&GWM had $693,510,338 of assets under management, all of which are managed on a discretionary basis. While this brochure generally describes the business of R&GWM, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on R&GWM’s behalf and is subject to the Firm’s supervision or control. Wealth Management Services Financial Planning and Consulting R&GWM offers clients a broad range of financial planning and consulting services as part of its wealth management services, which may include any or all of the following functions:
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• Cash Flow Forecasting Trust and Estate Planning Financial Reporting Insurance Planning Retirement Planning
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• Risk Management Charitable Giving Distribution Planning Tax Planning Manager Due Diligence In performing these services, R&GWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. R&GWM recommends that clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage R&GWM or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by R&GWM under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising R&GWM’s recommendations and/or services. R&GWM provides annual tax return preparation services through an unaffiliated accounting firm. These services will be provided to clients who maintain $2 million in managed assets, with R&GWM paying the associated expenses. The Firm will only pay for expenses relating to the annual personal tax returns for clients. R&GWM reserves the right to pay the expenses associated with this service for clients who maintain less than $2 million in managed assets, at the Firm’s discretion. Clients are under no obligation to accept the Firm's tax preparation services. Investment Management R&GWM manages client investment portfolios on a discretionary or non-discretionary basis. R&GWM primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and options. The Firm also reserves the right to use independent investment managers (“Independent Managers”) for the management of client assets. The Firm also utilizes various internally-generated investment models comprised of mutual funds and ETFs to manage client assets through its Tactical Asset Allocation Program (“TAAP”). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients may engage R&GWM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, R&GWM directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. R&GWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. R&GWM consults with clients on an initial and ongoing basis to assess their specific horizon, risk tolerance, time liquidity constraints and other related factors relevant to the portfolios. Clients are advised to promptly notify R&GWM if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if R&GWM determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement

Plan Rollover Recommendations When R&GWM provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that R&GWM is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way R&GWM makes money creates conflicts with your interests, so R&GWM operates under a special rule that requires R&GWM to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, R&GWM must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (give prudent advice); Never put the financial interests of R&GWM ahead of you when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that R&GWM gives advice that is in your best interest; Charge no more than is reasonable for the services of R&GWM; and Give Client basic information about conflicts of interest.
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• To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by R&GWM, please know that R&GWM and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by R&GWM. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by R&GWM. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in R&GWM receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by R&GWM and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of R&GWM or our affiliated personnel. Sponsor and Manager of Wrap Program R&GWM does not sponsor or manage a wrap program. Use of Independent Managers R&GWM reserves the right to select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. R&GWM will evaluate a variety of information about Independent Managers, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm will seek to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. R&GWM will also take into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. R&GWM will continue to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm will monitor the performance of those accounts being managed by Independent Managers. R&GWM will seek to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.