Our firm manages assets for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. As a fiduciary it is our duty to always act in the client’s best interest. This is accomplished in part by knowing the client. Our firm has established a service-oriented advisory practice with open lines of communication. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Our wrap fee program allows clients to pay a single fee for investment advisory services and associated custodial transaction costs. Because our firm’s Investment Advisor Representatives (“IARs”) absorb client transaction fees, an incentive exists to limit trading activities in client accounts. Custodial transaction costs, however, are not included in the advisory fee charged by our firm for non-wrap services, and are to be paid by the client to their chosen custodian. Depending on the client’s account or portfolio trading activity, clients may pay more for using our wrap fee services than they would for using our non-wrap services. However, clients should be aware that LPL Financial’s trading platform (“SWM”) offers a variety of investments including, but not limited to, individual stocks, individual bonds, exchange traded funds (“ETFs”), and mutual funds. LPL Financial has made available to our firm and our IARs a suite of $0 transaction fee mutual funds and ETFs and investment alternatives that may or may not have transaction fees. As a SWM client, all fees charged by fund companies or LPL Financial are wrapped, which means that our IAR’s pay any transaction fees charged to you, (if present in that particular investment). Therefore, with the introduction of $0 transaction fee mutual funds and ETFs, our firm’s IARs expenses have decreased. This change may incentivize our IARs to recommend no-transaction- fee ETFs over other types of securities in order to reduce their costs. This may present a conflict of interest by limiting the investments chosen to use to only those funds with no transaction fees. Therefore, while our IARs consider transaction fees in their buying decisions, they are not our IAR’s sole deciding factor. Our firm and IAR’s primary focus is what is in the best interest of the client and their portfolio. Thus, our firm will base our decisions on a number of factors, including, but not limited to, the merits of the investments, how that investment fits within the client’s investment objectives and risk tolerance, and the client’s overall investment goals. We will also consider the overall fees of the investment, performance history of the investment, and the actual investments within a particular ETF or mutual fund. Our

Wrap Advisory Services Wrap Comprehensive Portfolio Management: As part of our Wrap Comprehensive Portfolio Management service a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Rubicon Advisors Fee Schedule The maximum annual fee to be charged to the client’s account(s) will not exceed 1.90%. The fee to be assessed to each account will be detailed in the client’s signed advisory agreement, LPL Account Application or LPL Tiered Fee Authorization form. The total estimated fee, as well as the ultimate fee charged, is based on the number of client’s asset managed by our firm’s IARs as well as the scope and complexity of our engagement with the client. Fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Fees are negotiable and will be deducted from the account(s). Please note that fees will be adjusted for deposits and withdrawals made during the quarter. If accounts are opened during the quarter, the pro-rata advisory fees will be deducted during the next regularly scheduled billing cycle. Our firm bills on cash unless indicated otherwise in writing. In rare cases, our firm will agree to direct bill clients. As part of this process, Clients understand the following: a) LPL as the client’s custodian sends statements at least quarterly, showing all disbursements for each account, including the amount of the advisory fees paid to our firm; b) Clients provide authorization permitting LPL to deduct these fees; c) LPL calculates the advisory fees for all fee schedules and deducts them from the client’s account. Other Types of Fees & Expenses: The fees not included in the advisory fee for our wrap services are charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Wrap Fee Program Recommendations Our firm does not recommend or offer the wrap program services of other providers.