A. Description of the Advisory Firm RPC Private Wealth, LLC (hereinafter “RPCPW”) is a Limited Liability Partnership organized in the State of Illinois. The firm was formed in September 2018, and the principal owner is Thomas Edward Westrick. B. Types of Advisory Services Portfolio Management Services RPCPW offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RPCPW evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RPCPW will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. RPCPW seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of RPCPW’s economic, investment or other financial interests. To meet its fiduciary obligations, RPCPW attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RPCPW’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RPCPW’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. RPCPW provides account management under three levels of service structures. Our first structure is a comprehensive service that provides account management on a continuous basis and is referred to internally and with clients as our FundMAP platform. Clients on FundMAP have Charles Schwab as the custodian of their accounts. Clients’ accounts on the FundMAP platform have their account transactions reviewed daily by all advisors in the firm, receive quarterly performance reports, have more frequent meetings, written, and oral communications with their RPCPW advisor regarding their accounts and other financial planning topics, have the activity in their accounts reviewed at least quarterly, generally utilize a more robust variety of investment managers and styles, and are likely to have more account maintenance trades (such as rebalancing and capital gain/loss management) done in their accounts. Due to the more engaged level of advisory service, clients on the FundMAP platform are likely to be charged the highest advisory fee. Our second structure provides a less robust level of investment advisory service and is referred to internally and with clients as our F2 platform. Under this platform, clients’ accounts use American Funds mutual fund company as their custodian. Investments utilized are exclusively American Funds and almost exclusively use their “F2” fee only share class. Under this platform, clients pay the lowest level of advisory fee. RPCPW’s ongoing account management services are more limited and typically do not include more than annual account reviews and rebalancing trades. Client meetings are generally limited to annual in person or phone calls, and modest consulting conversations related to non- portfolio financial planning topics and issues. Our third structure of service is referred to as our variable annuity and 529 plan platforms. Clients on this platform typically have Nationwide Advisory Services Company serve as the custodian of their variable annuity accounts and Bright Directions or American Funds serve as the custodian of

their 529 plan accounts. Under this platform, clients typically pay an advisory fee slightly above the F2 platform but less than the FundMAP platform. The level and complexity of advisory and financial planning services provided to clients on this platform are similar to those provided on the F2 platform. Under all platforms, subject to a grant of discretionary authority, RPCPW, through its IARs or any recommended sub-advisers, shall invest and reinvest the securities, cash or other property held in the client’s account in accordance with the client’s investment objectives as identified by the client during initial interviews and information gathering sessions. Such suitability information is reviewed and updated as needed by the client’s advisor at least annually. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments RPCPW generally limits its investment advice to mutual funds, real estate funds (including REITs), and Exchange Traded Funds (ETFs). RPCPW primarily recommends clients invest mostly in mutual funds and ETFs. RPCPW may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions RPCPW offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon each client’s current situation (income, tax levels, investment time horizon, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RPCPW from properly servicing the client account, or if the restrictions would require RPCPW to deviate from its standard suite of services, RPCPW reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. RPCPW does not participate in wrap fee programs. E. Assets Under Management RPCPW has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $218,766,382.00 $1,886,273.00 December 2023