D E S C R I P T I O N O F A D V I S O R Y F I R M RTD Financial’s registration was granted by the United States Securities and Exchange Commission on June 13, 1983. Current equity ownership of the firm is as follows: Owns more than ten percent but less than twenty-five percent
• Jeffrey Alan Weiand, (CRD Number 1414639), Chairman & CEO
• Marc Charles Labadie, (CRD 5126545), Executive Vice President
• Mitchell J. Metz, (CRD Number 1417894), Senior Vice President
• Richard J. Durso, (CRD Number 2772293), Chief Financial Officer Owns five percent but less than ten percent
• Christopher Vassallo, (CRD Number 6125551), Vice President of Client Development
• Rachel F. Moran, (CRD 5680934), Vice President of Personal Wealth Management Owns less than five percent
• Elizabeth Ann Davies, President
• Gregory J. Young, (CRD 4128382), Chief Investment Officer
• William G. Love, (CRD 2785894), Senior Financial Planner
• Nicole M. Offerman, (CRD 5050780), Vice President of Employer Retirement Plan Services Kevin Cremi is the firm’s Chief Compliance Officer and Director of Operations. The firm is not publicly owned or traded. There are no indirect owners of the firm. The firm manages each Client’s portfolio on an individualized basis. Clients may impose restrictions on their accounts. The firm does not sponsor any wrap programs. As of December 31, 2023, RTD managed assets on a discretionary basis in the amount of $2,062,949,654 and on a non-discretionary basis, $54,465,110 for a total of $2,117,414,764. Types of Advisory Services Personal Wealth Management Services Typically Available: L I F E - C E N T E R E D P L A N N I N G
• Organize. Advisor will help bring order to Client’s financial life.
• Discover. Advisor will facilitate initial and ongoing listening and discovery to ensure Advisor fully understands Client’s life story, money history and purpose.
• Prioritize. Advisor will assist Client in determining the values and goals most important as well as to help establish a time frame to achieve.
• Identify. Advisor will identify where Client’s human capital and financial resources can best be applied to accomplish short and long-term goals.
• Monitor. Advisor will conduct ongoing reviews and updates to monitor progress toward milestones and alignment with Client’s life’s values. F I N A N C I A L P L A N N I N G
• Analyze. Advisor will evaluate and analyze Client’s current and projected financial wellness.
• Recognize. Advisor will proactively identify challenges and opportunities as they relate to Client’s short and long-term financial achievements.
• Strategize. Advisor will assist Client with the financial implications of life transitions as they occur.
• Visualize. Advisor will assist Client with understanding the impact various scenarios may have on life goals.
• Advise. Advisor will provide advice and recommendations that support Client’s short and long-term goals.
• Assess. Advisor will utilize techniques to efficiently manage taxes.
• Monitor. Advisor will periodically update financial planning projections to ensure Client is able to maintain financial wellness. I N V E S T M E N T M A N A G E M E N T ( U N D E R A D V I S O R ’ S M A N A G E M E N T )
• Develop. Advisor will develop an investment strategy that attempts to align Client’s short and long-term goals with: ▪ Risk Tolerance – the amount of risk Client wants to take. ▪ Risk Capacity – the amount of risk Client needs to take.
• Construct. Advisor will construct a written Investment Policy Statement.
• Advise. Advisor will advise and recommend an asset allocation and Investment selection.
• Implement. Advisor will implement all initial and ongoing trading when needed.
• Re-balance. Advisor will rebalance as per the Investment Policy Statement guidelines.
• Re-allocate. Advisor will reallocate and adjust the portfolio and/or change underlying investments due to changes in the economy, Client’s objectives, or security performance criteria.
• Tax Plan. Advisor will attempt to minimize investment related taxes on an ongoing basis.
• Report. Advisor will provide quarterly performance reporting.
• Monitor. Advisor will monitor underlying investments and Client allocation on an ongoing basis. Client Tailored Services and Client Imposed Restrictions Specific Client financial plans and their implementation are dependent upon the Client’s Investment Policy Statement which outlines each Client’s current situation (liquidity needs/tax constraints, if applicable and risk tolerance levels). It is used to construct a Client specific plan to aid in the selection of a portfolio of investments that matches restrictions, needs, and targets. 3(38) Investment Management for Employer Retirement Plans RTD provides investment management services to retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), referred to here as “ERISA Plan Clients”. Each ERISA Plan Client is required to enter into an investment management agreement with RTD describing the services that RTD will perform for the ERISA plan and if agreed to by the ERISA Plan Client, the ERISA plan participants. RTD provides both ERISA fiduciary services and non-fiduciary services to ERISA Plan Clients. i. Plan Level Fiduciary Services a. Discretionary Investment Management Services under ERISA §3(38). RTD provides investment management services to ERISA Plan Clients on a discretionary basis as an investment manager under ERISA Section 3(38) and in that capacity, RTD’s investment decisions are made in its sole discretion without the ERISA Plan Client’s prior approval. RTD’s investment management services include the following:
• RTD will develop an investment policy statement (IPS) for the Client. The IPS establishes the investment policies and objectives for the ERISA Plan.
• For Plan Clients that are participant-directed:
• RTD will select a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. The investment options selected by RTD may include the RTD managed portfolios in which RTD is the fund manager. If these RTD managed portfolios are made available as plan investment options, it will not result in additional compensation to RTD.
• RTD will provide ongoing and continuous discretionary investment management with respect to the asset classes and investment alternatives available under the ERISA

Plan in accordance with the IPS. Under this authority, RTD may remove and replace the investment alternatives available under the ERISA Plan in its discretion.
• If the Client decides to have a qualified default investment alternative (“QDIA”) for participants who fail to make an investment election under the ERISA plan, RTD will select the investment to serve as the QDIA. The Client retains the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5).
• For Plan Clients that are not participant-directed (i.e., pooled plans):
• RTD will develop asset allocations and portfolio modeling consistent with the Plan objectives expressed in the IPS.
• In accordance with the IPS, RTD will identify and select specific investments to populate the asset allocation categories.
• As investment results and/or cash flow change the percentage of Plan assets represented by the different asset allocation categories, RTD will provide periodic re-balancing as deemed appropriate in accordance with the IPS.
• RTD will adjust the asset allocations as deemed appropriate in accordance with the IPS.
• RTD will monitor and measure investment performance and adherence to the IPS. RTD can make changes in the selected investments, if appropriate, and will provide the Client with periodic reporting of investment performance and results. b. Non-Discretionary Investment Advisory Services for Participant-Directed Plans Clients who executed a Non-Discretionary Investment Advisory Service Agreement for Participant-Directed Plans prior to July 1, 2014 are grandfathered and will remain on the agreement in effect at that time until they convert to a 3(38) Investment Management agreement. ii. Participant-Level Fiduciary Services Non-Discretionary Investment Advisory Services If agreed to by the Client, RTD will provide non-discretionary investment advice to Plan participants about Plan investment alternatives. Plan participants will have the final decision-making authority regarding the initial selection, retention, and changes in investment selections. a. Plan-Level Non-Fiduciary Services for Participant-Directed and Pooled Plans If agreed to by the Client, RTD will perform the Non-Fiduciary services described below or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between RTD and Client.
• Educate the Client as to its fiduciary responsibilities.
• Assist the Client in monitoring, selecting and supervising service vendors by providing consulting services on these matters.
• Prepare fee analysis and benchmarking studies. b. Participant-Level Non-Fiduciary Services for Participant-Directed Plans
• Assist in initial and ongoing enrollment and education sessions with employees designed to increase retirement plan participation and to improve investment and financial understanding.
• Assist in the education of the participants in the Plan about general investment principles and investment alternatives available under the Plan. RTD’s assistance in participant investment education will be consistent with prevailing Department of Labor guidance. As such, RTD does not provide fiduciary advice (as defined in ERISA) in our education program to the participants. Retirement Account Clients Potential for Conflict of Interest RTD is a fiduciary under ERISA with respect to investment management services and investment advice provided to ERISA clients, including ERISA plan participants if making recommendations or giving individualized investment advice to the participants. RTD is also a fiduciary under the Internal Revenue Code (the “IRC”) with respect to investment management services and investment advice provided to ERISA plans, ERISA plan participants, IRA owners and IRAs (collectively, Retirement Account Clients). As such, RTD is subject to specific duties and obligations under ERISA and the IRC that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice in which it has a conflict of interest, the fiduciary must either avoid or eliminate the conflict or rely upon a Prohibited Transaction Exemption (“PTE”). A conflict of interest would arise, and the prohibited transaction rules would be implicated if RTD were to provide fiduciary advice about plan distributions and rollovers if it results in RTD receiving compensation that it would not have received absent the advice. In that instance, RTD would mitigate this conflict by acting in the best interest of the client. No client is under any obligation to roll over ERISA plan or IRA assets to an account advised or managed by RTD. Investment Management for Trusts and Non-Profits After assessing Client’s goals, objectives, time horizon and risk tolerance, Advisor will recommend a diversified portfolio and provide continuous and regular supervision of this portfolio. Clients may place reasonable restrictions on investing in certain securities or types of securities. Advisor’s Investment Management services include the following:
• Develop a written Investment Policy Statement.
• Investment selection and execution of trades.
• Quarterly performance reporting.
• Re-balance the portfolio when appropriate.
• Re-allocate the portfolio due to changes in the economy, of the Client’s objectives, or performance of the underlying securities managed.
• Portfolio tax management where appropriate. Investment Consulting for Trusts and Non-Profits After assessing Client’s goals, mission, objectives, time horizon, risk tolerance, and discussing with Client, Advisor will recommend a diversified portfolio and provide continuous and regular supervision of this portfolio. Client is responsible for providing information to Advisor. Advisor is not responsible for the accuracy of the information provided. Advisor’s Investment Consulting services include the following (collectively, the “Services”):
• Review Client’s outside assets to ensure they are in ongoing compliance with a written Investment Policy Statement.
• Quarterly performance reporting.
• Recommend re-allocation of the portfolio within the approved ranges of the Investment Policy or recommend a new investment range due to changes in the economy, of the Client’s objectives, or performance of the underlying securities managed on a solely non-discretionary basis.
• Annual education and fiduciary training session for new board and finance committee members
• Meeting attendance and updates with finance committee or board.