RK Financial is a fee-only advisory firm offering financial planning and investment management services to its clients. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with RK Financial setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). RK Financial has been an independent registered investment adviser since 1986 and is wholly owned by Patricia F. Raskob. As of December 31, 2022, the Firm had $82,981,357 of assets under management, of which $45,665,378 was managed on a discretionary basis and $37,315,979 was managed on a non- discretionary basis. While this brochure generally describes the business of RK Financial, 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 RK Financial’s behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services RK Financial offers clients a range of financial planning and consulting services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Asset Allocation
• Retirement Planning
• Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Needs Analysis
• Retirement Plan Analysis
• Charitable Giving
• Risk Management
• Distribution Planning While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management (as described below). In performing these services, RK Financial 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. RK Financial may recommend the services of itself or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage RK Financial to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by RK Financial under a financial planning or consulting engagement or to engage the services of any such Page 5 © MarketCounsel 2023 recommended professionals, including RK Financial itself. 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 RK Financial’s previous recommendations and/or services. Retirement Plan Consulting Services RK Financial provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning and Benefits
• Investment Management and Review
• Plan Fee and Cost Analysis
• Retirement Plan Committee Consultation
• Fiduciary and Compliance
• Legacy Plan Services As disclosed in the Agreement, certain of the foregoing services are provided by RK Financial as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of RK Financial’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the

Firm reasonably expects under the engagement. Investment Management Services RK Financial manages client investment portfolios on a discretionary or non-discretionary basis. RK Financial primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual equity and debt securities, in accordance with the investment objectives of its individual clients. On a limited basis, RK Financial recommends clients utilize certain independent investment managers (“Independent Managers”). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can also engage RK Financial to 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, RK Financial directs or recommends the allocation of client assets among the various investment options available with Page 6 © MarketCounsel 2023 the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. RK Financial tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. RK Financial consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify RK Financial 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 RK Financial 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. Use of Independent Managers As mentioned above, RK Financial recommends 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 are set forth in a separate written agreement between the designated Independent Manager and the client. In addition to this brochure, clients also receive the written disclosure documents of the designated Independent Managers engaged to manage their assets. RK Financial does not receive compensation from any such Independent Managers. RK Financial evaluates various information about the Independent Managers it chooses to manage client portfolios, 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 seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. RK Financial also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. RK Financial continues to provide services relative to the non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. RK Financial seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests.