A. Howe and Rusling, Inc. (Howe and Rusling or H&R) is a registered investment advisor, founded in 1930. Our principal owner is Craig Cairns, President, Chairman, and Chief Executive Officer. B. Howe and Rusling, Inc. primarily offers large cap equity and intermediate fixed income investment management. Howe and Rusling, Inc. researches security selection, and tactical asset class and sector allocations. Howe and Rusling, Inc. assists our clients with some financial planning and on occasion uses outside asset managers and ETFs, but mainly specializes in security selection. Howe and Rusling, Inc. has three primary equity strategies: Core Equity Portfolio: A diversified portfolio of approximately 40 large cap equities, Howe and Rusling’s primary strategy. Equity Income Portfolio: A portfolio of approximately 30 higher dividend equities, intended for clients looking to increase their portfolio income, or reduce their portfolio volatility. Our fixed income analysts use a combination of macroeconomic analysis & forecasting, proprietary modeling, sector-specific research, and financial reporting analysis. All securities are considered based on their yield to maturity, risk/reward profile, their liquidity, and how they fit into each portfolio. Howe and Rusling’s primary fixed income expertise is in the Treasury, agency, investment grade corporate, municipal, and agency mortgage-backed sectors; however, Howe and Rusling also has experience in other sectors. Howe and Rusling has robust trading programs and best-execution policies to ensure our clients get competitive pricing, and to maximize their liquidity. ESG Investments: In addition to applying various ESG screens to individual securities, Howe and Rusling may also select Exchange Traded Funds (“ETFs”) or third-party manager accounts that are managed by unaffiliated third parties. In such cases, Howe and Rusling has no control over the selection of investments within those ETFs or accounts and does not administer any positive or negative screens to assess the appropriateness of any individual securities bought or sold for the ETFs. Instead, Howe and Rusling relies on the representations and screening processes of the third-party advisers responsible for managing each ETF and/or account. While Howe and Rusling will conduct due diligence on each manager’s overall investment mandate and philosophy, Howe and Rusling cannot guarantee that each security held within the ETF or third-party account structure will align with the ESG objectives and restrictions expressed by its clients. Financial Planning/Consulting Services: We may offer some clients financial planning services which address some or all of the following areas:
• Personal: Family records, budgeting, personal liability, estate information, and financial goals.
• Tax & Cash Flow: Income tax and spending analysis and planning for past, current, and future years. We will illustrate the impact of various investments on a client's current income tax and future tax liability.
• Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning, and disability income analysis.
• Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals.
• Investments: Analysis of investment alternatives and their effect on a client's portfolio.
• Estate Planning: Analysis of financial issues with respect to living trusts, wills, estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. Typically, the financial plan and/or agreed-upon deliverables will be presented to the client within six weeks of receiving the client’s material, provided that all information needed to

prepare the agreed-upon materials has been promptly provided by the client. Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, insurance issues, annuity advice, or any other specific topic. We tailor all of our financial planning and consulting recommendations to the individual needs of each client. All recommendations are based on information gathered through client questionnaires and telephone and in-person discussions. Use of Sub-Advisers and Third-Party Managers: We may also, when appropriate, sub-advise certain portions of a client portfolio to independent third-party managers or recommend direct investment with independent third-party managers, typically when those managers demonstrate knowledge and expertise is a particular investment strategy. As part of this service, we perform management searches of various unaffiliated registered investment advisers. Based on a client's individual circumstances and needs (as exhibited in the client's IPS) we will determine which selected registered investment adviser's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client, and the investment philosophy of the selected registered investment adviser. We encourage clients to review each third-party manager’s disclosure document regarding the particular characteristics of any program and manager selected by us. Once we determine which selected registered investment adviser(s) are most appropriate for the client, we will provide the selected registered investment adviser(s) with the client's IPS or other suitability information. The selected registered investment adviser(s) will then create and manage the client's portfolio based upon the client's individual needs. We will regularly and continuously monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) are not providing sufficient management services to the client, or are not managing the client's portfolio in a manner consistent with the client's IPS, we will remove the client's assets from that selected registered investment adviser(s) and place the client's assets with another registered investment adviser(s) at our discretion and without prior consent from the client. Our firm will conduct appropriate due diligence on all independent third-party managers, making reasonable inquiries into their performance calculations, policies and procedures, Code of Ethics, and other operational and compliance matters deemed important to account performance and risk management. Consulting Services for Other Financial Professionals: We also offer consulting services to unaffiliated independent investment advisers and/or other financial professionals. Depending on the specific arrangement, we may provide these clients with security selections, weights, and allocations for use in their own managed portfolios. C. We do allow our clients to impose restrictions for certain investments. These restrictions generally regard issues relating to:
• asset mix
• an individual security
• investment characteristics (e.g. debt rating, foreign investments, social issues) Any investment restrictions placed upon an account are agreed upon in advance with the client and captured on the asset allocation agreement between the client and advisor. D. We do not currently sponsor or participate in any wrap fee programs. E. Howe and Rusling had 2,584 discretionary accounts valued at $1,672,222,403 and 15 non-discretionary accounts valued at $2,878,630 as of December 31, 2023.