Russell Capital Management, LLC (RCM) is a SEC-registered investment adviser with its principal place of business located in Lexington, Kentucky. Russell Capital Management, LLC began conducting business in 2011 as a successor to Russell Capital Management, Inc which began conducting business in 1991. Listed below are the firm's principal shareholders, those individuals or entities controlling 25% or more of Russell Capital Management, LLC.
• Harry Leslie Russell Jr., President/Chief Compliance Officer Russell Capital Management offers the following advisory services to our clients which are explained in greater detail in the following pages. INVESTMENT SUPERVISORY SERVICES 1) Individual Portfolio Management 2) Model Portfolio Management a. The Select Account b. Advanced Strategies Account CONSULTING SERVICES Consulting services are provided on a one-off basis. INVESTMENT SUPERVISORY SERVICES 1) INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to clients regarding the investment of their funds based on their individual needs. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment risk tolerance and create and manage a portfolio based on that risk. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Brochure dated 03/31/24 7 Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over the counter
• Certificates of deposit
• Municipal securities
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities 2) MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using our model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal and risk tolerance. Russell Capital Management’s Modular Portfolio Construction (MPC) method of investment diversification is utilized in the Select Account and Advanced Strategy portfolios. MPC is an investment process which requires several investments in each module. Select Account Model Portfolio The Select Account Model is specially designed to suit the unique needs of individual clients through a 5-step investment process. 1) Risk Determination The amount of risk and volatility that the client is willing to accept in their investments is determined

in consultation with the client. RCM assists our clients with this study; among other things, it should include analysis of distribution needs, client's financial situation, anticipated principal withdrawals and additions, and age of the client. 2) Investment Module Design Investment Modules are designed using Exchange Traded Funds “ETFs” which represent diversified portfolios of securities to track specific indexes; each module contains several ETFs, which creates diversification in style and Brochure dated 03/31/24 8 investment returns. Modules may consist of Growth, Aggressive Growth, Value, Global and Fixed Income. Modules may be designed especially for the client’s allocations and requirements. 3) Investment Allocation After the client’s level of risk tolerance is agreed upon and the investment module design is completed, investment allocations are formulated to target risk tolerance with investment allocation mix. 4) Investment Implementation RCM’s experienced staff works with each client to obtain the appropriate account opening and transfer documents for their account at custodian. Transfers are expedited by the professional staff at RCM. 5) Long-Term Monitoring Account modules may be rebalanced to maintain the appropriate balance between investments. All investments are continually monitored to assure that they are maintaining their quality of performance. Advanced Strategies Model Portfolio The Advanced Strategies portfolio of alternative no-load mutual funds and Exchange Traded Funds should be considered a separate asset class from Fixed Income, Equities, Real Estate, Futures, Metals, Commodities and other investments. The Advanced Strategy portfolio consists of several independent modules, each of which follows a different investment strategy. There is a maximum of twenty- four alternative investment funds included in the portfolio. Periodic rebalancing of the portfolio is necessary for smoother returns. The Advanced Strategies portfolio consists of liquid mutual funds and ETFs which attempt to replicate various “hedge fund” strategies and not correlate to the stock, bond, real estate, or commodity markets. The managers of these funds are attempting to provide positive returns in their own strategic models. There are a limited number of mutual funds which fall into the category of alternative funds. Through diligent research we have assembled the funds that are included in our modules. Constant vigilance keeps our portfolio current and the investments suitable for the various modules. Brochure dated 03/31/24 9 CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This may include advice on only an isolated area of concern such as estate planning, retirement planning, or other items related to investments. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. AMOUNT OF MANAGED ASSETS As of 12/31/2023 our total client assets under management are $251,840,636; of which we were actively managing $245,752,545 on a discretionary basis.