Rockbridge Investment Management, LLC (hereinafter referred to as “RIM”) has been in business since 1997. The principal owners are Craig Buckhout and Anthony Farella. Assets Under Management As of December 31, 2023, RIM manages $1,485,188,276 in client assets broken down as follows: Discretionary - $1,436,751,242 Non-Discretionary - $48,437,034 Investment Management Services We provide investment management services to our clients on a discretionary and non-discretionary basis. When we manage client assets on a discretionary basis, we execute securities transactions for clients without having to obtain specific client consent prior to each transaction. Discretionary authority is limited to investments within clients’ managed accounts. When we manage client assets on a non-discretionary basis, we notify client and obtain specific client consent prior to each transaction. We also provide investment management services including, advice regarding asset allocation and the selection of investments, portfolio design, asset allocation, investment plan implementation and ongoing investment monitoring. We rely on the stated objectives of the client and consider the client’s risk profile and financial status prior to making any recommendations. Investment Supervisory Services Investment supervisory services consist of constructing a portfolio for each client to achieve established risk objectives. The portfolio may include various funds, primarily passively managed, that would have the greatest probability of achieving the returns allowed by global capital markets at the lowest cost. The portfolio would be rebalanced on a regular basis to reflect previously established commitments to each market/asset class. We also provide investment supervisory services for 401(k) or other qualified retirement plans that consist of constructing a portfolio to achieve established risk objectives. The portfolio would include various funds, primarily passively managed, that would have the greatest probability of achieving the returns allowed by global capital markets at the lowest cost. The portfolio would be rebalanced on a regular basis to reflect previously established commitments to each market/asset class. Financial Planning and Consulting Services For certain clients we may provide financial planning and consulting services under a separate fee arrangement that are consistent with the client’s financial and tax status, in addition to risk profile and return objectives. We may also provide general

non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. We start the comprehensive financial planning process by taking a financial inventory. This generally involves gathering enough data to perform an analysis of client liabilities, cash flow and net worth analysis, and tax assessments. Our next step typically involves assisting clients with formalizing their goals and plotting their investment timelines. Financial Planning Conflicts of Interest When both investment management and financial planning services are offered, there is a potential conflict of interest since there is an incentive for an advisor offering financial planning services to recommend services for which the advisor, or a related party, may receive compensation. However, financial planning clients are under no obligation to act upon any of our recommendations or to affect any transactions through us if they decide to follow the recommendations. Tax Preparation Services Tax preparation services are offered to RIM clients for an additional fee. These services include:
• Individual Income Tax Returns
• Business Tax Returns
• Trust Tax Returns
• Estate Tax Returns The cost of tax preparation services is in addition to a client’s wealth management fee. In limited circumstances, at RIM’s discretion, tax preparation services are included in a client’s standard wealth management fee. RIM, at its sole discretion, can waive or negotiate fees. All tax preparation services are provided and billed by RIM. Clients are under no obligation to use Rockbridge tax services. When RIM provides investment advice to you regarding your retirement plan account or individual retirement account, RIM is a fiduciary 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. Under the above noted rules, RIM 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.