Retirement Fund Management, LLC ("RFM") was formed in 1995. While RFM primarily provides retirement plan management/consulting services to corporate/institutional clients with retirement plans, it also offers portfolio management services to individuals with IRA portfolios. Mark Edward McCoy is the sole principal owner of RFM. Please see Brochure Supplements for more information on Mr. McCoy and other individuals who formulate investment advice and have direct contact with clients or have discretionary authority over client accounts. SERVICES OFFERED Retirement Plan Advisory Services Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring that prudent procedural steps are followed in making investment decisions. RFM will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular services provided will be detailed in the agreement. The appropriate Plan Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended services for the Plan. Retirement Plan consulting services may be offered separately or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 ("ERISA") sets forth rules under which Plan Fiduciaries may retain investment advisers for various types of services with respect to Plan assets. For certain services, RFM will be considered a fiduciary under ERISA. For example, RFM will act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries by recommending a mix of investments as choices among which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain RFM to act as an investment manager within the meaning of ERISA § 3(38), RFM will provide discretionary investment management services to the Plan.
With respect to any account for which RFM meets the definition of a fiduciary under Department of Labor rules, RFM acknowledges that both RFM and its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement between RFM and Client.
RFM provides retirement plan management and consulting services primarily to corporate/institutional clients with retirement plans.
The RFM total retirement plan management approach includes two components.
Investment Process Services
•Proprietary system to screen, analyze and select funds representing 57 different asset classes
•Evaluate and select complementary asset classes to provide an optimum mix of investment options for participants that will accommodate various retirement plan scenarios Additional Plan Services
•Evaluate and select retirement plan custodians, record-keepers, third party administrators and trustees
•Develop a customized retirement plan Investment Policy Statement
•Conduct education and enrollment programs for retirement plan participants 4 Fiduciary Investment Consulting or Investment Advice Services
•Investment Selection Services - RFM will provide Plan Fiduciaries with recommendations of investment options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of investment options and for compliance with ERISA section 404(c).
•Non-Discretionary Investment Advice - RFM provides Plan Fiduciaries and Plan Participants general, non-discretionary investment advice regarding assets classes and investments.
•Investment Monitoring - RFM will assist in monitoring the plan's investment options by preparing periodic investment reports that document investment performance, consistency of fund management and other relevant factors. The investment options will conform to the guidelines set forth in the investment policy statement and RFM will make recommendations to maintain or remove and replace investment options. The details of this aspect of service will be enumerated in the agreement between the parties. Fiduciary Investment Management Services
•Discretionary Management Services - When retained as an investment manager within the meaning of ERISA § 3(38), RFM provides continuous and ongoing supervision over the designated retirement plan assets. RFM will actively monitor the designated retirement plan assets and provide ongoing management of the assets. When applicable, RFM will have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first

consulting with the Plan Fiduciaries. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
•Discretionary Investment Selection Services - RFM will monitor the investment options of the Plan and add or remove investment options for the Plan without prior consultation with the Plan Fiduciaries. RFM will have discretionary authority to make and implement all decisions regarding the investment options that are available to Plan Participants.
•Investment Management via Model Portfolios (i.e. Custom Target Retirement Date or Risk- Based) - RFM will provide discretionary management of Model Portfolios among which the participants may choose to invest as Plan options. Plan Participants will also have the option of investing only in options that do not include Model Portfolios (i.e., the Plan Participants may elect to invest in one or more of the core investment options made available in the Plan and choose not to invest in the Model Portfolios at all). Non-Fiduciary Services
•Participant Education - RFM can provide education services to Plan Participants about general investment principles and the investment alternatives available under the Plan. Education presentations will not take into account the individual circumstances of each Plan Participant and individual recommendations will not be provided. Plan Participants are responsible for implementing transactions in their own accounts.
•Participant Enrollment - RFM can assist with group enrollment meetings designed to increase retirement Plan participation among employees and investment and financial understanding by the employees. Individual Client Services RFM can provide investment management advice to a very limited number of individuals with IRA portfolios. These individual accounts are not solicited and must be initiated by the individual, through their connection with a current RFM corporate institutional client. In such circumstances, RFM provides ongoing management of the portfolio. 5 For portfolio management of individuals, RFM spends time with the client, asking questions, discussing the client's investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, RFM generally develops with each client:
•a financial outline for the client based on the client's financial circumstances and goals, and the client's risk tolerance level (the "Financial Profile" or "Profile"); and
•the client's investment objectives and guidelines (the "Investment Plan" or "Plan"). To implement the client's retirement plan, RFM will manage the client's investment portfolio on a discretionary basis. As a discretionary investment adviser, RFM will have the authority to supervise and direct the portfolio without prior consultation with the client. The Financial Profile is a reflection of the client's current financial picture and a look to the future goals of the client. The Investment Plan outlines the types of investments RFM will make on behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each client but are not necessarily written documents. The Investment Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by RFM based on updates to the client's financial or other circumstances. To implement the client's retirement plan, RFM will manage the client's investment portfolio on a discretionary basis. As a discretionary investment manager, RFM will have the authority to supervise and direct the portfolio without prior consultation with the client. Notwithstanding the foregoing, clients may impose certain written restrictions on RFM in the management of their investment portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of RFM. Assets Under Management As of December 31, 2023, we provide continuous management services for $692,530,840 in client assets on a non-discretionary basis.