Firm Description Retirement Management Systems Inc. (RMS) is an independently owned and operated investment advisory firm offering Savings Plan Management, Portfolio Management, and Financial Planning services. Established in 2008 as a corporation, Retirement Management Systems registered with the U.S. Securities and Exchange Commission (SEC) in February 2010. Principal Owners RMS is privately owned. J. Michael Scarborough is majority owner. Savings Plan Management Our Savings Plan Management service is offered to individual clients either directly from RMS or through a relationship with other Registered Investment Advisers (RIAs) and their Investment Adviser Representatives (IARs). These partners introduce clients to our service in either a Solicitor or an Adviser role. Clients may hire these professionals for other services outside the scope of Savings Plan Management on an as-needed basis. In the event that conflicts of interest occur, we will disclose them to clients. Individual clients are those people participating in defined contribution plans (e.g., 401(k), 403(b), 457), where the person is responsible for selecting the investments that will help him or her save for retirement. Often these people are in need of help in selecting, implementing and monitoring an investment program for their defined contribution plan savings. Savings Plan Management offers that support. As a part of the Savings Plan Management program, RMS:
• researches the investment options available within a client’s defined contribution plan
• develops an appropriate investment strategy based on one of seven investment models that cover a range of risk and return characteristics from conservative to aggressive
• implements the investment strategy agreed upon by the client
• reallocates the strategy to reflect changing market and economic conditions, while staying within the parameters of risk and return parameters for the client
• rebalances the strategy to maintain the appropriate balance of risk and return characteristics within the strategy
• communicates with the clients and their Investment Adviser Representatives regarding research findings, reallocation strategies, and retirement planning Due to the nature of the accounts on which we provide our advisory service, RMS limits its advice to those types of investments typically found in qualified plans such as mutual funds, exchange traded funds, unit investment trusts (including those that invest in a sponsoring company’s stock), and group variable annuity sub-accounts. Discretionary Asset Management Clients grant RMS limited discretionary trading authority to conduct trading for the account in which the client assets are held, and at client’s risk, to purchase, sell, exchange, and otherwise trade the account assets in accordance with the Investment Policy Statement provided to the client. Clients may impose reasonable restrictions on investing in certain securities or types of securities. RMS does not represent, warrant or imply that the services or methods of analysis used can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses. No guarantees can be offered that client’s goals or objectives will be achieved. Clients authorize RMS to access their account using the client’s personal identification and password. Under no circumstances will RMS facilitate loans from the account or redeem, withdraw, dispense, or distribute funds from the Account. RMS takes precautions to safeguard client’s personal identification and password. However, depending on the functions allowed by the Plan’s custodian website, unauthorized access to the client’s account could result in adverse consequences, including distributions, loans, address changes, and beneficiary changes. Additionally, RMS does not maintain a formal relationship with the client’s defined contribution custodian/recordkeeper and, as such, these companies provide no oversight of RMS’s client account access. Certain record keepers have formal security guarantees that may become void as a result of their participants divulging security credentials to a third party such as RMS. Non-Discretionary Advice Individual clients may wish to implement our portfolio recommendations on their own. For this “Do It Yourself” service, we send quarterly allocation recommendations to a client’s email address, with instructions where possible, on how to implement the trades. Clients are free to accept, reject, or implement any portion of the recommendations provided by RMS. Be aware that partial implementation or delayed implementation may have an impact on the performance of the account. Because RMS does not have access to monitor client assets, clients will be responsible for providing RMS with copies or duplicate statements. Advisory Agreement Individual clients wishing to engage RMS for the provision of its investment advisory services must complete RMS’s advisory agreement documents. Upon completion, RMS will be considered engaged by the client. The term of engagement will be an ongoing term, as set forth in the Agreement. Clients will be responsible for ensuring that RMS has been informed of changes in investment objectives and risk tolerance. To assist, RMS requests that clients complete the Investor Profile questionnaire annually upon renewal of the term. Termination of Agreement Upon termination of the Agreement by either party, RMS will not be under any obligation to provide further services with regard to client assets, and client will be solely responsible for the investment of the client assets. The power of attorney in Section III of the Discretionary Asset Management Agreement shall be revoked. Client agrees that any termination of the Agreement will not affect the liabilities or obligations of the parties under the Agreement which arise from transactions initiated prior to termination, including the provisions regarding arbitration, which shall survive any termination of the Agreement. Special Considerations for IRA Rollovers Qualified retirement plans (such as the 401(k)) offer their participants the ability to rollover their money into an Individual Retirement Account (IRA) at separation of service or at other qualifying events, such as attainment of age 59 ½. Investment Adviser Representatives are considered fiduciaries for any specific advice or recommendations they give to clients. Therefore, any recommendation to rollover money into an IRA must be given in the client’s best interest. RMS assumes no fiduciary obligation for rollover recommendations given by IAR’s of other investment advisory firms. There is a conflict of interest for an Investment Adviser Representative to recommend an IRA rollover when an increase in compensation would result. Clients are encouraged to carefully evaluate advantages and disadvantages of an IRA rollover. Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we 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. Portfolio Management Services RMS provides portfolio management services to individuals outside of their employer sponsored plan. This service is provided on a discretionary basis meaning that RMS Investment Adviser Representatives (IAR) purchase or sell investments on behalf of the client without obtaining specific client prior consent for each transaction in accordance with the asset management contract. The asset management contract is provided to each client prior to the onset of the service, and should be read carefully by the client for further information. This service involves allocating the client’s investment portfolio among investments available through

Schwab Advisor Services™ of Charles Schwab & Co. (“Schwab”). RMS provides the IARs with model portfolios that are intended as guidelines. IARs can use the models as created, deviate from models, or not use them at all. Portfolio Management services incorporates an investor profiling process. We use a quantifiably scored investor profile questionnaire that helps guide the discussion between Advisor and client regarding an appropriate risk and return profile for the client’s portfolio. Clients may impose reasonable restrictions on investing in certain securities or types of securities. Schwab is the selected third-party clearing broker- dealer/custodian that will execute trades, settle securities transactions and custody client assets for these advisory accounts on behalf of RMS and its IARs. In evaluating Schwab as a potential broker- dealer/custodian, it was noted that Schwab has financial strength, extensive reporting, and execution pricing and research. Schwab makes available to RMS clients a broad array of no-load, no transaction or low transaction cost mutual funds. RMS does not sponsor a wrap, unbundled wrap, or fee and commission offset program through these firms. As a point of differentiation from the Savings Plan Management service, RMS does not limit its advice to mutual funds, exchange traded funds, unit investment trusts (including those that invest in a sponsoring company’s stock), and group variable annuity sub-accounts. Clients also have access to accounts that invest in covered call transactions. These accounts have a higher fee structure and are subject to higher degrees of market risk due to their individual stock concentrations. Investors interested in a covered call account should carefully evaluate all additional costs and risks before investing. Please refer to Item 8 for more information. Consultation Service RMS will analyze and make recommendations on a broad array of financial issues on a consultative basis. Among other things, this consultation service may include portfolio asset allocation, financial advice regarding personal and business situations, and/or other financial planning services. Financial Planning RMS also provides advice in the form of a Financial Plan. While the specific categories to be reviewed will be determined based on the client’s particular financial situation, categories for review may include the following: a.) Investment Planning – Review client’s current financial situation and issue a written report of recommendations. Prepare an asset allocation program tailored to client’s financial objectives and Investor profile. b.) Budgeting – Review client’s current budget and provide feedback based upon the client’s stated goals and lifestyle. Prepare balance sheet showing client’s assets, liabilities, and net worth. Prepare a cash flow statement that reflects client’s income, living expenses and investment funding. c.) Estate Planning – Coordinate wills and other estate planning documents and arrangements. Make recommendations and assist others in recommendations that minimize the tax consequences and maximize efficient disposition of client’s estate within the constraints of client’s plans and goals. Fees for this service would be in addition to any legal fees from third parties, all of which will be borne by client. d.) Insurance Counseling – Work with the client to identify insurance needs based on the client’s individual goals and circumstances, including but not limited to providing for adequate coverage in case of an injury, long term care needs, or death. Coordinate life insurance, disability insurance, and other insurance policies. All selections and coverages are the responsibility of client. IARs will be compensated in their separate capacity as insurance agents for insurance policies sold by IARs. Any incidental legal fees and/or other insurance costs from third parties will be borne by the client. e.) Retirement Planning – Coordinate investment planning to assist client in accumulating capital for their retirement and creating an income plan to meet financial needs in retirement. Make recommendations on establishing individual or other retirement accounts. f.) Tax Planning - IAR will take into account the general tax consequences for all recommendations made to the client. However, IAR nor RMS will not provide tax or legal advice and the client needs to rely solely on their own accounting firm, law firm, or tax preparer for such advice. The CFP® and/or the IAR gather required information such as current financial status, future goals, and attitudes towards risk through personal interviews. Related documents supplied by the client are carefully reviewed, and then the Financial Plan document prepared. Financial Plan recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. Recommendations are generally of a generic nature. Should a client choose to implement the recommendations contained in the plan, the CFP® and/or the IAR will seek to utilize the insurance, advisory and/or brokerage services most desirable to the client. For specific tax and legal matters, the CFP® and/or IAR will suggest that the client work closely with their attorney or accountant. Clients should be aware that if they choose to utilize RMS’s services in implementing all or a portion of the Financial Plan, RMS will receive additional compensation, of which the CFP® and/or IAR who prepared the Plan will receive a portion, depending on the specific products or services chosen. Given that the fees for these services are in addition to any fee paid for the preparation of the Financial Plan, a conflict of interest exists because there is a financial incentive for the CFP® and/or the IAR to recommend additional services that could be executed through the firm. However, implementation of Financial Plan recommendations is entirely up to the client, the Financial Plan could be implemented with another firm, and clients are not obligated to use RMS or its IARs for financial planning services. Plan Sponsor Consulting Services RMS also offers investment advisory services directly to plan sponsors. Acting in a fiduciary capacity, RMS offers services from recommending investments for a retirement plan to discretionary services of selecting an investment line-up for retirement plans. Plan sponsors can choose from three types of fiduciary services:  3(21) Non-Discretionary Investment Advisory Services - RMS will review, monitor and recommend investments for the retirement plan based on a prudent investment selection process that follows an Investment Policy Statement developed in conjunction with the Plan Sponsor. Plan sponsors will approve and implement the recommendations.  3(38) Discretionary Investment Management Services - The plan sponsor directs RMS to take full responsibility and discretion over the selection, monitoring, replacement, and implementation of the plan’s investment options.  3(38) Plus Discretionary Investment Management Services with Managed Accounts - Similar to 3(38) service, 3(38) Plus also includes risk-based portfolios that give participants pre- constructed, diversified allocations that match their investment timeframe and tolerance for risk. Portfolios may be used as a qualified default investment alternative (certain conditions apply) or voluntarily by participants under the guidance of a financial advisor. Plan Sponsor clients wishing to engage RMS for the provision of its consulting services must complete RMS’s agreement documents. The term of engagement will be an ongoing term, as set forth in the Agreement. Termination of Agreement Either party may terminate this Agreement upon thirty (30) days prior written notice to the other party. Such termination will not, however, affect the liabilities or obligations of the parties arising from transactions initiated prior to such termination, and such liabilities and obligations (together with the provisions of the agreement) shall survive any expiration or termination of this Agreement. Educational Seminars RMS also provides investment education seminars as a service to financial advisors, individual clients, prospective clients and/or plan sponsors. These seminars are intended to help individual employees better understand their company's qualified savings plan, and include information about the plan structure, the merits of saving and investing, the general asset classes available, the specific investment options in the plan, income tax considerations, and plan rules regarding loans, withdrawals and distributions. Assets Under Management As of December 31, 2023, across 3,955 individual accounts, RMS managed $1,438,988,116 in discretionary assets. We do not have any non- discretionary client assets under management. Additionally, we provide investment advice on an additional $10,183,232 of assets that are directly managed by the client. These assets are not considered assets under management since they are not traded by RMS.