RTWM provides financial planning, consulting, investment management, and wealth management services. Prior to engaging RTWM to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with RTWM setting forth the terms and conditions under which RTWM renders its services (collectively the “Agreement”). The Firm has been in business since May 2011, and is principally owned by Don L. Ray and Matthew T. Theil. This Disclosure Brochure describes the business of RTWM. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of RTWM’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on RTWM’s behalf and is subject to RTWM’s supervision or control. Financial Planning and Consulting Services RTWM may provide its clients with a broad range of comprehensive financial planning and consulting services. These services include business planning, investments, insurance, retirement, estate planning, tax planning, accounting and tax and cash flow needs of the client. These services may be included as part of RTWM’s wealth management services, described below. In performing its services, RTWM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. RTWM may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if RTWM recommends its own services. The client is under no obligation to act upon any of the recommendations made by RTWM/ under a financial planning or consulting engagement or to engage the services of any such recommended professional, including RTWM itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of RTWM’s recommendations. Clients are advised that it remains their responsibility to promptly notify RTWM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising RTWM’s previous recommendations and/or services. Investment Management Services Clients can engage RTWM to manage all or a portion of their assets on a discretionary basis. In addition, RTWM may provide clients with wealth management services which generally include a broad range of comprehensive financial planning and consulting services as well as discretionary management of investment portfolios. RTWM primarily allocates clients’ investment management assets among Independent Managers (as defined below), mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with the investment objectives of the client. RTWM may also provide advice about any type of investment held in clients' portfolios. RTWM may render non-discretionary investment management services to clients relative to variable life/annuity products that they may own, their individual employer-sponsored retirement plans, or other products that may not be held by the client’s primary custodian. In so doing, RTWM either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian

designated by the product. RTWM tailors its advisory services to the individual needs of clients. RTWM consults with clients initially and on an ongoing basis to develop an investment policy statement which determines risk tolerance, time horizon and other factors that may impact the clients’ investment needs. RTWM ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. RTWM does not participates in a wrap fee program. Clients are advised to promptly notify RTWM if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon RTWM’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in RTWM’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Use of Independent Managers As mentioned above, RTWM recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between RTWM or the client and the designated Independent Managers. RTWM renders services to the client relative to the discretionary selection or recommendation of Independent Managers. RTWM also monitors and reviews the account performance and the client’s investment objectives. RTWM receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending or selecting an Independent Manager for a client, RTWM reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that RTWM considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, RTWM’s investment advisory fee set forth above. As discussed above, the client may incur additional fees than those charged by RTWM, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to RTWM’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than RTWM. In such instances, RTWM may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. As of December 31, 2023, RTWM has approximately $220,870,985 in assets under management, all of which are managed on a discretionary basis.