In 1976, Richard S. Crum founded RS Crum Advisory Services, which was incorporated in 2003 as R. S. Crum, Inc. (“RS Crum Inc.,” the “Firm,” “we,” “our,” or “us”). In July 2011, the Firm completed a transfer of ownership to senior employees. Currently, RS Crum Inc.’s principal owners are Mark Rylance, Jon Theriault, and Daniel Sexton. RS Crum Inc. is an SEC registered investment adviser. Registration with the SEC does not in any way constitute an endorsement by the SEC of an investment adviser's skill or expertise. Since our beginning, RS Crum Inc. has provided investment management, financial planning, and business consulting services on a FEE ONLY basis to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. The Firm does not participate or offer product sales (or accept commissions) in connection with services. We believe this enhances objectivity to our clients. The client always maintains control of their assets as their accounts are held by a qualified custodian. The Firm does not act as a custodian of client assets, providing additional security for the client. Types of Advisory Services RS Crum Inc. manages investments primarily on a discretionary and, in limited circumstances, on a non- discretionary basis. On a more than an occasional basis, the Firm provides advice to clients on matters not involving securities as further described below. The scope of financial advice and/or planning services differs from client to client depending on their specific need. RS Crum Inc. provides services on a continuous (ongoing) and limited engagement basis. RS Crum Inc. offers both comprehensive financial services and services that are limited in scope. Areas that could be covered include:
• Budget, Cash Flow, and Net Worth Assessment
• Summary of Client Goals
• Investment Management
• Retirement Analysis
• Transitional Event Planning
• Real Estate Analysis
• Business Consulting The Firm might also work with a client’s other advisors as they generally relate to estate planning, tax planning, and / or insurance. See below Item 14 – Client Referrals and Other Compensation. Services that are Limited in Duration RS Crum Inc. offers engagements of limited duration up to one year. The cost of a limited engagement does not include the follow up or monitoring of future activities. In addition, the limited engagement does not include periodic review nor is there any obligation on the part of the client to re-utilize RS Crum Inc. Clients who previously received services on a limited engagement may choose to have such services updated and/or modified. This decision is solely that of the client. RS Crum Inc. does not send periodic reminders or advocate any specific time frame wherein a “financial check-up” may become advantageous. However, the client is told that time and economic circumstances do change and that every financial plan will need modification and/or revision at some future time. The policy of RS Crum Inc. is to charge a flat fee for such services. Continuous (On-Going) Advisory Services Clients may engage RS Crum Inc. for financial services on an ongoing basis (i.e., month to month). A fee, paid monthly or quarterly, is determined and agreed upon by both parties prior to entering any service arrangement. The fee and billing schedule are included in a formal engagement contract. This contract is signed by parties and retained on file before work begins. An electronic copy is also retained. A fee might be determined that may not relate purely to asset management. This fee might be based on estimated work and responsibilities attributable to the service provided in other financial areas such as estate planning, income tax planning, retirement analysis, business consulting, etc. Ongoing investment management is normally conducted on a discretionary basis. Although clients participate in identifying specific goals, they usually are not involved in the “day-to-day” specificity of investment selection. Clients receive periodic statements and confirmations of trading activity from independent account custodian(s) or third-party administrator(s). RS Crum Inc. receives duplicate account statements and confirmations. RS Crum Inc. DOES NOT maintain general powers of attorney over client accounts. New Clients (Limited Duration and Continuous Advisory Clients) An initial consultation is given free of charge to potential clients. This meeting may include a general discussion of their financial options, alternatives, and goals in one or more of the following financial areas, but not limited to:
• Budget, Cash Flow, and Net Worth
• Investments
• Income Tax
• Retirement
• Estate
• Real Estate
• Business Consulting A copy of the ADV Part 2A (Brochure) is generally delivered to any potential new client(s) prior to the initial conference or it is provided at the initial meeting, but otherwise no later than at time of contract signing. Prospective clients are normally asked to provide the following at or prior to the initial meeting:
• Most recent year’s income tax returns
• Brief description of assets and liabilities (or a financial statement if available)
• Brief written description of goals or special questions or matters to be covered during that session
• Any additional data that may be relevant to the discussions The

initial interview session generally lasts from 1 to 2 hours. No decision is required to engage RS Crum, Inc. at the initial meeting or to the cost, duration, or scope of services that might be provided. Prospective clients are typically contacted within several business days of the initial consultation to discuss such matters. A written engagement letter is prepared for each client prior to commencing any specified activity. In part, this letter discusses cost and duration of services as well as specific areas the client wishes to be included. Financial areas not specified in the Advisory/Engagement Letter are not included. Generally, a portion of the fee is due on signing, to pay for services in advance. Such advanced fees usually cover the first quarter of services. A signed copy of this letter is required in advance of any work and is retained on file. An electronic copy is also retained. Investment Management RS Crum Inc. manages client accounts on an individual basis separate from other client portfolios. Our goal is to manage risk and accumulate wealth safely for our clients. Individual portfolios are based on an asset allocation invested across an array of asset classes that may include cash, stocks, bonds, and alternative investments. RS Crum Inc. provides continuous and regular investment services on a discretionary basis. We have the ongoing responsibility to select and/or make recommendations, based upon the objectives of the client, as to specific securities and / or asset allocation. Our investment management services include designing, implementing, and continued monitoring of client accounts, limited only by the client’s individual needs and any restrictions imposed on the account. Our asset allocation models and recommendations for new portfolios consist of various types of securities, depending on the investment objective of each model, the client’s objectives, and/or the size of the account. Below under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss we discuss the types of securities that we recommend. Non-managed Accounts Assets or securities that are identified as non-managed are removed from managed accounts or designated as non-managed within RS Crum Inc.’s portfolio management platform. RS Crum Inc. will only be responsible for the supervision and management of securities we recommend. RS Crum Inc. will not be responsible for the supervision or management of non-managed assets. Non-managed assets are not included in the calculation of portfolio investment performance or fees, nor does RS Crum Inc. monitor non-managed assets. Non-managed assets may include securities held in a client’s account that is under management with RS Crum Inc. that were: 1. Delivered into the account by the client; 2. Purchased by the client; 3. Purchased by RS Crum Inc. at the request of the client as an accommodation; or 4. Designated by the client to be non-managed securities. Clients are instructed to keep RS Crum Inc. informed of changes in their financial situation. Financial Planning RS Crum Inc. offers advice through written financial plans and/or consultations. Written plans may involve analysis and discussions with the client, and usually involve cash flow projections to model the potential outcomes of retirement, estate planning, and other decisions. This might include examining different retirement dates, real estate or business sales, evaluating employee stock options, educating children or grandchildren, support of parents or heirs with special needs, inheritances or other scenarios. Certain consultations address immediate and specific issues, such as deciding on a pension option, leasing or buying a car or choosing a mortgage. Analysis or research of such topics may be limited since these are discussions to resolve a short-term concern. Financial planning may be the only service provided to the client and does not require that the client use or purchase the investment advisory services offered by the Firm. The client is under no obligation to act upon RS Crum Inc.’s recommendations, and if the client elects to act on any of the recommendations, the client is under no obligation to implement through the Firm. Retirement Investment Advice When we provide investment advice to clients regarding their retirement plan accounts or individual retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The receipt of our advisory fee for making a recommendation creates a conflict of interest under ERISA/IRC between our interests and the clients’ interests, so we operate under a special rule that requires us to act in the clients’ best interests and not put our interest ahead of theirs. For example, if we recommend that a client roll over assets from one retirement account to another and we will receive increased compensation as a result of that recommendation, we have a conflict that requires us to operate under this special rule. Assets Under Management RS Crum Inc.’s discretionary assets under management as of December 29, 2023, were $574,776,004. On occasion, RS Crum Inc. is asked to help with the supervision of and reporting of accounts on a non- discretionary basis. As of December 29, 2023, RS Crum Inc.’s non-discretionary assets under management were $11,384,375.