RCM offers a variety of advisory services, which include investment management, financial planning, and consulting services. RCM has been an independent registered investment adviser since January 2012 and is wholly owned by James A. Rench. As of March 4, 2024, RCM had $372,002,941 in assets under management, all of which was managed on a discretionary basis.
Prior to the rendering of any advisory services, clients are required to enter into one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”).
While this brochure generally describes the business of RCM, certain sections also discuss the activities of the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees and other persons who provide investment advice on RCM’s behalf and are subject to the Firm’s supervision or control (each such person, a “Supervised Person” and collectively, “Supervised Persons”).
INVESTMENT MANAGEMENT SERVICES RCM manages client investment portfolios on a discretionary basis. Financial planning and consulting services, as discussed below, may also be rendered in conjunction with investment management services. RCM primarily allocates client assets among individual equity securities, individual fixed-income securities, mutual funds, exchange-traded funds (“ETFs”), interval funds, and, in limited circumstances, options, in accordance with the investment objectives of its clients. Clients may also engage RCM to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer-sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, RCM directs or recommends the allocation of client assets among the various investment options available with the product. In addition, where appropriate, the Firm may provide advice about any type of legacy position or other investment held in client portfolios.
RCM tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. The Firm consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify RCM if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if the Firm determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
FINANCIAL PLANNING AND CONSULTING SERVICES As mentioned above, RCM may provide clients with financial planning and consulting services as part of its investment management services. However, the Firm may also provide such services on a stand-alone basis. Financial planning and consulting services may include any or all of the following: When appropriate, RCM advises clients to engage the services of professionals who specialize in the particular planning areas listed above (e.g., estate planning counsel). In performing these services, RCM is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information.
The Firm may recommend the services of itself or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage RCM to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by the Firm under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including RCM itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising RCM’s previous recommendations and/or services.
IRA ROLLOVERS: CONSIDERATIONS AND CONFLICTS In connection with initial or ongoing investment advisory services that RCM provides, it may recommend that a new or existing client withdraw assets from such client’s employer-retirement plan and roll those assets over to an IRA that RCM manages on the client’s behalf. It is important to understand that a conflict of interest exists in this situation since, upon rolling assets over to an IRA that RCM manages, it will charge an investment management

fee in accordance with the fee schedule set forth in Item 5, below. This conflict of interest means that there is an incentive for RCM’s investment adviser representatives to recommend an IRA rollover since this would result in additional fee-based compensation to RCM. No client or prospective
• Retirement Plan Analysis
• Distribution Planning
• Social Security Planning
• Risk Management
• Investment Analysis
• Asset Allocation
• Cash Flow Forecasting
• Estate Planning
• Insurance Needs Analysis
• Financial Reporting
• Charitable Giving
• Medicare Planning client is under any obligation to roll assets to an IRA, whether managed by RCM or not. If an IRA rollover is done, no client or prospective client is under any obligation to have RCM manage the assets in such IRA. Many employers allow former employees to continue to keep their retirement assets inside of the company’s retirement plan. It is important to consider the costs and benefits of choosing whether to complete an IRA rollover or, alternatively, to keep retirement assets inside a company’s retirement plan. A non-exhaustive list of considerations is set forth below.
Fees and Expenses Before choosing whether to roll assets to an IRA from a company retirement plan, it is important to compare the fees and expenses associated with each option. For example, fees common in company retirement plans include custodial, record-keeping, administrative and other similar fees. In comparison, fees common to an IRA include administrative, account setup and custodial fees. In addition, if RCM is engaged to manage the IRA assets, an additional investment management fee will be charged in accordance with the fee schedule set forth in Item 5, below. If fees are higher under either the company retirement plan or an IRA rollover (including an IRA rollover managed by RCM), it is important to weigh the costs and benefits associated with any additional services being provided by the more expensive option.
Investment Choices IRAs typically offer access to a broader array of investment options than a company retirement plan. However, it is important to consider the investments available inside a company’s retirement plan, whether the client is comfortable with such options and whether they may carry lower costs than funds to which the client may have access in an IRA.
Services A client should consider what services will be received in relation to the fees incurred if assets are kept inside a company’s retirement plan, and those services should be compared with services that will be received if the assets are rolled over to an IRA (including an IRA managed by RCM).
Penalty-Free Early Withdrawals Many company retirement plans allow penalty-free withdrawals from the company retirement plan if the employee separates from service in the year such employee turns 55 or later. Therefore, if an employee leaves employment in the year in which such employee turns 55 or later, by rolling assets from the company retirement plan to an IRA, the (former) employee would be giving up the right to take penalty-free early withdrawals between the ages of 55 and 591/2. Protection from Creditors and Legal Judgments There are additional protections for assets held inside a company retirement plan compared to assets held inside an IRA. While assets held inside an IRA are protected in the bankruptcy context, unlike a company retirement plan, they do not provide unlimited protections from creditors under federal law.
Required Minimum Distributions For IRA owners who turned 701/2 during or prior to 2019, such owners were required to begin taking annual required minimum distributions (“RMDs”) beginning with the year in which such owners turned 701/2. For IRA owners who turned 701/2 during or after 2020 but prior to 2023, such owners were required to begin taking RMDs beginning with the year in which such owners turned age 72. For IRA owners turning 72 during or after 2023, but prior to 2033, such owners are required to begin taking RMDs beginning with the year in which such owners turn age 73. Beginning in 2033, IRA owners will be required to begin taking RMDs beginning with the year in which such owners turn age 75. When retirement assets are held in an IRA, RMDs are required regardless of whether or not the IRA owner is still working. In contrast, if a participant in a company retirement plan continues working past age 701/2, 72, 73, or 75, as applicable, and holds his or her retirement assets in that company’s retirement plan, there is no RMD requirement for those assets as long as the participant continues working for that employer. Therefore, by keeping retirement assets inside their employer’s retirement plan, a participant is able to continue to enjoy the benefit of tax deferral as long as they continue working for such employer. This benefit would not be available if the assets were instead rolled over to an IRA.