RiverTree offers a variety of advisory services, including investment management services, financial planning and consulting. Prior to rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with RiverTree setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). RiverTree was formed in January of 2013 and is wholly owned by Theodore S. Rich. As of December 31, 2023, RiverTree had $168,664,449 in assets under management, $167,671,615 of which was managed on a discretionary basis and $992,834 managed on a non-discretionary basis. While this brochure generally describes the business of RiverTree, certain sections also discuss the activities of its Supervised Persons, which refers to the Firm’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 RiverTree’s behalf and is subject to the Firm’s supervision or control. Investment Management Services RiverTree manages client investment portfolios on a discretionary or (in certain circumstances) non-discretionary basis. RiverTree actively allocates client assets among one or more of its proprietary investment styles. In managing each of these styles, the Firm uses a variable mix of globally diverse investment holdings, which seek to obtain asset class, sector, geographic and other exposure through exchange-traded funds (“ETFs”) and mutual funds, as well as individual securities, such as stocks and bonds. RiverTree also may provide advice to clients regarding certain investment products which are not maintained at their primary custodians, such as assets held in their employer-sponsored retirement plans. In these situations, RiverTree directs or recommends the allocation of the client’s assets among the various investment options available with the product. These assets are maintained at the custodian designated by the employer‘s provider. RiverTree tailors its advisory services to accommodate the needs of its clients and continuously seeks to ensure its clients’ portfolios are managed in a manner consistent with their specific investment profiles. RiverTree consults with clients on an initial and ongoing basis to determine

their specific risk tolerance, time horizon, liquidity constraints and other factors relevant to the management of their portfolios. Clients are advised to promptly notify RiverTree 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 RiverTree determines, in its sole discretion, that such conditions would not materially impact the performance of an investment strategy or prove overly burdensome to the Firm’s management efforts. These investment management services do not include securities brokerage services, as RiverTree does not serve as the sponsor or manager of a wrap fee program (i.e., an arrangement where brokerage trading costs and transaction costs are absorbed by the Firm). Financial Planning and Consulting Services In addition to investment management services, RiverTree also may offer clients a variety of financial planning and consulting services, including any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Asset Allocation
• Retirement Planning
• Estate Planning
• Financial Reporting
• Insurance Needs Analysis
• Charitable Giving
• Risk Management
• Distribution Planning In performing these services, RiverTree 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. RiverTree may recommend its own services, and/or the services of other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if RiverTree recommends its own services. Clients are under no obligation to act upon any of the recommendations made by RiverTree under a financial planning or consulting engagement or to engage the services of any such recommended professional, including RiverTree itself. Clients retain absolute discretion over all such implementation decisions. Clients are advised that it remains their responsibility to promptly notify RiverTree if there is any change in their financial situation or investment objectives.