A. Firm Information Round Rock Advisors LLC (“Round Rock” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Round Rock is organized as a Limited Liability Company (“LLC”) under the laws of the State of Connecticut. Round Rock was founded in April 2017 and is owned and operated by Bert T. Bowler (Principal). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Round Rock. In September 2023, Jeffrey Shaw joined Round Rock to operate the Armstrong Shaw Division of Round Rock (“ASD”). Mr. Shaw was previously Chief Investment Officer and Portfolio Manager and of Armstrong Shaw Associates Inc., a registered investment adviser that planned to terminate its operations in the Fall of 2023. He will manage client accounts as described in Items 4B, 5A, 8A, 12B, and 14A, including accounts for those clients of Armstrong Shaw Associates Inc. who open accounts at Round Rock. B. Advisory Services Offered Round Rock offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Round Rock’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Round Rock provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Round Rock devotes the time to work closely with each Client to identify their unique needs, priorities, investment goals and objectives as well as risk tolerance and financial situation in order to create a straightforward, intelligent portfolio strategy. Round Rock will then construct its portfolios utilizing diversified mutual funds and/or exchange-traded funds (“ETFs”), in order to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, alternative investments or options contracts to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. Round Rock’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Round Rock will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Round Rock evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Round Rock may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Round Rock may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Round Rock may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Round Rock accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Page 6 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – Round Rock may also recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the

Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain aligned investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures), and Form CRS. Fixed Income Portfolios – Round Rock generally recommends that a Client seeking a personalized portfolio of fixed income investments utilize Smith Affiliated Capital Corp. (“SAC”) pursuant to a sub- advisory agreement between Round Rock and SAC. SAC is an Independent Manager as described above, and is a registered investment advisory firm specializing in fixed income investment that provides investment advice for separately managed portfolios of individuals, including high net worth individuals and institutional investors, including, public and corporate retirement plans, corporations, foundations and government entities. Additional information regarding SAC is available in SAC’s Form ADV Brochure and Form CRS. Clients who may utilize SAC’s services are advised to read those documents carefully. Also see Item 5 below for information about SAC’s fees. Round Rock does not receive any compensation for referring clients to SAC. Financial Planning Services Round Rock will typically provide a variety of financial planning and consulting services to Clients, either as a component of investment management services or pursuant to a written financial planning agreement. Services are comprehensive in nature, which allows the Advisor to view the Client’s affairs holistically to address several areas of a Client’s financial situation, based on their goals and objectives. Generally, such financial planning services involve creating a solution focused approach to financial planning designed to allow the Client to make an informed decision about investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation. Round Rock’s planning approach generally consist of the following six (6) steps: 1. Identify needs and goals 2. Gather information 3. Assess strategies and develop a plan 4. Present recommendations and finalize plan 5. Implement plan 6. Review, measure and refine plan In addition, Round Rock works with the Client’s accountant, attorney or other specialists, as appropriate for their unique situation. By working with this network of skilled professionals, the Advisor leverages these unique insights Page 7 to provide solutions that comprehensively addresses the Client’s financial situation and helps to reach their goals and objectives. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Armstrong Shaw Division The Armstrong Shaw Division has a disciplined, absolute value approach to the equity market. ASD believes that investing in high quality businesses with strong cash flow generation run by proven management teams at attractive prices will provide superior returns over time. ASD seeks to provide attractive long term returns by investing in a concentrated portfolio assembled through bottom up, fundamentally driven stock selection. ASD invests in securities where cash flow or asset value analysis determines that a company's stock is selling at a substantial discount to its intrinsic value. C. Client Account Management Prior to engaging Round Rock to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Round Rock, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – Round Rock will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Round Rock will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Round Rock will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Round Rock does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Round Rock. E. Assets Under Management As of December 31, 2023, Round Rock the Advisor manages $673,293,156 in Client assets, $643,550,878 which are managed on a discretionary basis and $29,742,278 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.