A. Firm Information Return on Investment, LLC (“ROI” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company under the laws of the State of Wyoming, effective April 2021. Previously, the Advisor was organized as a limited liability company under the laws of the State of California. ROI was a registered investment advisor from August 2009 through November 2014. ROI became registered again as an investment advisor in February 2019. ROI is owned and operated by William R. DuBois (Managing Member and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by ROI. B. Advisory Services Offered ROI offers investment advisory services to clients such as private trusts and private holding companies (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the 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. ROI’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services ROI provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing non-discretionary investment management and related advisory services. ROI works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. ROI will then construct an investment portfolio, consisting of low-cost, diversified mutual funds, unit investment trusts and alternative investments to achieve the Client’s investment goals. The Advisor may also utilize individual stocks and bonds to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations ROI’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate investments that have been held for less than one year to meet the objectives of the Client or due to market conditions. ROI 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. ROI evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. ROI may recommend, on occasion, redistributing investment allocations to diversify the portfolio. ROI may recommend specific positions to increase sector or asset class weightings. ROI 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 ROI 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 the designated account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices. C. Client Account Management Prior to engaging ROI to provide investment advisory services, each Client is required to enter into one or more advisory agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: Page 5
• Establishing an Investment Strategy – ROI, in connection with the Client, will develop a strategy targeted to achieve the Client’s goals and objectives.
• Asset Allocation – ROI 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 – ROI will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – ROI will provide investment management and ongoing oversight of the Client’s portfolio. D. Wrap Fee Programs ROI does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by ROI. E. Assets Under Management As of December 31, 2022, ROI manages approximately $747,000,000 in Client assets, all of which are on a non- discretionary basis. Clients may request more current information at any time by contacting the Advisor.